U.S. Environmental Protection Agency
Information Collection Request
Title: NESHAP for Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (Renewal)
OMB Control Number: 2060-0608.
EPA ICR Number: 2277.07
Abstract: The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) were proposed on September 20, 2007, and promulgated on December 28, 2007. These regulations apply to existing facilities and new Electric Arc Furnace (EAF) steelmaking facilities that are area sources of hazardous air pollutants (HAP) emissions. These standards establish particulate matter (PM) emission limits for control devices and opacity limits for melt shops, pollution prevention requirements for ferrous scrap that is melted in EAFs, and monitoring, reporting, and recordkeeping requirements. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart YYYYY.
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.
Over the next three years, approximately 78.9 existing respondents per year will be subject to these standards, and 0.9 additional respondents per year will become subject to these same standards, for an overall average of 79.8 respondents per year.
The Office of Management and Budget (OMB) approved the currently-active ICR with the following “Terms of Clearance”:
“In accordance with 5 CFR 1320, the information collection is approved for three years. As terms of clearance, upon renewal of this collection, EPA is required to include the following in its supporting statement for this and other NESHAP ICRs: (1) a description of the regulatory text applicable to the ICR including submission specifications; (2) a clear description of the data elements being collected under the ICR; (3) screen shots of the electronic portal where the reporting requirements are submitted to EPA (with the control number and burden statement); (4) a detailed discussion of how information is submitted and the extent to which electronic reporting is available; (5) evidence of consultation with respondents (by actively reaching out to stakeholders as permitted by the PRA) to ensure the supporting statement's accuracy on availability of data, frequency of collection, clarity of instructions, accuracy of burden estimate, relevance of data elements, and similar PRA matters; and (6) discussion of how EPA addressed substantive concerns raised by respondents and other stakeholders during consultation and in response to comments received on FR notices. In addition, please convert the supporting statement to the standard 18 question SS-A format upon renewal.”
The relevant regulatory text is referenced in section 12(b) of this document. We have created a supplementary document including the regulatory text that describes the ICR requirements as identified in section 12(b) of this document as requested. This NESHAP does not require electronic reporting, and the Agency has not developed specific reporting forms for these subparts for use within CEDRI. The list of rules and required reports available in CEDRI are available at https://www.epa.gov/electronic-reporting-air-emissions/cedri. The notifications and reports required of respondents may be submitted to the authority by any appropriate method such as paper letter or electronic data file. A description of the EPA’s consultation with respondents and how EPA responded to any concerns raised by respondents or other stakeholders is discussed in section 8 of this document. Per the Terms of Clearance on the previous ICR, this supporting statement follows the standard 18-question format.
Supporting Statement A
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 EAF steelmaking facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart YYYYY.
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 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 the standards are being met. The performance test may also be observed.
The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures, and for compliance determinations.
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
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.
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.
Information contained in these reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by the EPA's Office of Compliance. 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.
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 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.
A small entity for this industry is defined by the Small Business Administration as a firm having no more than 1,000 employees. The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Although these standards would not have a significant economic impact on the small entities, we tried to reduce the impact of the rule on small facilities. The EPA met with industry trade associations and company representatives to address any small business concerns during development of the final rule. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.
Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.
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 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 five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.
An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (89 FR 63933) on August 6, 2024. No comments were received on the burden published in the Federal Register for this renewal.
8b. 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 six respondents will be subject to the standard over the three-year period covered by this ICR.
Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Steel Manufacturers Association at 202-296-1515, and The Association for Iron & Steel Technology at 724-814-3000. The Steel Manufacturers Association responded and confirmed the number of respondents and respondent growth rate. No other comments were received.
It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.
No payments or gifts are made to respondents.
ASSURANCE OF 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).
The reporting or recordkeeping requirements in the standard do not include sensitive questions.
The respondents to the recordkeeping and reporting requirements EAF steelmaking facilities. The United States Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) codes for the respondents affected by the standards are listed in the table below:
Standard (40 CFR Part 63, Subpart YYYYY) |
SIC Code |
NAICS Code |
Iron and Steel Mills and Ferroalloy Manufacturing |
3312 |
331110 |
Based on our research for this ICR, on average over the next three years, approximately 78.9 existing respondents will be subject to the standard. It is estimated that an additional 0.9 respondents per year will become subject, for an overall average of 79.8 respondents per year. The number of respondents is calculated using the table Number of Respondents that addresses the three years covered by this ICR. None of the facilities in the United States are owned by either state, local, or tribal entities or by the Federal government. They are all 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 an average of one affected facility at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).
The total number of annual responses per year is calculated using the table Total Annual Responses shown below. The number of Total Annual Responses is 243.
In this ICR, all the data that are recorded or reported is required by the NESHAP for Electric Arc Furnace Steelmaking Facilities (40 CFR part 63, Subpart YYYYY) (Renewal). 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.
