SUPPORTING
STATEMENT
NATIONAL
EMISSION
STANDARDS
FOR
COKE
OVEN
BATTERIES:
FINAL
AMENDMENTS
PART
A
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
National
Emission
Standards
for
Coke
Oven
Batteries
(
Final
Rule)."
This
is
a
revision
to
the
existing
approved
information
collection
request
(
ICR).
The
Office
of
Management
and
Budget
(
OMB)
has
previously
approved
the
information
collection
requirements
in
the
existing
rule
(
40
CFR
part
63,
subpart
L)
under
the
provisions
of
the
Paperwork
Reduction
Act,
44
U.
S.
C.
3501
et
seq.
and
has
assigned
OMB
control
number
2060­
0253.
The
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
request
is
ICR
number
1362.07.

(
b)
Short
Characterization.

Potential
respondents
are
owners
or
operators
of
coke
oven
batteries
subject
to
the
maximum
achievable
control
technology
(
MACT)
standards
for
charging,
doors,
and
topside
leaks
in
the
existing
rule
(
MACT
track
batteries).
The
final
amendments
will
establish
more
stringent
visible
emission
limitations
for
doors
and
topside
leaks
on
existing
by­
product
coke
oven
batteries
to
address
health
risk
remaining
after
implementation
of
the
1993
rule.
Based
on
our
8­

year
review
requirements
under
section
112(
d)(
6)
of
the
CAA,
we
are
also
promulgating
emission
limits
and
work
practice
requirements
for
the
improved
control
of
charging
emissions
from
new
or
reconstructed
non­
recovery
batteries.
These
requirements
will
include
an
opacity
limit
for
charging
operations,
emission
and
opacity
limits
for
the
charging
emission
control
device,
and
work
practice
standards.
Other
final
amendments
will
establish
work
practice
requirements
2
designed
for
improved
door
leak
control;
these
requirements
will
apply
to
all
non­
recovery
batteries
on
the
MACT
track.

No
new
or
revised
information
collection
requirements
are
included
for
existing
byproduct
coke
oven
batteries
because
the
existing
rule
already
includes
appropriate
monitoring,

recordkeeping,
and
reporting
provisions.
Respondents
that
own
or
operate
any
new
non­
recovery
battery
on
the
MACT
track
will
be
required
to
develop
a
site­
specific
test
plan
and
conduct
performance
tests;
make
opacity
observations;
add
information
to
the
startup,
shutdown,
and
malfunction
plan;
submit
one­
time
notifications
and
semi­
annual
compliance
reports;
and
maintain
records
of
specific
information
to
ensure
that
the
final
requirements
are
being
achieved.
These
requirements
are
listed
in
Attachment
1.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

Section
112
of
the
CAA
establishes
a
two­
stage
regulatory
process
to
address
emissions
of
hazardous
air
pollutants
(
HAP)
from
stationary
sources.
In
the
first
stage,
EPA
must
establish
MACT
standards
for
new
or
existing
major
or
area
sources
according
to
the
requirements
in
section
112(
d).
Under
section
112(
d)(
6),
EPA
must
review
these
technology­
based
standards,

and,
if
appropriate,
to
revise
them
every
8
years.
In
the
second
stage,
section
112(
f)
requires
EPA
to
determine
whether
the
MACT
standards
protect
the
public
health
with
an
ample
margin
of
safety.

Certain
records
and
reports
are
necessary
for
the
Administrator
to:
(
1)
confirm
the
compliance
status
of
major
sources,
identify
any
non­
major
sources
not
subject
to
the
standards,

and
identify
new
or
reconstructed
sources
subject
to
the
standards;
and
(
2)
ensure
that
the
MACT
3
(
and
residual
risk
)
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
General
Provisions
for
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
in
40
CFR
part
63,
subpart
A..

(
b)
Use/
Users
of
the
Data.

The
additional
information
will
be
used
by
Agency
enforcement
personnel
to
ensure
that
the
emission
limitations
are
being
achieved.
Based
on
review
of
the
recorded
information
at
the
site
and
the
reported
information,
EPA
can
identify
facilities
that
may
not
be
in
compliance
and
decide
which
plants,
records,
or
processes
should
be
inspected.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.

