Proposal Supporting Statement 080508

SUPPORTING STATEMENT
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR
AREA SOURCES: FERROALLOYS PRODUCTION FACILITIES

PART A
1.0

Identification of the Information Collection

(a)

Title and Number of the Information Collection.
“National Emission Standards for Hazardous Air Pollutants for Area Source: Ferroalloys

Production Facilities.” This is a new information collection request (ICR), and the EPA tracking
number is 2303.01
(b)

Short Characterization.
This ICR covers information collection requirements in the proposed area source rule for

Ferroalloys Production Facilities (40 CFR part 63, subpart YYYYYY). The information
collected will be used by EPA and delegated state and local agencies to determine the
compliance status of sources subject to the rule.
The potential respondents are owners or operators of any existing or new
electrometallurgical operation located at an area source that produces silicon metal, ferrosilicon,
ferrotitanium using the aluminum reduction process, ferrovanadium, ferromolybdenum, calcium
silicon, silicomanganese zirconium, ferrochrome silicon, silvery iron, high-carbon ferrochrome,
charge chrome, standard ferromanganese, silicomanganese, ferromanganese silicon, calcium
carbide or other ferroalloy products. manufactures silicon metal, ferrosilicon, calcium silicon,
silicomanganese zirconium, ferrochrome silicon, silvery iron, high-carbon ferrochrome, charge
chrome, standard ferromanganese, silicomanganese, ferromanganese silicon, calcium carbide or
other ferroalloy products. We believe there are 10 facilities currently operating that would be
subject to National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the
Ferroalloys Production Area Source Category. The affected source is each new or existing
metallurgical operation and covers all charging, smelting, and product tapping operations.
Fugitive emissions from the furnace building would also be controlled. Existing area source
ferroalloys production facilities are currently well-controlled in terms of metal air toxics
1

emissions as a result of state and national standards, permitting requirements, and/or
management practices already taken by the industry to reduce particulate matter. We estimate
that the only impact associated with the proposed rule is the compliance requirements
(monitoring, reporting, recordkeeping, and testing) which is estimated to be approximately
$6,100 per facility.
The proposed standards establish a limit, as measured by Method 22, on the duration of
visible emissions (VE) from the control device(s) on the electrometallurgical operations. The
Method 22 test is designed to measure the amount of time that any VE are observed during an
observation period. The owner or operator must demonstrate that the control device outlet
emissions do not exceed 3 percent of accumulated occurrences in a 60-minute observation
period. We refer to this as the 3 percent limit throughout this document. Sources are required to
conduct an initial and ongoing semiannual Method 22 test of the control device outlet.
Monitoring is based on a daily observation of visible emissions from the control device outlet. If
any emissions are observed, the source must conduct a Method 22 test within 24 hours.
The standards also consist of a 20 percent opacity limit on the furnace building, with an
upper limit of up to 40 percent opacity for any single six-minute reading. The opacity limit is
designed to ensure that the source minimizes fugitive emissions from the EAF operations. The
source must conduct a semiannual EPA Method 9 observation to demonstrate compliance with
this limit. In order to provide flexibility to sources and reduce the costs of demonstrating
compliance, sources may elect to monitor visible emissions using a Method 22 test in place of
the semiannual Method 9 test. The Method 22 test is successful if no visible emissions are
observed for 90 percent of the readings over the furnace cycle (tap to tap) or 60 minutes,
whichever is more. If visible emissions are observed greater than 10 percent of the time over the
furnace cycle or 60 minutes, whichever is more, then the facility must conduct a Method 9 test as
soon as possible, but no later than 15 calendar days after the Method 22.
The information collection requirements for existing and new sources in the Ferroalloys
Production Source Category are listed in Attachment 1.

2

2.

