1831ss08

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal), EPA ICR Number 1831.07, OMB Control Number 2060-0391.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) were proposed on proposed on August 4, 1998; promulgated on May 20, 1999; and amended on: March 22, 2001; June 23, 2003; April 20, 2006; June 30, 2015 (80 FR 37366); January 18, 2017 (82 FR 5408); and most-recently on November 19, 2020 (85 FR 73902). These regulations apply to both new and existing ferroalloy production facilities that manufacture ferromanganese and silicomanganese, and that are either major sources of hazardous air pollutant (HAP) emissions or are co-located at major sources of HAPs. The following affected facilities at ferroalloy production plants are subject to this NESHAP rule: electric arc furnaces; casting operations; metal oxygen refining (MOR) processes; crushing and screening operations; and outdoor fugitive dust sources. New facilities include those that commenced construction or reconstruction after the date of proposal. The ‘burden’ in this ICR reflects the burden associated with the recordkeeping and reporting requirements of this regulation for new and existing sources included in both the June 30, 2015 Risk and Technology Review (RTR) final rule amendments and January 18, 2017 reconsideration notice. The burden associated with the 2015 final rule amendments and reconsideration notice is accounted for in EPA ICR No. 2448.02 (OMB Control No. 2060-0676). The 2020 amendment implemented the plain language reading of the “major source” and “area source” definitions of section 112 of the Clean Air Act (CAA) and provide that a major source can be reclassified to area source status at any time upon reducing its potential to emit (PTE) hazardous air pollutants (HAP) to below the major source thresholds and required this notification be submitted electronically. This information is being collected to assure compliance with 40 CFR Part 63, Subpart XXX.

In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these measurements and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where the delegated state or local authority can review them. In the event that there is no such delegated authority, the EPA regional office can review them. All other reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the EPA regional offices. The use of the term "Designated Administrator" throughout this document refers to the U.S. EPA or a delegated authority such as a state agency. The term "Administrator" alone refers to the U.S. EPA Administrator. 

The "Affected Public" are owners and operators of either new or existing ferroalloy production facilities that manufacture ferromanganese and silicomanganese. The ‘burden’ to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal). The ‘burden’ to the Federal Government is attributed entirely to work performed by either Federal government employees or government contractors. This burden may be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal). There are two ferroalloy production facilities which are owned and operated by the ferroalloy production industry. None of these two facilities in the United States are owned by either state, local, tribal entities or the Federal government. They both are owned and operated by privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries.

Based on our consultations with industry representatives, there is one affected facility at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately two respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards.

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

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:

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

In the Administrator's judgment, HAP emissions from ferroalloy production facilities either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart XXX.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these 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 these emission standards. Continuous emission monitors are used to ensure compliance with these 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 these standards are used to inform either the Agency or its delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, leaks are being detected and repaired, and that these standards are being met. The performance test may also be observed.

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

Additionally, the EPA is requiring electronic reporting for certain notifications or reports. The EPA is requiring that owners or operators of affected sources would submit electronic copies of initial notifications required in 40 CFR 63.9(b), notifications of changes in information already provided in 40 CFR 63.9(j), performance test reports, and results of the performance evaluations through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI). For the notifications required in 40 CFR 63.9(b) and 63.9(j), owners and operators would be required to upload a PDF of the required notifications.

CEDRI includes the Electronic Reporting Tool (ERT) software, which is used by facilities to generate electronic reports of performance tests and results of the performance evaluations. The EPA is also requiring that 40 CFR Part 63, Subpart XXX performance test reports and performance evaluations be submitted through the EPA’s ERT.

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

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart XXX.

3(a) Non-duplication

For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as for state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication. 

For all other reports, 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 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, duplication does not exist. 