A
computer
search
of
the
Federal
Information
Locator
System
indicated
that,
with
the
exception
of
the
existing
rule,
there
are
no
similar
information
requests
being
carried
out
by
the
Federal
government.
A
similar
search
of
EPA's
ongoing
ICR's
revealed
no
duplication
of
information­
gathering
efforts.
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
proposed
amendments.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
information
that
would
be
required
in
the
semi­
annual
compliance
report.

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

This
section
is
not
applicable
because
this
is
a
rule­
related
ICR.
4
(
c)
Consultations.

These
final
amendments
were
developed
in
consultation
with
State
and
local
agencies,

EPA
Regional
Office
experts,
individual
coke
plants,
and
their
trade
associations.
For
example,

several
meetings
and
telephone
consultations
were
held
with
representatives
from
the
affected
plants,
their
trade
associations,
and
the
American
Iron
and
Steel
(
AISI)/
American
Coke
and
Coal
Chemicals
Institute
(
ACCCI)
Coke
Oven
Environmental
Task
Force
(
COETF).
In
addition,

discussions
were
held
with
the
non­
recovery
plant
(
Indiana
Harbor
Coke).
The
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
Telephone
Number
George
Bradley,
Jr.
Indiana
Harbor
Coke
Co.
(
219)
397­
2180
David
Ailor
ACCCI
(
202)
452­
1140
(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
were
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
a
plant
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.
5
4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
NAIC
Codes.

In
the
existing
rule,
respondents
are
owners
or
operators
of
new
or
existing
byproduct
or
non­
recovery
coke
oven
batteries.
Potential
respondents
under
the
final
amendments
are
owners
or
operators
of
non­
recovery
batteries
that
are
on
the
MACT
track.
We
estimate
that
one
nonrecovery
coke
oven
facility
(
four
batteries)
will
be
subject
to
the
monitoring,
recordkeeping,
and
reporting
requirements;
no
new
non­
recovery
batteries
are
expected
during
the
3­
year
clearance
period
for
this
ICR.
Owners
or
operators
of
by­
product
coke
oven
batteries
are
not
potential
respondents
under
the
amendments
because
they
are
currently
meeting
the
monitoring,

recordkeeping,
and
reporting
requirements
in
the
existing
rule.
The
NAICS
codes
for
this
industry
are
331111,
"
Iron
and
Steel
Mills",
and
324199,
"
All
Other
Petroleum
and
Coal
Products
Manufacturing"
(
i.
e.,
coke
ovens
not
integrated
with
steel
mills).

(
b)
Information
Requested.

(
i)
Data
Items,
Including
Recordkeeping
Requirements.
Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
final
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
Activities.
The
respondent
activities
required
by
the
final
amendments
are
identified
in
Table
2
and
introduced
in
section
6(
a).

5.
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
Table
3
and
introduced
in
section
6(
c).

(
b)
Collection
Methodology
and
Management.

This
is
not
relevant
to
this
information
collection
request.

(
c)
Small
Entity
Flexibility.

A
small
entity
for
this
industry
is
defined
by
the
Small
Business
Administration
as
a
firm
having
no
more
than
1,000
employees.
Of
the
three
companies
that
will
be
subject
to
the
final
amendments,
one
company
(
operating
a
total
of
three
batteries)
is
considered
a
small
entity.

However,
the
final
amendments
will
not
impose
any
significant
additional
regulatory
costs
on
that
small
entity
because
it
is
already
meeting
the
stricter
emission
limitations
for
existing
by­
product
6
coke
oven
batteries
included
in
the
final
amendments,
as
well
as
the
monitoring,
recordkeeping,
and
reporting
requirements.
Although
the
final
amendments
will
not
have
a
significant
economic
impact
on
this
small
entity,
we
nonetheless
tried
to
reduce
the
impact
of
the
final
amendments
on
small
facilities.
We
held
several
meetings
with
industry
trade
associations
and
company
representatives
to
discuss
the
amendments
and
have
included
provisions
to
address
their
concerns.

(
d)
Collection
Schedule.