Need For and Use of the Collection

(a)

Need/Authority for the Collection.
Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both

major and area sources of HAP that are listed for regulation under CAA section 112(c). An area
source is a stationary source that is not a major source (i.e., an area source does not emit and
does not have the potential to emit more than 10 tons per year [tpy] of any single HAP and more
than 25 tpy of any combination of HAP). Requirements for area sources in CAA sections
112(c)(3) and 112(k) direct EPA to (1) identify at least 30 air toxics that present the greatest
potential health threat in the largest number of urban areas and (2) to identify sufficient area
source categories to ensure that sources representing 90 percent or more of the emissions of the
30 “listed” HAP are subject to regulation. EPA implements these requirements through the
Integrated Urban Air Toxics Strategy (64 FR 38715, July 19, 1999). We added the source
category to the Integrated Urban Air Toxics Strategy area source category list on November 22,
2002 (67 FR 70427). Ferroalloys production was listed for its contributions toward meeting the
90 percent requirement of chromium compounds, manganese compounds, and nickel
compounds. Each of these HAP metals is on the list of 30 HAP identified in the 1999 strategy.
Under CAA section 112(d)(5), EPA may elect to promulgate HAP standards for area
sources based on the use of generally available control technology (GACT) or management
practices used by the sources. EPA can consider costs and economic impacts in determining
GACT, which is particularly important when developing regulations for source categories that
may have few establishments and many small businesses, or when determining whether
additional control is needed for sources that are already well-controlled as a result of other air
emissions standards.
Certain records and reports are necessary for the Administrator to confirm the
compliance status of area sources, identify any new or reconstructed sources subject to the
standards, and confirm that the standards are being achieved on a continuous basis. These
recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean
Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The
recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and
40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5
3

years following the date of each occurrence, measurement, maintenance, corrective action,
report, or record.
(b)

Use/Users of the Data.
The information will be used by the delegated authority (state agency, or Regional

Administrator if there is no delegated state agency) to ensure that the standards and other
requirements are being achieved. Based on review of the recorded information at the site and the
reported information, the delegated permitting authority can identify facilities that may not be in
compliance and decide which facilities, records, or processes may need inspection.
3.

Nonduplication, Consultations, and Other Collection Criteria

(a)

Nonduplication.
A computer search of EPA’s ongoing ICRs revealed no duplication of information-

gathering efforts. The information collection requirements in 40 CFR part 63, Subpart XXX
apply only to ferroalloy production facilities that are major sources of HAP. The information
collection requirements in 40 CFR part 60, subpart Z New Source Performance Standards
(NSPS) apply to two of the existing sources and would apply to new sources. These
requirements are not inconsistent with the proposed area source rule and would be reconciled in
the Title V permit.
(b)

Public Notice Required Prior to ICR Submission to OMB.
This is a rule-related ICR and comments will be solicited on the proposal package and

this ICR.
(c)

Consultations.
The proposed rule was developed in consultation with individual companies and state

agencies. The key non-EPA persons consulted on the information collection activities are
identified in Table 1.
TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES
Contact

Organization

Email address

Edward Bredniak

CC Metals & Alloys

[email protected]

Don Elverd
Matt Greene

Tennessee Alloys Corporation
Globe Metallurgical Inc.

[email protected]
[email protected]

Eugene Hogan
Rick Poynter,

Simcala Inc. (Consultant)
Carbide Industries

[email protected]
[email protected]
4

Contact
Dave Renfrew

Organization
Elkem Metals

Email address
[email protected]

Frank Sizemore
Joe Smydo
David White

Carbide Industries
Langeloth Metallurgical
Metallurg Vanadium

[email protected]
[email protected]
[email protected]

(d)

Effects of Less Frequent Collection.
If the relevant information were collected less frequently, the delegated permitting

authority (State or EPA) will not be reasonably assured that a facility is in compliance with the
standards.
(e)

General Guidelines.
None of the guidelines in 5 CFR 1320.6 are being exceeded.

(f)

Confidentiality.
All 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 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR
17674, March 23, 1979).
(g)

Sensitive Questions.
This section is not applicable because this ICR does not involve matters of a sensitive

nature.
4.

The Respondents and the Information Requested

(a)

Respondents/NAICS Codes.
Potential respondents under Subpart YYYYYY are owners or operators of any existing

or new ferroalloys production facility that is an area source of HAP emissions. The North
American Industry Classification System (NAICS) codes for ferroalloys production facilities are
331112, 331419, and 325188. We estimate that 10 area source facilities will be subject to the
NESHAP; no new area sources are projected during the 3 year period of this ICR.
(b) Information Requested.