A source must make the following reports:
Notifications |
|
Scrap management and pollution prevention plan |
§§63.10685(a)(1) and (b)(1) |
Startup, shutdown, and malfunction plan |
§63.6(e)(3) |
Notification of applicability |
§63.9(b)(1) |
Notification and application of construction or reconstruction |
§63.9(b)(4) |
Compliance extension |
§63.9(c) |
Notification of special requirements |
§63.9(d) |
Notification of performance test |
§§63.7(b), 63.9(e) |
Notification of opacity and visible emission observations |
§63.9(f) |
Additional COMS notifications |
§63.9(g) |
Notification of compliance status |
§§63.10690(b), 63.9(h) |
Notification of actual startup |
§63.9(b) |
Reports |
|
Semiannual compliance reports |
§§63.10685(c), 63.10(e) |
Opacity or visible emissions observations results |
§63.10(d)(3) |
Startup, shutdown, malfunction report |
§63.10(d)(5) |
Additional CMS reports |
§63.10(e) |
A source must keep the following records:
Recordkeeping |
|
Notifications and reports |
§§63.10685(c), 63.10(b)(2)(xiv) |
Startups, shutdowns, malfunctions |
§§63.6(e)(3)(iii)-(v), 63.10(b)(2)(i)-(ii) |
Performance tests, performance evaluations, and opacity observations |
§§63.10686(d), 63.10(b)(2)(viii)-(ix) |
Scrap management requirements |
§§63.10685(a)(1), 63.10685(b)(1)-(3) and 63.10685(c) |
Continuous monitoring systems |
§§63.10(c), 63.6(h)(7), 63.8(d)(3) |
Maintenance on air pollution control and monitoring equipment |
§63.10(b)(2)(iii) |
Respondent Activities |
Familiarization with the regulatory requirements. |
Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply pressure. |
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 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. |
12d. Respondent Burden Hours and Labor Costs
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 average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 3,920 hours (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously approved ICR, and any comments received.
This ICR uses the following labor rates:
Managerial $172.41 ($82.10 + 110%)
Technical $141.75 ($67.50 + 110%)
Clerical $71.36 ($33.98 + 110%)
These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
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.
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 continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to this regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.
The total capital/startup costs for this ICR are $10,700. This is the total of column D shown below in the table Capital/Startup vs. Operation and Maintenance (O&M) Costs.
There are no operation and maintenance (O&M) costs for this ICR.
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 $10,700.
14a. Agency Activities
The EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:
• 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.
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 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. EPA uses ICIS 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.
14b. Agency Labor Cost
The ‘burden’ to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors. 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 burden and cost during the three years of the ICR is estimated to be 278 hours at a cost of $15,500. See Table 2: Average Annual EPA Burden and Cost – Average Annual EPA Burden and Cost – NESHAP for Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (Renewal).
This cost is based on the average hourly labor rate as follows:
Managerial $76.91 (GS-13, Step 5, $48.07 + 60%)
Technical $57.07 (GS-12, Step 1, $35.67 + 60%)
Clerical $30.88 (GS-6, Step 3, $19.30+ 60%)
These rates are from the Office of Personnel Management (OPM), 2024 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 at the end of this document in Table 2: Average Annual EPA Burden and Cost – NESHAP for Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (Renewal).
14c. Agency Non-Labor Costs
There are no non-labor costs to the Agency associated with this information collection.
REASONS FOR CHANGE IN BURDEN
There is an adjustment decrease in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. This decrease is not due to any program changes. The decrease is due to a revision to the number of respondents expected per year based on the feedback received during consultations with stakeholders as discussed in section 8(b) above. Despite a decrease in burden there is an increase in costs due to the use of updated labor rates. This ICR uses labor rates from the most recent Bureau of Labor Statistics report (December 2023) to calculate respondent burden costs. Although we applied an adjustment increase to the capital costs to adjust 2021 $ to 2023 $, there is an overall decrease in Capital/O&M costs due to the decrease in the number of new respondents per year as confirmed by consultations with stakeholders and the EPA’s internal industry experts described in section 8(b) above.
Although this rule does not require electronic reporting, respondents could choose to submit notifications or reports electronically. All non-CBI data submitted electronically to the Agency through CEDRI are available to the public for review and printing and are accessible using WebFIRE. Electronically submitted emissions data from performance testing or performance evaluations using the Electronic Reporting Tool or templates attached to CEDRI, as well as data from reports from regulations with electronic templates, are tabulated; data submitted as portable document format (PDF) files attached to CEDRI are neither tabulated nor subject to complex analytical techniques. Electronically submitted emissions data used to develop emissions factors undergo complex analytical techniques and the draft emissions factors are available on the Clearinghouse for Inventories and Emission Factors listserv at https://www.epa.gov/chief/chief-listserv for public review and printing. Electronically submitted emissions data, as well as other data, obtained from one-time or sporadic information collection requests often undergo complex analytical techniques; results of those activities are included in individual rulemaking dockets and are available at https://www.regulations.gov/ for public review and printing.