As
discussed
in
the
ICR
for
the
existing
rule,
information
contained
in
the
periodic
reports
submitted
to
the
EPA
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)

database
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.

Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
National
Compliance
Data
System
operated
and
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance.

Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
enforcement
and
compliance
programs.
A
schedule
for
collection
of
information
and
publication
of
data
is
not
applicable
because
reports
are
triggered
by
actions
of
the
respondents.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.

The
annual
burden
estimates
for
the
additional
recordkeeping
and
reporting
requirements
in
the
final
amendments
are
shown
in
Table
2.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
the
final
amendments
are
presented
in
Table
2.

Because
much
of
the
data
are
already
collected
by
respondents
or
required
by
existing
law,
minimal
respondent
development
costs
are
associated
with
the
information
collection
activities
for
the
final
amendments.

(
i)
Estimating
Labor
Costs.
Labor
rates
and
associated
costs
are
based
on
Bureau
of
Labor
Statistics
(
BLS)
data.
Technical,
management,
and
clerical
average
hourly
rates
for
private
industry
workers
were
taken
from
the
March
2003
Employment
Cost
Trends
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t10.
htm).
Wages
for
white­
collar
occupations
are
used
as
7
the
basis
for
the
labor
rates
with
a
total
compensation
of
$
30.54/
hour
for
technical,
$
44.33/
hour
for
managerial,
and
$
18.88/
hour
for
clerical.
These
rates
represent
salaries
plus
fringe
benefits
and
do
not
include
the
cost
of
overhead.
An
overhead
rate
of
110
percent
is
used
to
account
for
these
costs.
The
fully­
burdened
wage
rates
used
to
represent
respondent
labor
costs
are:
technical
at
$
64.13,
management
at
$
93.09,
and
clerical
at
$
39.64.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs.
As
shown
in
Table
2,
no
(
zero)
capital/
startup
or
O&
M
costs
are
associated
with
the
final
amendments
over
the
3­
year
period
of
this
ICR.
No
(
zero)
capital/
startup
or
O&
M
costs
to
the
industry
are
associated
with
the
existing
rule.

(
iii)
Capital/
Startup
vs.
O&
M
Costs.
The
estimate
of
capital/
startup
costs
vs.
O&
M
costs
is
shown
in
Table
2.
No
(
zero)
O&
M
costs
are
associated
with
the
final
amendments
over
the
3­
year
period
of
this
ICR.
No
(
zero)
O&
M
costs
are
associated
with
the
existing
rule.

(
iv)
Annualizing
Capital
Costs.
As
shown
in
Table
2,
no
(
zero)
annualized
costs
are
associated
with
the
final
amendments
during
the
3­
year
period
of
this
ICR.
No
(
zero)
annualized
costs
are
associated
with
the
existing
rule.

(
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
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
3.

The
Agency
labor
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
2003
General
Schedule
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
Salary
Table
2003­
GS
available
on
the
OPM
website,
http://
www.
opm.
gov­
oca­
03tables/
pdf/
gs
h.
pdf.
The
8
government
employee
labor
rates
are
$
13.91/
hour
for
clerical
(
GS­
7,
Step
1),
$
29.35
for
technical
(
GS­
13,
Step
1),
and
$
40.80/
hr
for
management
(
GS­
15,
Step
1).
These
rates
represent
salaries
plus
fringe
benefits
and
do
not
include
the
cost
of
overhead.
An
overhead
rate
of
110
percent
is
used
to
account
for
these
costs.
The
fully­
burdened
wage
rates
used
to
represent
Agency
labor
costs
are:
clerical
at
$
29.21;
technical
at
$
61.64,
and
management
at
$
85.68.

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

The
EPA
estimates
that
five
plants
(
nine
batteries)
will
be
subject
to
the
final
amendments.

However,
new
monitoring,
recordkeeping,
and
reporting
requirements
will
apply
only
to
one
nonrecovery
facility
with
four
batteries
because
existing
by­
product
batteries
remain
subject
to
the
monitoring,
recordkeeping,
and
reporting
requirements
in
the
existing
rule.
No
new
respondents
are
anticipated
during
the
next
3
years.
Therefore,
the
average
annual
number
of
respondents
is
0.33.
Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
2.