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 (86 FR 19256) on April 13, 2021. No comments were received on the burden published in the Federal Register for this renewal.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately two respondents will be subject to these standards over the three-year period covered by this ICR.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and theses same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted Felman Productions, at (304) 882-1181, and Eramet Marietta, Inc., at (740) 374-1000.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as for 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 these 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

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 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 these 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. The EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to either 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 (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

The reporting or recordkeeping requirements in these standards do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators of all new and existing ferroalloys production facilities that are major sources or are co-located at major sources. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards is SIC 3313 (Electrometallurgical Products, except Steel) which corresponds to the North American Industry Classification System (NAICS) 331110 for Iron and Steel Mills and Ferroalloy Manufacturing (which includes Ferromanganese Manufacturing, Ferrosilicon Manufacturing, and Silicomanganese Ferroalloys Manufacturing).

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported is required by the NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63 Subpart XXX) (Renewal).

A source must make the following reports:

Notifications
Notification of applicability if an area source becomes subject to the rule	§63.9(b)(1), §63.1627(a)
Notification of construction/reconstruction	§63.9(b)(4)-(5), §63.1627(a)
Notification of performance test	§63.9(e), §63.1627(a)
Notification of opacity and visible emission observations	§63.9(f), §63.1627(a)
Notification of compliance status	§63.9(h), §63.1627(a)
Notification of reclassification to area source status or to revert to major source status (electronic submission)	§63.9(b)
Notification of change in information already provided (electronic submission)	§63.9(j)

Reports
Results of performance tests (electronic submission)	§63.10(d)(2), §63.1628(c), §63.1628(e)(1)(i)(A)
Results of opacity or visible emission observations	§63.10(d)(3), §63.1628(c)
Deviations from process fugitive emissions ventilation plan	§63.1628(d)(1)
Deviations from outdoor fugitive dust control plan	§63.1628(d)(1)
Deviations from standard operating procedures manual for baghouses	§63.1628(d)(1)
Deviations from established parameters for pressure drop and flow rate in scrubbers controlling PM	§63.1628(d)(2)
Alarms and actions taken in response to bag leak detection system	§63.1628(d)(3)
Shop building capture system monitoring and deviations	§63.1628(d)(4)
Results of quarterly inspections of the furnace capture system	§63.1628(d)(5)
Malfunctions and exceedances	§63.1628(d)(7)
Annual compliance certification	§63.1628(e)

A source must keep the following records:

Recordkeeping
Maintain records of all information for five years	§63.10(b)(1), §63.1628(a)
Maintain records of all required maintenance performed on the air pollution control and monitoring equipment	§63.10(b)(2)(iii), §63.1628(a)
Bag leak detection system: output, alarms, corrective actions	§§63.1628(b)(1)-(2)
Baghouses without leak detection systems: inspection and maintenance records	§63.1628(b)(3)
Wet scrubbers: pressure drop, water flow rate, deviations, corrective actions	§63.1628(b)(4), §63.1628(b)(7)
Shop building capture system: monitoring, deviations, corrective actions	§63.1628(b)(5)
Inspections of the furnace capture system (quarterly)	§63.1628(b)(6)
Records of startup and/or shutdown.	§63.1628(b)(9)
Records of malfunctions and exceedances	§63.1628(b)(10)
Deviations from process fugitive emissions ventilation plan	§63.1628(b)(11)
Deviations from outdoor fugitive dust control plan	§63.1628(b)(11)
Deviations from monitoring SOP manual for baghouses	§63.1628(b)(11)
Records of performance tests	§63.1628(a), §§63.10(b)(2)(viii), (ix)
Records of opacity and visible emission observations	§63.1628(b)(2)(viii)

Electronic Reporting

Some of the respondents are using 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.

The rule was recently amended to include electronic reporting provisions on June 30, 2015. Respondents are required to use the EPA’s Electronic Reporting Tool (ERT) to develop performance test reports and submit them through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be accessed through the EPA’s Central Data Exchange (CDX) (https://cdx.epa.gov/). The ERT is an application, rather than a form, and the requirement to use the ERT is applicable to numerous subparts. The splash screen of the ERT contains a link to the Paperwork Reduction Act (PRA) requirements, such as the OMB Control Number, expiration date, and burden estimate for this and other subparts.