5

(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information
Requirements, summarizes the data items, including recordkeeping and reporting requirements,
for the Ferroalloys Production Area Source Category.
New sources would be required to use monitoring equipment that automatically records
parameter data. Although personnel at the affected facility must still evaluate the data, internal
automation has significantly reduced the burden associated with monitoring and recordkeeping
at a 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 20 percent of the respondents
use electronic reporting.
(ii) Respondent Activities. The respondent activities that will be required by the
proposed Ferroalloys Production Area Source NESHAP are identified in Table 2 (located at the
end of this supporting statement) and are introduced in section 6(a).
5.

The Information Collected–Agency Activities, Collection Methodology, and
Information Management

(a)

Agency Activities.
The Agency activities associated with the proposed Ferroalloys Production Area Source

NESHAP are provided in Table 4 (located at the end of this supporting statement) and are
introduced in section 6(c).
(b)

Collection Methodology and Management.
Data and records maintained by the respondents are tabulated and published for use in

compliance and enforcement programs of the delegated permitting authority. The notifications
of compliance status, annual compliance certifications, and reports of startups, shutdowns, and
malfunctions required under the proposed rule are used for problem identification, as a check on
source operation and maintenance, and for compliance determinations. EPA is the permitting
authority until the state agency is delegated authority to implement the final rule. Therefore,
information contained in the reports submitted to the Regional Administrator will be entered into
the Air Facility System (AFS), which is operated and maintained by EPA’s Office of

6

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.
(c)

Small Entity Flexibility.
The Small Business Administration defines a small entity as one that meets the Small

Business Administration size standards for small businesses found at 13 CFR 121.201 (less than
750 employees for NAICS 331112 and 331419 and less than 1,000 employees for NAICS
325188). We estimate that five facilities are small entities. However, our analysis indicates that
the proposed rule would not impose a significant adverse impact on any facilities, large or small,
since these costs are much less than 0.1 percent of revenues.
(d)

Collection Schedule.
The specific frequency for each information collection activity within this request is

shown in Table 4 for the Ferroalloys Production Area Source Category.
6.

Estimating the Burden and Cost of the Collection

(a)

Estimating Respondent Burden.
The annual burden estimates for the proposed Ferroalloys Production Area Source

NESHAP are shown in Table 2. These numbers were derived from estimates based on EPA’s
experience with other standards. No burden estimates are provided for new area sources because
no new facilities are expected to become affected sources during the 3-year period of this ICR.
(b)

Estimating Respondent Costs.
The information collection activities for the proposed Ferroalloys Production Area

Source NESHAP are presented in Table 2. Because the data are already collected by
respondents as part of normal operations, no respondent development costs are associated with
the information collection activities.
(i) Estimating Labor Costs. We relied on the 2002 Sixth Edition Control Cost Manual1

1

United States Environmental Protection Agency, Office of Air Quality Planning and Standards (January 2002)
EPA Air Pollution Control Cost Manual Sixth Edition EPA/452/B-02-001.

7

as well as various cost spreadsheets provided by EPA2 to estimate industry labor rates. Labor
rates have been calculated for 2007. We used May 2006 labor rates from the Bureau of Labor
Statistics for the Iron and Steel Mills and Ferroalloy Manufacturing (NAICS 331100),3 and
escalated them to 2007 rates using the Employment Cost Index (ECI) provided by the BLS for
the manufacturing industry.4 Loading factors (i.e., fringe benefits and overhead rates) were
calculated using methodologies referenced in promulgated regulations and their accompanying
Information Collection Requests (ICRs), particularly those used in New Source Review (NSR)
regulations. Fringe benefits are calculated as 29% of hourly earnings, and overhead is calculated
using a standard 110% above hourly earnings. Table 3 presents the labor rates used in the cost
analysis.
Table 3. 2006 LOADED LABOR RATES

Labor Category
Professional specialty and
technical
Installation, maintenance, repair
Executive, admin, managerial
Admin support

Hourly earnings
[$2006]

Fringe

31.20
21.87
47.05
14.07

1.29
1.29
1.29
1.29

Overhead
2.10
2.10
2.10
2.10

Loaded
84.52
59.25
127.46
38.12

ECI

Loaded 2007
Hourly
Earnings ($)

1.020
1.020
1.020
1.022

$86.18
$60.35
$129.96
$38.94

To estimate the costs of conducting the initial Method 9 test, we assumed that facilities
would hire a contractor to avoid the costs of having to certify plant personnel for Method 9
observations. We show this cost as a one-time expense in the ICR. The estimate is based on
information provided by a testing contractor (TRC Solutions.) 5
(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. There are no
estimated capital costs or O&M costs associated with the information collection requirements of
the proposed Ferroalloys Production NESHAP for area sources. The rule would not require the

2

Communication with Peter Westlin, EPA, February 2006.
May 2006 National Industry-Specific Occupational Employment and Wage Estimates. Located
http://www.bls.gov/oes/current/naics4_331100.htm
4
Bureau of Labor Statistics. Table 5. Compensation (not seasonally adjusted): Employment Cost Index for total
compensation, for private industry workers, by occupational group and industry. Available:
http://www.bls.gov/news.release/eci.t05.htm. Accessed April 25, 2008.
5
Communication with Jim Serne, TRC Solutions, March 17, 2008.
3

8

purchase or operation of testing or monitoring equipment. Capital and O&M costs were not
estimated for new sources because no new sources are expected during the next 3-year period.
(iii) Annualizing Capital Costs. Not applicable.
(c)

Estimating Agency Burden and Cost.
Because the information collection requirements were developed as an incidental part of

standards development, no costs can be attributed to the development of the information
collection requirements. Because reporting and recordkeeping requirements on the part of the
respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the
part 63 NESHAP General Provisions, no operational costs will be incurred by the Federal
Government. Publication and distribution of the information are part of the Compliance Data
System, with the result that no Federal costs can be directly attributed to the ICR. Examination
of records to be maintained by the respondents will occur incidentally as part of the periodic
inspection of sources that is part of EPA’s overall compliance and enforcement program, and,
therefore, is not attributable to the ICR. The only costs that the Federal government will incur
are user costs associated with the analysis of the reported information, as presented in Table 4.
The Agency labor rates are from the Office of Personnel Management (OPM) 2007
General Schedule which excludes locality rates of pay. These rates can be obtained from Salary
Table 2007-GS available on the OPM website, http://www.opm.gov/oca/07tables/html/gs_h.asp.
The government employee labor rates are $14.60/hour for clerical (GS-6, Step 3), $26.98 for
technical (GS-12, Step 1), and $36.36/hr for management (GS-13, Step 5). These rates were
increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates
used to represent Agency labor costs are: clerical at $23.36; technical at $43.17, and
management at $58.18.
(d)

Estimating the Respondent Universe and Total Burden and Costs.
There are an estimated 10 existing facilities that will be subject to the Ferroalloys

Production Area Source NESHAP. No new sources are expected during the next 3 years.
Consequently, the average annual number of ferroalloys production facilities during the 3-year
period of this ICR is 10
For the proposed Ferroalloys Production NESHAP, the components of the total annual
responses attributable to this ICR are one-time initial notifications, one-time notifications of
9

compliance status, and annual compliance certifications for the 10 facilities that will be subject
to the rule.
The number of total annual responses for subpart YYYYYY is estimated as: 32 (10
annual average respondents × 3 notifications, plus 2 average annual reports of exceedances).
(e)

Bottom Line Burden Hours and Cost Tables.
(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 recordkeeping and reporting requirements in subpart YYYYYY for the 10 existing
facilities that subject to the Ferroalloys Production Area Source NESHAP is 819 person-hours,
with an annual labor average cost of $61,122 and annualized capital costs of $0.
(ii) The Agency tally. The average annual Federal Government cost is $1,646 for
39 hours for subpart YYYYYY. The bottom line Agency burden hours and costs presented in
Table 4 (located at the end of this supporting statement) are calculated by adding person-hours
per year down each column for technical, managerial, and clerical staff, and by adding down the
cost column.
(iii) Variations in the annual bottom line. This section does not apply since no
significant variation is anticipated.
(f)

Reasons for Change in Burden.
We are requesting an increase in burden of 819 hours due to implementation of this new

regulation.
(g)

Burden Statement
The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 26 hours per response. The average annual respondent burden for the
proposed Ferroalloys Production Area Source NESHAP is estimated at 82 hours.
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
10

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 currently valid OMB control number. The OMB
control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.
To comment on the Agency’s need for this information the accuracy of the provided
burden estimates, and any suggestions for minimizing respondent burden, including through the
use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID No. EPA-HQ-OAR-2008-0154, which is available for online viewing at
http://www.regulations.gov, or in person viewing at the Air and Radiation 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
Air Docket is (202) 566-1742. An electronic version of the public docket is available at
http://www.regulations.gov. This site can be used to submit or view public comments, access
the index listing of the contents of the public docket, and to access those documents in the public
docket that are available electronically. When in the system, select “search,” then key in one of
the Docket ID Numbers identified above. Also, you can send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID
Number (EPA-HQ-OAR-2008-0154) in any correspondence.
PART B
This section is not applicable because statistical methods are not used in data collection
associated with the proposed rule.

11

T A B L E 2 A . Y e a r 1 A N N U A L R E S P O N D E N T B U R D E N A N D C O S T O F R E P O R T IN G
A N D R E C O R D K E E P IN G R E Q U IR E M E N T S O F T H E P R O P O S E D S T A N D A R D
(A )
P e rs o n h o u rs p e r
o c c u rre n c e

(B )
(C )
No. of
P e rs o n -h o u rs
o c c u rre n c e s
p e r re s p o n d e n t
p e r re s p o n d e n t
per year
per year
(C = A x B )

1.
2.
3.
4.
A.
B.

(D )
R e s p o n d e n ts
per year

(E )
T e c h n ic a l
p e rs o n -h o u rs
per year
(E = C x D )

(F )
M anagem ent
p e rs o n -h o u rs
per year
(E x 0 . 0 5 )

A p p lic a t io n s
N /A
S u r ve y a n d S t u d ie s
N /A
A c q u i s i t i o n , In s t a l l a t i o n , & U t i l i z a t i o n o f T e c h . & S y s t e m s
4 0 .0 0
1 .0
4 0 .0
0 .0
0 .0
R e p o rt in g R e q u ire m e n t s
R e a d in s t ru c t io n s (b )
4 .0 0
1 .0
4 .0
1 0 .0
4 0 .0
R e q u ire d a c t ivit ie s
O n e - t i m e a c t i v i t y . In i t i a l c o n t r o l d e v i c e M e t h o d 2 2 P l a n n i n g
8 .0 0
1 .0
8 .0
1 0 .0
8 0 .0
O n e - t i m e a c t i v i t y . In i t i a l c o n t r o l d e v i c e M e t h o d 2 2 T e s t
2 .0 0
1 .0
2 .0
1 9 .0
3 8 .0
P e rio d ic c o n t ro l d e vic e M e t h o d 2 2
2 .0 0
1 .0
2 .0
1 9 .0
3 8 .0
R e t e s t c o n t r o l d e vic e
2 .0 0
1 .0
2 .0
1 .0
2 .0
D a ily V E c h e c k (1 9 c o n t ro l d e vic e s )
0 .0 8
3 6 5 .0
2 9 .2
1 9 .0
5 5 4 .8
O n e - t i m e a c t i v i t y . In i t i a l b u i l d i n g o p a c i t y M e t h o d 9 ( c )
9 .0
P e rio d ic (s e m i-a n n u a l) b u ild in g V E M e t h o d 2 2
2 .0 0
1 .0
2 .0
9 .0
1 8 .0
R e t e s t b u ild in g o p a c it y M e t h o d 9
1 .0
C . C r e a t e i n fo r m a t i o n
S ee 4B
D . G a t h e r e x i s t i n g i n fo r m a t i o n
S ee 4B
E . W rit e re p o rt
S ee 4B
In i t i a l N o t i fi c a t i o n
2 .0 0
1 .0
2 .0
1 0 .0
2 0 .0
N o t i fi c a t i o n o f C o m p l i a n c e S t a t u s
4 .0 0
1 .0
4 .0
1 0 .0
4 0 .0
A n n u a l C o m p l i a n c e C e r t i fi c a t i o n ( d )
4 .0 0
1 .0
4 .0
1 0 .0
4 0 .0
R e p o rt o f E x c e e d e n c e s s (e )
2 .0 0
1 .0
2 .0
2 .0
4 .0
5 . R e c o rd k e e p in g R e q u ire m e n t s
A . R e a d in s t ru c t io n s
S ee 4A
B . P la n a c t ivit ie s
S ee 5E
C . Im p l e m e n t a c t i v i t i e s
S ee 5E
D . D e ve lo p re c o rd s y s t e m
S ee 5E
E . T i m e t o e n t e r i n fo r m a t i o n
R e c o r d s o f a l l i n fo . r e q u i r e d b y s t a n d a r d s ( f)
0 .2 5
1 2 .0
3 .0
1 0 .0
3 0 .0
F . T im e t o t ra in p e rs o n n e l
N /A
G . T im e t o a d ju s t e x is t in g w a y s t o c o m p ly w / p r e v. a p p l. re q .
N /A
H . T i m e t o t r a n s m i t o r d i s c l o s e i n fo r m a t i o n ( g )
0 .2 5
1 .0
0 .3
1 0 .0
2 .5
I. T i m e fo r a u d i t s
N /A
T O T A L A N N U A L B U R D E N A N D C O S T (S A L A R Y )
9 0 7 .3
T O T A L A N N U A L N U M B E R O F R E S P O N S E S (i)
A N N U A L C A P IT A L C O S T S :
T o t a l a n n u a l c a p it a l
0 .0 0
A N N U A L IZ E D C A P IT A L C O S T S :
T o t a l a n n u a liz e d c a p it a l
0 .0 0
T O T A L A N N U A L IZ E D C O S T S ( A n n u a l i z e d c a p i t a l + O & M c o s t s )
N / A = N o t A p p lic a b le .
( a ) C o s t s a r e b a s e d o n t h e fo l l o w i n g h o u r l y r a t e s : t e c h n i c a l a t $ 8 6 . 1 8 , m a n a g e m e n t a t $ 1 2 9 . 9 6 , a n d c l e r i c a l a t $ 3 8 . 9 4 , e x c e p t t h e d a i l y V E a n d M e t h o d 2 2 s a r e $ 6 0 . 3 5 .
( b ) O n e - t i m e a c t i v i t y . T h e r e a r e a n e s t i m a t e d 1 0 e x i s t i n g fe r r o a l l o y s p r o d u c t i o n fa c i l i t i e s a n d n o n e w fa c i l i t i e s a r e e x p e c t e d .
( c ) O n e - t i m e a c t i v i t y . A s s u m e t h e fa c i l i t i e s h i r e a c o n t r a c t o r . N o t a p p l i c a b l e t o fa c i l i t y w i t h s c r u b b e r , w h i c h h a s a b a g h o u s e o n t h e fu r n a c e b u i l d i n g .
( d ) T h e 1 0 e x i s t i n g p l a n t s w o u l d b e r e q u i r e d t o s u b m i t a n A n n u a l C o m p l i a n c e C e r t i fi c a t i o n a t t h e e n d o f Y e a r 1 o f t h e IC R a n d e a c h y e a r t h e r e a ft e r .
( e ) A s s u m e s t h a t 2 fa c i l i t i e s p e r y e a r w o u l d h a v e t o s u b m i t a R e p o r t o f e x c e e d e n c e .
( f) R e c o r d k e e p i n g r e q u i r e m e n t s b e g i n i n Y e a r 1 o f IC R c l e a r a n c e p e r i o d fo r a l l e x i s t i n g p l a n t s .

12

(G )
C le ric a l
p e rs o n -h o u rs
per year
(E x 0 . 1 )

(H )
C o s t , $ (a )

0 .0

0 .0

$

-

2 .0

4 .0

$

3 ,8 6 3

5 .0
0 .0
0 .0
0 .0
0 .0

0 .0
0 .0
0 .0
0 .0
0 .0

$
$
$
$
$

0 .0

0 .0

$

7 ,5 4 4
2 ,2 9 3
2 ,2 9 3
121
3 3 ,4 8 2
$ 1 8 ,0 0 0
1 ,0 8 6
$ 2 ,0 0 0

1 .0
2 .0
2 .0
0 .2

2 .0
4 .0
4 .0
0 .4

$
$
$
$

1 ,9 3 1
3 ,8 6 3
3 ,8 6 3
386

1 .5

3 .0

$

2 ,8 9 7

0 .1

0 .3

$

241

1 3 .8

1 7 .7

$

8 3 ,8 6 5
32

$

-

$
$

-

TABLE 2B. Year 2/3 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE PROPOSED STANDA
(A)
(B)
(C)
(D)
(E)
(F)
(G)
(H)
Cost,$ (a)
PersonNo. of Person-hourRespondentsTechnical Managemen Clerical
er responde per year person-hours
person-hours
person-hours
hours per occurrences
per year
per year
per year
occurrenceer responde per year
(C=AxB)
(E=CxD)
(Ex0.05)
(Ex0.1)
per year
1. Applications
N/A
2. Survey and Studies
N/A
3. Acquisition, Installation, & Utilization of Tech. & Systems
40.00
1.0
40.0
0.0
0.0
0.0
0.0
4. Reporting Requirements
A. Read instructions (b)
4.00
1.0
4.0
0.0
0.0
0.0
0.0
B. Required activities
One -time activity. Initial control device Method 22 Planning
8.00
1.0
8.0
0.0
0.0
0.0
0.0 $
One -time activity. Initial control device Method 22 Test
2.00
1.0
2.0
0.0
0.0
0.0
0.0
Periodic control device Method 22
2.00
2.0
4.0
19.0
76.0
0.0
0.0 $
4,587
Retest control device
2.00
1.0
2.0
1.0
2.0
0.0
0.0 $
121
Daily VE check (19 control devices)
0.08
365.0
29.2
19.0
554.8
0.0
0.0 $
33,482
One-time activity. Initial buidling opacity Method 9 (c)
0.0
$0
Periodic (semi-annual) building VE Method 22
2.00
2.0
4.0
9.0
36.0
0.0
0.0 $
2,173
Retest building opacity Method 9
1.0
0.0
0.0
0.0
$2,000
C. Create information
See 4B
D. Gather existing information
See 4B
E. Write report
See 4B
Initial Notification
2.00
1.0
2.0
0.0
0.0
1.0
1.0 $
Notification of Compliance Status
4.00
1.0
4.0
0.0
0.0
1.0
0.0 $
Annual Compliance Certification (d)
4.00
1.0
4.0
10.0
40.0
2.0
4.0 $
3,863
Report of Exceedencess (e)
2.00
1.0
2.0
2.0
4.0
0.2
0.4 $
386
5. Recordkeeping Requirements
A. Read instructions
See 4A
B. Plan activities
See 5E
C. Implement activities
See 5E
D. Develop record system
See 5E
E. Time to enter information
Records of all info. required by standards (f)
0.25
12.0
3.0
10.0
30.0
1.5
3.0 $
2,897
F. Time to train personnel
N/A
G. Time to adjust existing ways to comply w/ prev. appl. req.
N/A
H. Time to transmit or disclose information (g)
0.25
1.0
0.3
10.0
2.5
0.1
0.3 $
241
I. Time for audits
N/A
TOTAL ANNUAL BURDEN AND COST (SALARY)
745.3
5.8
8.7 $
49,750
TOTAL ANNUAL NUMBER OF RESPONSES (h)
12
ANNUAL CAPITAL COSTS:
Total annual capital
0.00
$
ANNUALIZED CAPITAL COSTS:
Total annualized capital
0.00
$
TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)
$
N/A = Not Applicable.
(a) Costs are based on the following hourly rates: technical at $86.18, management at $129.96, and clerical at $38.94, except that daily VE and Method 22s are $60
(b) One-time activity. There are an estimated 10 existing ferroalloys production facilities and no new facilities are expected.
(c) One-time activity. Assume the facilities hire a contractor. Not applicable to facility with scrubber, which has a baghouse on the furnace building.
(d) The 10 existing plants would be required to submit an Annual Compliance Certification at the end of Year 1 of the ICR and each year thereafter.
(e) Assumes that 2 facilities per year would have to submit a Report of exceedence.
(f) Recordkeeping requirements begin in Year 1 of ICR clearance period for all existing plants.
(g) Transmittals would include Annual Compliance Certifications for 10 plants.
(h) The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 4B.

13

TABLE 4. ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT OF THE PROPOSED STANDARDS
(A)
(B)
(C)
EPA personNo. of
EPA personhours per
occurrences
hours per
occurrence
per plant
plant per
per year
year
Activity
(C=AxB)
Report Review
Initial Notification (b)
1.0
1.0
1.0
Notification of Compliance Status (c)
2.0
1.0
2.0
Annual Compliance Certification (d)
2.0
1.0
2.0
Report of Exceedence (e)
2.0
1.0
2.0
TOTAL BURDEN AND COST (SALARY)

(D)
Plants
per
year

(E)
Technical
person-hours
per year
(E=CxD)

3.3
3.3
10.0
2.0

3.3
6.7
20.0
4.0
34.0

(F)
Management
person-hours
per year
(Ex0.05)

(G)
Clerical
personhours per
year
(Ex0.1)
0.2
0.3
1.0
0.2
1.7

0.3
0.7
2.0
0.4
3.4

(H)
Cost,$ (a)

$161
$323
$968
$194
$1,646

(a) Costs are based on the following hourly rates: technical at $43.17, management at $58.18, and clerical at $23.36.
Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
(b) All 10 plants will submit the initial notification, leading to an average annual burden of 3 plants/yr.
(c) All 10 plants will submit the notification of compliance status, leading to an average annual burden of 3 plants/yr.
(d) All 10 plants will submit an annual compliance certification each year.
(e) Assumes that 2 facilities per year would have to submit an exceedance report per year.
N/A = Not applicable.
Total hours

14

39

ATTACHMENT 1. INFORMATION REQUIREMENTS--NESHAP FOR FERROALLOYS PRODUCTION AREA SOURCES
Requirement
Monitoring
Notifications
Notification of applicability
Notification of construction/reconstruction
Notification of special compliance requirements
Notification of performance test
Notification of opacity/VE observations
Additional CMS notifications
Notification of compliance status
Notification of changes in information
Plans
SSM plan
Performance test plan
Bag leak detection system monitoring plan
CMS quality control plan
CMS performance evaluation test plan
Records
Records of notifications
Records that demonstrate continuous compliance
Monitoring information
Reports
Reports of exceedences
Semiannual monitoring reports
Initial/repeat performance tests
Quality assurance test plan
CMS performance evaluation/report
SSM reports
Excess emissions reports
Annual compliance certifications

Citation for existing sources

Citation for new sources

General Provisions citation

N/A

N/A

N/A

§63.11529(a)
N/A
N/A
N/A
N/A
N/A
§63. 11529(b)
N/A

§63.11529(a)
N/A
N/A
N/A
N/A
N/A
§63. 11529(b)
N/A

40 CFR 63.9(b)(2)
40 CFR 63.9(b)(5)
40 CFR 63.9(d)
40 CFR 63.9(e)
40 CFR 63.9(f)
40 CFR 63.9(g)
40 CFR 63.9(h)
40 CFR 63.9(j)

N/A
N/A
§63. 11527(a)(5)
N/A
N/A

N/A
N/A
§63. 11527(a)(5)
N/A
N/A

40 CFR 63.6(e)(3)
N/A
N/A
40 CFR 63.8(d)
40 CFR 63.8(e)(3)

§63. 11529 (d)(1)
§63. 11529 (d)(2)
§63. 11529 (d)(2)

§63. 11529 (d)(1)
§63. 11529 (d)(2)
§63. 11529 (d)(2)

40 CFR 63.10
40 CFR 63.10
40 CFR 63.10

N/A
N/A
N/A
N/A
N/A
N/A
N/A
§63. 11529 (c)

N/A
N/A
N/A
N/A
N/A
N/A
N/A
§63. 11529 (c)

N/A
N/A
N/A
N/A
40 CFR 63.8(e)(5)
40 CFR 63.6(e)(3)
40 CFR 63.10(e)(3)
N/A

15