The
total
annual
responses
for
the
existing
rule
is
57.5.
The
number
of
increased
responses
for
the
final
amendments
is
3.
This
number
is
calculated
from
the
number
of
respondents
subject
to
notification
requirements
(
1)
multiplied
by
the
number
of
initial
reports
(
1),
plus
the
number
of
respondents
(
1)
multiplied
by
the
semiannual
compliance
certifications
(
2).
Thus,
the
total
number
of
responses
for
the
rule
is
60.5.

(
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
monitoring,
recordkeeping,
and
reporting
requirements
in
the
existing
rule
is
104,659
person
hours
with
an
annual
average
cost
of
$
5,644,998
with
no
annual
capital
and
O&
M
costs.
The
increased
average
annual
burden
for
the
final
amendments
is
448
person
hours
with
an
annual
average
cost
of
$
28,338
for
technical,
management,
and
clerical
hours
with
no
annual
capital
and
O&
M
costs.
The
total
annual
average
burden
for
the
rule,
including
the
final
amendments
will
be
105,107
person
hours
with
an
annual
average
cost
of
$
5,673,336.
9
(
ii)
The
Agency
tally.
The
average
annual
Federal
Government
cost
for
the
existing
rule
is
$
56,697
for
1,634.4
total
annual
hours.
The
bottom
line
Agency
burden
hours
and
costs
for
the
final
amendments,
presented
in
Table
3,
are
calculated
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,
total
cost
is
the
sum
of
this
total
salary
cost
and
total
travel
expenses
for
tests
attended.
The
increased
total
annual
hours
are
3.4.
The
increased
total
annual
cost
is
$
182.
The
total
average
annual
cost
of
the
rule,
including
the
final
amendments,
is
$
56,879
for
1,637.8
hours.

(
iii)
Variations
in
the
annual
bottom
line.
This
section
does
not
apply
since
no
significant
variation
is
anticipated.

(
f)
Reasons
for
Change
in
Burden.

The
increase
in
burden
is
primarily
due
to
the
monitoring,
recordkeeping,
and
reporting
costs
for
the
final
amendments.
It
is
also
due
to
the
use
of
more
current
labor
rates
for
calculating
the
industry
and
Agency
burden.

(
g)
Burden
Statement
The
increased
average
annual
respondent
burden
for
one
facility
is
estimated
at
448
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
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
10
ID
No.
OAR­
2003­
0051,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B­
102,
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
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
docket.
Use
EDOCKET
to
submit
or
view
public
comments,

and
to
access
the
index
listing
of
the
contents
of
the
public
docket
that
are
available
electronically.

Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
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
EPA
Docket
ID
No.
OAR­
2003­
0051
and
OMB
control
No.
2060­
0253
in
any
correspondence.

PART
B
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
the
final
amendments.
11
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
PROPOSED
AMENDMENTS
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
(
C)

Personhours
per
respondent
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
N/
A
4.
Reporting
Requirements
A.
Read
instructions
2
1
2
0.33b
0.66
0.03
0.07
$
48
B.
Required
activities
Daily
observations
for
door
leaks
1
365
365
1
365
18
37
$
26,553
Revision
to
startup,
shutdown,

and
malfunction
plan
8
1
8
0.33
b
2.64
0.13
0.26
$
192
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Initial
compliance
certification
3
1
3
0.33b
1.0
0.05
0.10
$
72
Semiannual
compliance
certification
3
2
6
1
6.0
0.30
0.60
$
436
5.
Recordkeeping
Requirements
A.
Read
instructions
See
4A
B.
Plan
activities
3
1
3
0.33b
1.0
0.05
0.10
$
72
C.
Implement
activities
2
1
2
0.33b
0.66
0.03
0.07
$
48
D.
Develop
record
system
3
1
3
0.33b
1.0
0.05
0.10
$
72
E.
Time
to
enter
information
0.25
36.5
9.1
1
9
0.5
0.9
$
664
12
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
(
C)