The rule was also recently amended to include electronic reporting provisions on November 19, 2020. Respondents are also required to submit electronic copies of certain notifications through EPA’s CEDRI. The notification is an upload of their currently required notification in portable document format (PDF) file. For purposes of this ICR, it is assumed that there will be no additional burden associated with the proposed requirement for respondents to submit the notifications and reports electronically.

Electronic copies of records may also be maintained in order to satisfy federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Monitor shop opacity.

Monitor baghouse operations on a regular basis (e.g., observe on a daily basis for the presence of visible emissions at baghouses and bag leak detection system). Conduct periodic visual inspections to ensure systems are working properly.

Monitor pressure drop and liquid supply pressure across the venturi scrubber.

Perform initial performance test and repeat performance test, if necessary. Reference Method 9 for opacity observations and Method 5 for determination of particulate matter concentrations and volumetric flow rates for baghouses without stacks.

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 collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for disclosing and providing information.

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

The EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:

Agency Activities

Observe 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 Enforcement and Compliance History Online (ECHO) and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard 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. The quarterly and 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 reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. The EPA and its delegated authorities can edit, store, retrieve and analyze the data.

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

5(c) Small Entity Flexibility

The NESHAP for ferroalloys production facilities only applies to major sources. There are no small entities (i.e., small businesses) affected by this regulation. In addition, during the rule development process, the EPA closely reviewed existing permit conditions at existing facilities, and, where feasible, incorporated similar, if not identical, requirements in the final rule. The Agency considers these to be the minimum requirements needed to ensure compliance with these standards and, therefore, cannot reduce them further for small entities.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (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. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may neither conduct nor 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 1,610 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of these regulations, Agency knowledge and experience with the NESHAP program, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $153.55 ($73.12 + 110%)

Technical $122.20 ($58.19 + 110%)

Clerical $61.51 ($29.29 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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 standard(s) are both labor costs, which are addressed elsewhere in this ICR, and the costs associated with annual performance testing and continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to these regulations. The annual operation and maintenance costs are the ongoing costs to maintain the control devices, monitors, and such other costs as photocopying and postage.

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

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Performance Testing/Continuous Monitoring Device	Capital/ Startup Cost for One Respondent	Number of New Respondents	Total Capital/ Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M (E X F)
Initial Compliance test (PM, HCl, Hg, PAH, Formaldehyde) - Furnace PP FF	$200,000	0	$0
Initial Compliance test (PM, HCl, Hg, PAH, Formaldehyde) - Furnace NP FF/Scrubber	$52,000	0	$0
Initial Compliance test (PM) Building Ventilation/#12 casting/misc. sources NP/FF	$5,000	0	$0
Pressure Drop/Liquid Flow Rate CPMS - Scrubber a	$50,000	0	$0	$18,000	1	$18,000
Bag Leak Detection System b	$269,148	0	$0	$109,539	2	$219,078
Ductwork Flow Rate Monitoring c	$41,400	0	$0	$2,070	2	$4,140
Annual furnace control device tests: PM, Hg, PAH d				$5,000	5	$25,000
Five-year furnace control device tests: HCl, formaldehyde, capture system e				$126,000	1.2	$151,200
Five-year local ventilation test f				$5,000	0.6	$3,000
Five-year crushing and screening equipment test g				$5,000	0.6	$3,000
Five-year metal oxygen refining (MOR) process test h				$5,000	0.2	$1,000
Totals (rounded) i			$0			$424,000
a One respondent uses a single venturi scrubber to control emissions from two furnaces.
b Four furnaces are each controlled with fabric filters and are equipped with bag leak detection systems (BLDS).
c There are five furnace capture systems that require quarterly examinations of the ductwork to insure proper operation.
d The control devices on furnaces are tested annually. A wet scrubber is tested for PM, Hg, and PAH, while fabric filters are tested for Hg and PAH. We assume that respondents operating ferromanganese furnaces have applied for and received permission to test for PAH on a yearly basis.
e The control devices on furnaces are required to be tested for HCl, formaldehyde, and their capture system every five years. This is a repeat of the initial performance testing that cost a total of $756,000 for 6 furnace tests, or an average of $126,000 per test. (See Table 2 of ICR 2448.02.) The cost shown is the five-year average. (6 furnaces/5 years = 1.2 per year)
f The shop building ventilation systems controlled by baghouses require testing every five years. There are a total of three shop buildings that require testing. Testing costs are taken from Table 2 Year 2 of ICR 2448.02 for initial testing for 'Initial Compliance test (PM) – Bldg. Vent./#12 casting/misc. sources NP FF'. The cost shown is the five-year average. (3 systems/5 years = 0.6/year)
g The crushing/screening operations controlled by baghouses require testing every five years. There are a total of three crushing/screening operations that require testing. Testing costs are taken from Table 2 Year 2 of ICR 2448.02 for initial testing for 'Initial Compliance test (PM) – Bldg. Vent./#12 casting/misc. sources NP FF'. The cost shown is the five-year average. (3 operations/5 years = 0.6/year)
h Only one respondent has a metal oxygen refining (MOR) process. This will be tested every five years. Testing costs are taken from Table 2 Year 2 of ICR 2448.02 for initial testing for 'Initial Compliance test (PM) – Bldg. Vent./#12 casting/misc. sources NP FF'. The cost shown is the five-year average. (1 MOR process/5 years = 0.2/year)
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

There are no capital/startup costs for this ICR. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this ICR are $424,000. This is the total of column G. 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 $424,000. These are the recordkeeping costs.

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's overall compliance and enforcement program includes such activities 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 $3,600.

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

Managerial $69.04 (GS-13, Step 5, $43.15 + 60%)

Technical $51.23 (GS-12, Step 1, $32.02 + 60%)

Clerical $27.73 (GS-6, Step 3, $17.33 + 60%)

These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal).

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 two existing respondents will be subject to these standards. It is estimated that no additional respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is two per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR:

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents a	(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	2	0	0	2
2	0	2	0	0	2
3	0	2	0	0	2
Average	0	2	0	0	2

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

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 2.

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
Initial Notifications	0	0	0	0
Notification of construction/reconstruction	0	0	0	0
Notification of compliance status	0	1	0	0
Notification of performance test	2	1	0	2
Notification of opacity observations	2	1	0	2
Notification of change in information already provided	2	0.33	0	0.66
Report of performance tests, opacity observations	2	1	0	2
Reports of the results of quarterly inspections of the furnace capture system	2	4	0	8
Reports of deviations, alarms, actions taken, malfunctions, and exceedances	2	1	0	2
Annual compliance certification	2	1	0	2
Total (rounded)				19

The number of Total Annual Responses is 19.

The total annual labor costs are $185,000. Details regarding these estimates may be found at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal).

6(e) Bottom Line 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 at the end of this document, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 1,610 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 84 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $424,000. 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 72 labor hours at a cost of $3,600; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is a change in burden from the most-recently approved ICR (ICR Number 1831.07) as currently identified in the OMB Inventory of Approved Burdens. This is due to several considerations. The regulations are not anticipated to change over the next three years. The growth rate for this industry is very low or non-existent, so there is no change in the number of respondents. The 2015 Risk and Technology Review final rule, issued June 30, 2015 (80 FR 37366), and the 2017 reconsideration, issued January 18, 2017 (82 FR 5408), revised the rule significantly, resulting in changes in the labor burden, capital/startup costs, and operation and maintenance (O&M) costs. However, these changes were not included in the previously- approved ICR (ICR Number 1831.07: issued March 8, 2019). Instead, the burden for the rule revision was included in ICR Number 2448.02 (issued March 16, 2015), which showed only the increase in burden due to the rule changes. This ICR (1831.08) combines and incorporates the ‘burden’ from the 2015 and 2017 rule revisions, as shown in ICR Number 2448.02, with the ‘burden’ shown in the previously-approved ICR (ICR Number 1831.07). This current ICR also reorganizes and clarifies the ‘burden’ associated with each rule requirement.

There is a decrease in the total estimated burden for capital/startup costs from that shown in ICR Number 2448.02. This decrease is not due to any program changes. The change in the burden and cost estimates occurred because the revised standard has been in effect for more than three years and the requirements are different during the initial compliance. ICR Number 2448.02 reflected those burdens and costs associated with the initial activities for the two subject facilities. This includes purchasing monitoring equipment, conducting performance test(s), and establishing recordkeeping systems. This ICR reflects the on-going burden and other costs for existing facilities.

There is an increase in the total estimated burden from that shown in ICR Number 2448.02. This increase is not due to any program changes. This increase is due to an omission in the burden calculations for O&M costs in ICR Number 2448.02, which failed to include costs for periodic testing (every five years) for certain equipment and processes.

The 2020 amendment to these regulations (85 FR 73902) added electronic notification requirements, but this did not add to the overall burden. There is a slight increase in labor costs, which is due wholly to the use of updated labor rates. This ICR uses labor rates from the most- recent Bureau of Labor Statistics report (March 2021) to calculate respondent burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 84 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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 neither conduct nor 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 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-OAR-2021-0093. 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), WJC 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. Due to COVID-19 precautions, entry to the Reading Room is available by appointment only. Please contact personnel in the Reading Room to schedule an appointment. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center 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, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2021-0093 and OMB Control Number 2060-0391 in any correspondence.

Part B of the Supporting Statement

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

Table 1: Annual Respondent Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal)

Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
1. Reporting Requirements
A. Familiarize with Regulatory Requirements	4	1	4	2	8	0.4	0.8	$1,088.23
B. Required activities
a. Initial performance test (PM, HCl, Hg, PAH, Formaldehyde) - Furnace, capture systems - Fabric Filter	15	3	60	0	0	0	0	$0
b. Initial performance test (PM, HCl, Hg, PAH, Formaldehyde) - Furnace, capture systems - Scrubber	15	2	30	0	0	0	0	$0
c. Initial performance test (PM) - Local ventilation, Metal Oxygen Refining (MOR) process, crushing and screening	20	4	70	0	0	0	0	$0
d. Periodic performance tests for submerged arc furnace control devices
i. Annual wet scrubber PM tests (furnace)	15	2.5	37.5	2	75	3.8	7.5	$10,202.14
ii. Annual Hg tests for wet scrubber, fabric filter, and vent stacks (furnace)
iii. Annual PAH tests for wet scrubber, fabric filter, and vent stacks (ferromanganese furnaces)
iv. PM tests for fabric filters every five years (furnace)	15	0.5	7.5	2	15.0	0.75	1.50	$2,040.43
v. HCl test every five years (furnace)
vi. Formaldehyde test every five years (furnace)
vii. Capture system test every five years (furnace)
viii. Local ventilation test every five years	20	0.5	10	2	20	1.0	2.0	$2,720.57
ix. MOR process test every five years
x. Crushing and screening equipment test every five years
e. Non-furnace baghouse observations and inspections
i. Daily visible emissions observations	0.5	350	175	2	350	18	35	$47,609.98
ii. Weekly confirmation of dust removal	0.1	50	5	2	10	0.5	1.0	$1,360.29
iii. Monthly check of bag cleaning mechanisms	0.1	12	1.2	2	2	0.1	0.2	$326.47
iv. Quarterly baghouse integrity checks	0.1	4	0.4	2	1	0.0	0.1	$108.82
v. Semiannual baghouse inspections	0.1	2	0.2	2	0	0.0	0.0	$54.41
f. Furnace baghouse bag leak detection system (annual O&M)	4	2	8	2	16	0.8	1.6	$2,176.46
g. Pressure drop/liquid flow rate CPMS-scrubber (annual O&M)	2	1	2	1	2	0.1	0.2	$272.06
h. Weekly Method 9 (Opacity)	2	156	312	2	624	31	62	$84,881.78
i. Ductwork flowrate monitoring (annual O&M)	2	1	2	2	4	0.2	0.4	$544.11
j. Furnace capture system inspection (Quarterly)	2	4	8	2	16	1	2	$2,176.46
C. Create information	See 1B
D. Gather information	See 1B
E. Report preparation
a. Initial Notifications	N/A
b. Notification of construction/reconstruction	N/A
c. Notification of compliance status	4	1	4	0	0	0	0	$0
d. Notification of performance test	2	1	2	2	4	0.2	0.4	$544.11
e. Notification of opacity observations	2	1	2	2	4	0.2	0.4	$544.11
f. Notification of change in information already provided	2	0.33	0.66	2	1	0.1	0.1	$179.56
g. Report of performance tests, opacity observations	5	1	5	2	10	0.5	1.0	$1,360.29
h. Process fugitive emissions ventilation plan
i. Develop and submit plan	80	1	80	0	0	0	0	$0
ii. Report deviations from plan	See 1.E.o
iii. Update plan	See 1.E.o
i. Outdoor fugitive dust control plan
i. Develop and submit plan	10	1	10	0	0	0	0	$0
ii. Report deviations from plan	See 1.E.o
j. Bag leak detection system
i. Develop plan	20	1	20	0	0	0	0	$0
ii. Report alarms and actions taken in response	See 1.E.o
k. Monitoring SOP manual for baghouses controlling process vents, process fugitive, or outdoor fugitive dust
i. Develop and submit manual	10	1	10	0	0	0	0	$0
ii. Report deviations from plan	See 1.E.o
l. Report deviations from established parameters for pressure drop and flow rate in scrubbers controlling PM	See 1.E.o
m. Report shop building capture system monitoring and deviations	See 1.E.o
n. Reports of the results of quarterly inspections of the furnace capture system	4	4	16	2	32	1.6	3.2	$4,352.91
o. Reports of deviations, alarms, actions taken, malfunctions, and exceedances	10	1	10	2	20	1.0	2.0	$2,720.57
p. Annual compliance certification	10	1	10	2	20	1.0	2.0	$2,720.57
Subtotal for Reporting Requirements					1,420			$167,984
2. Recordkeeping Requirements
A. Familiarize with Regulatory Requirements	See 1A
B. Implement activities	See 1B
C. Develop record system	NA
E. Records of information required by standards
a. Bag leak detection system: output, alarms, corrective actions	1	1	1	2	2	0.1	0	$272.06
b. Baghouses without leak detection systems: inspection and maintenance records	2	20	40	2	80	4	8	$10,882.28
c. Wet scrubbers: pressure drop, water flow rate, deviations, corrective actions	2	1	2	1	2	0.10	0.2	$272.06
d. Shop building capture system: monitoring, deviations, corrective actions	2	1	2	2	4	0.20	0.4	$544.11
e. Inspections of the furnace capture system (quarterly)	2	4	8	2	16.0	0.80	1.60	$2,176.46
f. Records of startup and/or shutdown.	1	1	1	2	2.0	0.10	0.20	$272.06
g. Records of malfunctions and exceedances	2	1	2	2	4.0	0.20	0.40	$544.11
h. Deviations from process fugitive emissions ventilation plan	1	1	1	2	2	0.10	0.2	$272.06
i. Deviations from outdoor fugitive dust control plan	1	1	1	2	2	0.1	0.2	$272.06
j. Deviations from monitoring SOP manual for baghouses	1	1	1	2	2	0.1	0.2	$272.06
k. Records of performance tests	2	2.5	5	2	10	1	1	$1,360.29
F. Personnel training	20	1	20	2	40	2.0	4.0	$5,441.14
G. Time for audits	NA
Subtotal for Recordkeeping Requirements					191			$17,140
Total Labor Burden and Cost (rounded) t					1,610			$185,000
Total Capital and O&M Costs (rounded) t								$424,000
GRAND TOTAL (rounded) t								$609,000
Assumptions:
a There are two ferroalloy production facilities currently subject to the standard. We assume no additional respondents will become subject to this regulation in the three-year period of this ICR.
b This ICR uses the following labor rates: $153.55 per hour for Managerial labor; $122.20 per hour for Technical labor, and $61.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.
c There are a total of six operating furnaces at these two sources. Four furnaces are controlled with fabric filters and two furnaces are controlled with a single venturi scrubber. The fabric filter baghouses controlling the arc furnaces are required to have bag leak detection systems.
d There are a total of seven local ventilation, MOR process, and crushing/screening operations controlled by baghouses at these two sources.
e There are six operating furnaces at these two sources controlled by five control devices (four fabric filters and one scrubber (5/2=2.5)). Each furnace is tested annually.
f We assume that all six ferromanganese furnaces have demonstrated compliance with the PAH standard in four consecutive tests and have petitioned the operating authority to reduce testing frequency to an annual basis.
g This testing is done every five years. We assume these tests will be done simultaneously with the annual test. This row calculates the average cost per year over five years. At these two sources, there are a total of three shop buildings (local ventilation), one MOR process, and three crushing/screening operations, each controlled by baghouses.
h Each source has non-furnace operations (crushing and screening, MOR process, building ventilation) that are controlled by baghouses. These observations, inspections, and maintenance get performed on the schedule shown.
i At the two sources, there are a total of four arc furnaces each controlled by a single baghouse. These baghouses use bag leak detection systems.
j One source operates a scrubber controlling two arc furnaces.
k We assume each respondent will perform weekly opacity readings on three non-furnace facilities. (3 x 52 = 156)
l The ductwork flowrate monitoring is for determining compliance with the shop building opacity standard at 40 CFR 63.1623 and 63.1626(h).
m The capture systems collecting emissions from the six arc furnaces are inspected for proper functioning annually.
n We assume sources will make changes to information previously reported once every three years.
o These plans and manuals were developed and submitted during the first year after the most recent amendments were promulgated.
p We assume that both respondents will report deviations from these plans and parameters each year during the three-year period of this ICR.
q Respondents are required to update the process fugitive emissions ventilation plan every 5 years.
r We assume that 2 respondents per year will need to submit a Report of Exceedance.
s Each respondent is required to submit an Annual Compliance Certification each year.
t Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal)

Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
Report reviews
Notification of performance test	1	1	1	2	2	0.1	0.2	$114.91
Notification of opacity observations	1	1	1	2	2	0.1	0.2	$114.91
Notification of change in information already provided	1	0.33	0.3	2	1	0.03	0.1	$37.92
Report of performance tests, opacity observations	5	1	5	2	10	0.5	1	$574.55
Reports of the results of quarterly inspections of the furnace capture system	2	4	8	2	16	0.8	1.6	$919.28
Reports of deviations, alarms, actions taken, malfunctions, and exceedances	14	1	14	2	28	1.4	2.8	$1,608.72
Annual compliance certification	2	1	2	2	4	0.2	0.4	$229.82
TOTALS (rounded) c					72			$3,600
Assumptions:
a There are two ferroalloy production facilities currently subject to the standard. We assume no additional respondents will become subject to this regulation in the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.03 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.