DISPLAY OF EXPIRATION DATE
Although this rule does not require electronic reporting, respondents could choose to submit notifications or reports electronically. All non-CBI data submitted electronically to the Agency through CEDRI are available to the public for review and printing and are accessible using WebFIRE. Electronically submitted emissions data from performance testing or performance evaluations using the Electronic Reporting Tool or templates attached to CEDRI, as well as data from reports from regulations with electronic templates, are tabulated; data submitted as portable document format (PDF) files attached to CEDRI are neither tabulated nor subject to complex analytical techniques. Electronically submitted emissions data used to develop emissions factors undergo complex analytical techniques and the draft emissions factors are available on the Clearinghouse for Inventories and Emission Factors listserv at https://www.epa.gov/chief/chief-listserv for public review and printing. Electronically submitted emissions data, as well as other data, obtained from one-time or sporadic information collection requests often undergo complex analytical techniques; results of those activities are included in individual rulemaking dockets and are available at https://www.regulations.gov/ for public review and printing.
There are no exceptions to the topics of the certification statement.
Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (Renewal)
Burden item |
(A) |
(B) |
(C) |
(D) Respondents per yeara |
(E) |
(F) |
(G) |
(H) |
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. Familiarization with Regulatory Requirements |
8 |
1 |
8 |
79.8 |
638.4 |
31.92 |
63.84 |
$100,552.15 |
B. Required activities |
|
|
|
|
|
|
|
|
Initial performance tests c |
|
|
|
|
|
|
|
|
Prepare scrap plan and scrap specificationsd |
4 |
1 |
4 |
0.9 |
3.6 |
0.18 |
0.36 |
$567.02 |
C. Create information |
See 4B |
|
|
|
|
|
|
|
D. Gather existing information |
See 4B |
|
|
|
|
|
|
|
E. Write report |
See 4B |
|
|
|
|
|
|
|
Initial notification of applicabilityd |
2 |
1 |
2 |
0.9 |
1.8 |
0.09 |
0.18 |
$283.51 |
Notification of compliance statusd |
2 |
1 |
2 |
0.9 |
1.8 |
0.09 |
0.18 |
$283.51 |
Request for compliance extension |
N/A |
|
|
|
|
|
|
|
Notification of performance test c |
2 |
1 |
2 |
0.9 |
1.8 |
0.09 |
0.18 |
$283.51 |
Startup, shutdown, and malfunction plan/reportse |
4 |
1 |
4 |
79.8 |
319.2 |
15.96 |
31.92 |
$50,276.07 |
Semiannual excess emissions reportse |
2 |
2 |
4 |
79.8 |
319.2 |
15.96 |
31.92 |
$50,276.07 |
Subtotal for Reporting Requirements |
|
|
|
|
1,479 |
$202,522 |
||
5. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
A. Familiarization with Regulatory Requirements |
See 4A |
|
|
|
|
|
|
|
B. Plan activities |
See 4B |
|
|
|
|
|
|
|
C. Implement activities |
See 4B |
|
|
|
|
|
|
|
D. Develop record system d |
4 |
1 |
4 |
0.9 |
3.6 |
0.18 |
0.36 |
$567.02 |
E. Time to enter information f |
0.5 |
52 |
26 |
79.8 |
2,075 |
103.74 |
207.48 |
$326,794.49 |
F. Time to transmit or disclose informationf |
0.25 |
2 |
0.5 |
79.8 |
39.9 |
2.00 |
3.99 |
$6,284.51 |
G. Time to adjust existing waysd |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
F. Time to train personneld |
4 |
1 |
4 |
0.9 |
3.6 |
0.18 |
0.36 |
$567.02 |
G. Time for audits |
N/A |
|
|
|
|
|
|
|
Subtotal for Recordkeeping Requirements |
|
|
|
|
2,440 |
$334,213 |
||
TOTAL LABOR BURDEN AND COST (rounded)g |
|
|
|
|
3,920 |
$537,000 |
||
TOTAL CAPITAL AND O&M COST (rounded)g |
|
|
|
|
|
|
|
$10,700 |
GRAND TOTAL (rounded)g |
|
|
|
|
|
|
|
$548,000 |
|
|
|
|
|
|
|
|
|
Assumptions: |
|
|
|
|
|
|
|
|
a There are 78 existing EAF steelmaking facilities and we expect that there will be an average of 0.9 new facilities per year, for an annual average of 79.8 respondents per year. We assume that each respondent will have to familiarize with the regulatory requirements each year. |
||||||||
b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. |
||||||||
c All existing plants have conducted performance tests during the implementation period of the rule. We assume new sources will use contractors to conduct initial tests and have accounted for that cost in the Capital/O&M calculations in this ICR. |
||||||||
d After full implementation, existing facilities are not expected to experience any burden from these activities and 0.9 new facilities per year are expected to become subject to the rule over the 3-year period. |
||||||||