Personhours
per
respondent
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
F.
Time
to
train
personnel
3
1
3
0.33b
1.0
0.05
0.10
$
72
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
3
1
3
0.33
b
1.0
0.05
0.10
$
72
H.
Time
to
transmit
or
disclose
information
0.25
2
0.5
1
0.50
0.03
0.05
$
36
I.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
390
19
39
$
28,338
Annualized
cost
of
capitalc
$
0
Operation
and
maintenancec
$
0
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
64.13,
management
at
$
93.09,
and
clerical
at
$
39.64.

b
Affects
one
non­
recovery
plant.
One
time
event
over
the
3­
year
term
of
the
ICR
(
1/
3
=
0.33
respondents/
yr).

c
There
are
no
capital
costs
or
operation
and
maintenance
costs
associated
with
this
ICR.
13
TABLE
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
OF
THE
PROPOSED
AMENDMENTS
Activity
(
A)

Hours
per
occurrence
(
B)

Hours
per
plant
per
year
(
C)
Plants
per
year
(
D)
Technical
person­
hours
per
year
(
D=
BxC)
(
E)
Management
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
person­
hours
per
year
(
Dx0.1)
(
G)

Cost,
$
a
Initial
performance
test
N/
A
Repeat
performance
test­
Retesting
preparation
N/
A
Repeat
performance­
Retesting
N/
A
Litigation
N/
Ac
Excess
Emissions
Enforcement
Activities
N/
Ac
Report
Review
Notification
of
construction/
reconstruction
N/
A
Notification
of
anticipated
startup
N/
A
Notification
of
actual
startup
N/
A
Notification
of
special
compliance
requirements
N/
A
Notification
of
applicability
N/
A
Notification
of
initial
performance
test
N/
A
Notification
of
CEMS
performance
evaluation
N/
A
CEMS
QA
plan
N/
A
Notification
of
compliance
status
2
2
0.33b
0.66
0.03
0.07
$
45
Site­
specific
test
plan
N/
A
Repeat
performance
test
report
N/
A
Semi­
annual
compliance
report
2
2
0.33b
0.66
0.03
0.07
$
45
NESHAP
waiver
application
NA
Compliance
extension
request
NA
Emergency
startup,
shutdown,
and
malfunction
report
4
4
0.33
b
1.32
0.07
0.13
$
91
TOTAL
BURDEN
AND
COST
(
SALARY)
3
0.1
0.3
$
182
Travel
Expenses
for
Tests
Attended
TOTAL
ANNUAL
COST
$
182
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
61.64,
management
at
$
85.68,
and
clerical
at
$
29.21.
14
b
Affects
one
non­
recovery
plant.
One
time
event
over
the
3­
year
term
of
the
ICR
(
1/
3
=
0.33
respondents/
yr).

c
No
litigation
activities
are
expected.
15
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions
citation
Record
retention
STUDIES
AND
PLANS
Written
work
practice
procedures
for
oven
damper
adjustment/
monitoring
63.303(
c)
N/
A
3
yearsa
Operation
and
maintenance
plan
for
bag
leak
detection
systems
for
non­
recovery
batteries
63.309(
m)
N/
A
3
yearsa
Revision
to
startup,
shutdown,
and
malfunction
plan
for
non­
recovery
coke
oven
batteries
63.310(
f)
63.6(
e)(
3)
Kept
onsite
at
all
times
Site­
specific
test
plan
63.309(
k)
63.7(
c)
3
yearsa
REPORTS
Notification
of
performance
test
63.311(
c)
63.7(
b)
3
yearsa
Initial
compliance
certifications
63.311(
b)
63.9(
h)
3
yearsa
Semiannual
compliance
report
63.311(
d)
N/
A
3
yearsa
RECORDKEEPING
Performance
tests
and
opacity
observations
63.311(
f)(
1)
63.10(
b)(
2)(
viiii)
3
yearsa
Bag
leak
detection
systems
63.311(
f)(
1)
63.10(
b)(
2)(
vi)
3
yearsa
Records
required
to
demonstrate
continuous
compliance
with
work
practices
63.311(
f)(
1)
63.10(
b)(
2)(
viii)
3
yearsa
a
Kept
onsite
for
at
least
1
year
and
accessible
within
3
days
to
the
Administrator
for
the
time
specified
in
40
CFR
70.6(
a)(
3)(
ii)(
B).