e Sources are required include in their semiannual reports the number of mercury switches removed or the weight of mercury recovered from the switches and properly managed, the estimated number of vehicles processed, an estimate of the percent of mercury switches recovered, and a certification that the recovered mercury switches were recycled at RCRA-permitted facilities, if they are subject to a site-specific plan for mercury. In addition all sources must submit semiannual reports for the control of contaminants from scrap according to the requirements in §63.10(e). For start-up, shutdown, and malfunction, these semi-annual reports are only required if a startup or shutdown caused the source to exceed any applicable emission limitation in the relevant emission standards, or if a malfunction occurred during the reporting period. This ICR assumes each source had one six-month period during each year that required a report. |
||||||||
f Assumed that each facility will update records weekly. The only transmission is the semi-annual report and the annual SSM report. |
||||||||
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|||||
Table 2: Average Annual EPA Burden and Cost – NESHAP for Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (Renewal)
Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
Report Review |
||||||||
Initial notification of applicability c |
1 |
1 |
1 |
0.9 |
0.9 |
0.045 |
0.09 |
$57.60 |
Startup, shutdown, malfunction plan/reportd |
2 |
1 |
2 |
79.8 |
159.6 |
7.98 |
15.96 |
$10,214.96 |
Notification of compliance statusc |
1 |
1 |
1 |
0.9 |
0.9 |
0.045 |
0.09 |
$57.60 |
Notification of performance test c |
1 |
1 |
1 |
0.9 |
0.9 |
0.045 |
0.09 |
$57.60 |
Semiannual excess emissions report |
0.5 |
2 |
1 |
79.8 |
79.8 |
3.99 |
7.98 |
$5,107.48 |
TOTAL ANNUAL BURDEN AND COST (rounded)e |
|
|
|
|
278 |
$15,500 |
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|
|
|
|
|
|
|
|
|
a There are 78 existing EAF steelmaking facilities and we expect that there will be an average of 0.9 new facilities per year, for an annual average of 79.8 respondents per year. |
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b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 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. |
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c After full implementation, the agency is not expected to experience any burden from these activities because existing facilities are no longer expected to submit Initial notifications of applicability or Notifications of compliance status. 0.9 new facilities per year are expected to become subject to the rule over the 3-year period. |
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d This ICR assumes each source had one six-month period during each year that required a report. |
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|
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e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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|
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Number of Respondents |
|||||
|
Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports |
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
Year |
Number of New Respondents 1 |
Number of Existing Respondents |
Number of Existing Respondents that keep records but do not submit reports |
Number of Existing Respondents That Are Also New Respondents |
Number of Respondents |
1 |
0.9 |
78 |
0 |
0 |
78.9 |
2 |
0.9 |
78.9 |
0 |
0 |
79.8 |
3 |
0.9 |
79.8 |
0 |
0 |
80.7 |
Average |
0.9 |
78.9 |
0 |
0 |
79.8 |
1 This ICR assumes there are 78 existing respondents, and approximately 2.7 new respondents over the next three years (or approximately 0.9 new respondents per year.) |
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Total Annual Responses |
||||
(A) |
(B) |
(C) |
(D) |
(E) |
Information Collection Activity |
Number of Respondents |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
Total Annual Responses |
Prepare scrap plan and scrap specifications |
0.9 |
1 |
N/A |
0.9 |
Initial performance tests |
0.9 |
1 |
N/A |
0.9 |
Notification of compliance status |
0.9 |
1 |
N/A |
0.9 |
Request for compliance extension |
0 |
1 |
N/A |
0 |
Notification of performance test |
0.9 |
1 |
N/A |
0.9 |
SSM report |
79.8 |
1 |
N/A |
79.8 |
Semiannual excess emissions reports |
79.8 |
2 |
N/A |
159.6 |
TOTAL (rounded) |
|
|
|
243 |
Capital/Startup vs. Operation and Maintenance (O&M) Costs |
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(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
Performance Testing1 |
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) |
Method 5 Testing |
$9,185 |
0.9 |
$8,266 |
$0 |
0 |
$0 |
Method 9 Testing |
$1,702 |
0.9 |
$2,416 |
$0 |
0 |
$0 |
Total |
|
|
$10,700 |
|
|
$0 |
1 We assume all new respondents will be required to conduct initial Method 5 and Method 9 testing. Both Method 5 and Method 9 testing are usually conducted by a contractor. We have increased costs from 2021 $ to 2023 $ using the CEPCI CE Index. |
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Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |