1
SUPPORTING
STATEMENT
NATIONAL
EMISSION
STANDARDS
FOR
COKE
OVEN
BATTERIES:
FINAL
AMENDMENTS
PART
A
1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection.

"
National
Emission
Standards
for
Coke
Oven
Batteries
(
Renewal)."
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
1362.06.

(
b)
Short
Characterization/
Abstract.

Respondents
are
owners
or
operators
of
coke
oven
batteries
subject
to
National
Emission
Standards
for
Coke
Oven
Batteries
(
40
CFR
Part
63,
Subpart
L)
promulgated
on
October
27,

1993.
Two
compliance
approaches
are
available
under
the
rule:
the
"
MACT
(
Maximum
Achievable
Control
Technology)
track"
and
the
"
LAER
(
Lowest
Achievable
Emission
Rate)

extension
track."
Amendments
to
the
1993
rule
were
promulgated
on
April
15,
2005
and
established
more
stringent
visible
emission
limitations
for
doors
and
topside
leaks
on
existing
byproduct
coke
oven
batteries
on
the
MACT
track
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
also
promulgated
emission
limits
and
work
practice
requirements
for
the
improved
control
of
charging
emissions
from
new
or
reconstructed
non­
recovery
batteries.
These
2
requirements
include
an
opacity
limit
for
charging
operations,
emission
and
opacity
limits
for
the
charging
emission
control
device,
and
work
practice
standards.
Other
final
amendments
establish
work
practice
requirements
designed
for
improved
door
leak
control;
these
requirements
apply
to
all
non­
recovery
batteries
on
the
MACT
track.

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

recordkeeping,
and
reporting
provisions.
Respondents
that
own
or
operate
any
new
or
existing
non­
recovery
battery
on
the
MACT
track
will
be
required
to
observe
coke
oven
doors
for
leaks
each
day.
Respondents
that
own
or
operate
any
new
non­
recovery
battery
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
semiannual
compliance
reports;
and
maintain
records
of
specific
information
to
ensure
that
the
final
requirements
are
being
achieved.
These
requirements
are
listed
in
Attachment
1.

This
revised
ICR
also
updates
the
population
of
affected
facilities
associated
with
the
existing
approved
ICR,
which
was
based
on
25
respondents.
Subsequently,
seven
by­
product
recovery
coke
plants
have
permanently
closed,
and
one
new
non­
recovery
coke
plant
began
operation.
As
of
March
2005,
19
respondents
were
owners
or
operators
of
new
or
existing
byproduct
or
non­
recovery
coke
oven
batteries
subject
to
the
regulation.
The
respondents
consist
of
two
sectors
within
the
coke
industry,
iron
and
steel
integrated
plants
that
produce
coke
for
their
operations
(
9
plants)
and
merchant
plants
that
produce
furnace
and
foundry
coke
for
sale
on
the
open
market
(
10
plants).
These
19
coke
plants
operate
55
coke
oven
batteries
(
affected
facilities);

44
are
by­
product
batteries
operated
at
16
plants,
and
11
are
non­
recovery
batteries
operated
at
3
three
plants.
No
additional
respondents
(
new
sources)
are
expected
to
become
subject
to
the
regulation
in
the
next
three
years.

In
general,
all
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)

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
the
standard.
The
owner/
operator
must
also
maintain
a
file
of
these
measurements
and
retain
the
file
for
at
least
five
years.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
regional
office.
The
requirements
are
summarized
in
Attachment
2.

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,
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,
4
and
identify
new
or
reconstructed
sources
subject
to
the
standards;
and
(
2)
ensure
that
the
MACT
(
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)
Practical
Utility/
Users
of
the
Data.

The
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.
5
(
c)
Consultations.

The
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).
6
(
g)
Sensitive
Questions.

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

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
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.
There
are
two
non­
recovery
coke
oven
facilities
subject
to
the
monitoring,
recordkeeping,
and
reporting
requirements
of
the
final
amendments;
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
Standard
Industrial
Classification
(
SIC)
code
for
this
industry
is
SIC
3312,
"
Steel
Works,
Blast
Furnaces
(
including
coke
ovens)
and
Rolling
Mills",

which
under
the
new
North
American
Industrial
Classification
System
(
NAICS)
codes
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.
Attachments
1
and
2
summarize
the
recordkeeping
and
reporting
requirements
of
the
final
rule
amendments
and
the
1993
rule,

respectively.

(
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).
7
(
b)
Collection
Methodology
and
Management.

Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
compliance
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
Air
Facility
System
(
AFS),
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,

maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.

EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

(
c)
Small
Entity
Flexibility.

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
at
two
plants)
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
byproduct
coke
oven
batteries
included
in
the
final
amendments,
as
well
as
the
monitoring,

recordkeeping,
and
reporting
requirements
of
the
1993
rule.
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
their
concerns.

(
d)
Collection
Schedule.

The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2.

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
and
the
updated
estimates
for
the
original
rule
are
shown
in
Table
2.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.
8
(
b)
Estimating
Respondent
Costs.

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

Because
most
of
the
data
is
already
collected
by
respondents
as
required
by
the
existing
rule,

minimal
respondent
development
costs
are
associated
with
the
information
collection
activities.

(
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
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2005,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group"
available
at
http://
www.
bls.
gov/
news.
release/
ecec.
t02.
htm.
Wages
for
occupational
groups
are
used
as
the
basis
for
the
labor
rates
with
a
total
compensation
of
$
40.41/
hour
for
technical,
$
47.90/
hour
for
managerial,
and
$
20.61/
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
hourly
wage
rates
used
to
represent
respondent
labor
costs
are:

technical
at
$
84.86,
management
at
$
100.59,
and
clerical
at
$
43.28.

(
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
or
with
the
existing
rule
over
the
3­
year
period
of
this
ICR.

(
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
or
with
the
existing
rule
over
the
3­
year
period
of
this
ICR.

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

(
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.
9
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)
2005
General
Schedule,
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
Salary
Table
2005­
GS
available
on
the
OPM
website,
http://
www.
opm.
gov/
oca/
05tables/
pdf/
gs_
h.
pdf.
The
government
employee
labor
rates
are
$
14.06/
hour
for
clerical
(
GS­
6,
Step
3),
$
25.98
for
technical
(
GS­
12,
Step
1),
and
$
35.01/
hr
for
management
(
GS­
13,
Step
5).
These
rates
were
increased
by
60
percent
to
include
fringe
benefits
and
overhead.
The
fully­
burdened
wage
rates
used
to
represent
Agency
labor
costs
are:
clerical
at
$
22.50,
technical
at
$
41.57,
and
management
at
$
56.02.

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

There
are
19
existing
sources
that
are
currently
subject
to
the
regulation.
No
new
sources
are
expected
to
become
subject
to
the
standard
in
the
next
three
years.
Consequently,
the
average
number
of
respondents
over
the
three­
year
period
of
this
ICR
is
19.
The
primary
component
of
the
total
annual
responses
is
the
semiannual
compliance
report,
which
is
required
for
all
19
respondents.
As
shown
below,
we
estimate
that
one
respondent
may
reconstruct
a
battery
and
one
may
close
a
battery
over
the
3­
year
period
(
0.33
respondents
per
year),
two
respondents
per
year
may
report
a
malfunction,
and
10
percent
of
the
16
respondents
with
by­
product
recovery
batteries
may
report
a
venting
episode.
The
number
of
total
annual
responses
is
estimated
as
42.3.
Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
2.
10
(
A)

Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Total
Annual
Responses
D=(
B*
C)

Semiannual
Compliance
Report
19
2
38
Notification
of
Construction/
Reconstruction
0.33
1
0.33
Notification
of
Malfunction
and
Report
2
1
2
Notification
of
Battery
Closure
0.33
1
0.33
Report
of
Venting
Coke
Oven
Gas
Episode
at
a
Stack
Flare
1.6
1
1.6
Total
42.3
(
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
and
amendments
is
80,119
person
hours
with
an
annual
average
cost
of
$
6,564,046
with
no
annual
capital
and
O&
M
costs.

(
ii)
The
Agency
tally.
The
average
annual
Federal
Government
cost
is
$
4,686
for
116
total
annual
hours.
The
bottom
line
Agency
burden
hours
and
costs
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.

(
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
burden
estimate
decreased
by
24,988
hours
(
from
105,107
hours
to
80,119
hours).

The
change
was
due
to
an
adjustment
to
the
number
of
respondents
from
25
to
19
to
account
for
permanent
plant
closures
and
the
start­
up
of
one
new
plant.
11
(
g)
Burden
Statement
The
average
annual
respondent
burden
is
4,217
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
ID
No.
EPA­
HQ­
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
for
online
viewing
at
www.
regulations.
gov.
Use
EPA's
electronic
docket
and
comment
system
at
www.
regulations.
gov
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
Docket
Search
under
Advanced
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.
EPA­
HQ­
OAR­
2003­
0051
in
any
correspondence.
12
PART
B
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
the
final
amendments.
13
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST:
NESHAP
for
Coke
Oven
Batteries
(
40
CFR
Part
63,
Subpart
L)

Burden
item
(
A)
Personhours
per
occurrence
(
B)
No.
of
occurrences
per
respondent
(
C)
Person­
hours
per
respondent
(
C=
A*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
E*
0.1)
(
H)
Cost
b,
$

1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
N/
A
4.
Reporting
Requirements
A.
Read
instructions
8
1
8
19
152
7.6
15.2
$
14,321
B.
Required
activities
ALL
PLANTS:

Daily
performance
tests/
visible
observations
c
8.25
365
3,011
19
57,214
2,861
5,721
$
5,390,536
Certification
Program
d
24
1
24
19
456
22.8
45.6
$
42,963
Implement
work
practice
plan
40
1
40
19
760
38
76
$
71,605
Implement
startup,
shutdown,
and
malfunction
plan
40
1
40
19
760
38
76
$
71,605
NON­
RECOVERY
PLANTS:

Coke
oven
doors:
daily
pressure
monitoring
e
0.5
365
182.5
3
547.5
27.4
54.75
$
51,584
Coke
oven
doors:
leak
detection
procedures
f
1
365
365
2
730
36.5
73
$
68,779
Charging
operations:
work
practices
on
the
control
equipment
g
0.5
365
182.5
3
547.5
27.4
54.75
$
51,584
BY­
PRODUCT
PLANTS:

Daily
inspection
of
the
collecting
main
for
leaks
0.5
365
182.5
17
3,103
155.1
310.3
$
292,310
Inspect
bypass/
bleeder
stack/
flare
system
h
0.5
365
182.5
17
3,103
155.1
310.3
$
292,310
Coke
oven
doors
with
sheds
complying
with
the
alternative
standard:

initial
and
regular
performance
test
and
monitoring
of
opacity
i
N/
A
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Notification
requirements
include:

­
Election
of
compliance
track
j
2
0
0
0
0
0
0
$
0
­
Construct/
reconstruct
a
new
battery,
a
brownfield
battery,
or
a
padup
rebuild
battery
k
2
1
2
0.33
0.66
0.033
0.066
$
62
Malfunction
notification
and
report
l
26
1
26
2
52
2.6
5.2
$
4,899
Report
of
plant
or
battery
closure
m
2
1
2
0.33
0.66
0.033
0.066
$
62
Report
of
venting
of
coke
oven
gas
through
a
bypass/
bleeder
stack
n
25
1
25
1.6
40
2
4
$
3,769
Initial
compliance
certification
o
3
0
0
0
0
0
0
$
0
Semiannual
compliance
certifications
2
2
4
19
76
3.8
7.6
$
7,161
5.
Recordkeeping
Requirements
14
Burden
item
(
A)
Personhours
per
occurrence
(
B)
No.
of
occurrences
per
respondent
(
C)
Person­
hours
per
respondent
(
C=
A*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
E*
0.1)
(
H)
Cost
b,
$

A.
Read
instructions
See
4A
B.
Plan
activities
See
4A
C.
Implement
activities
See
4A
D.
Record
information:
all
data
required
by
rule
1.5
52
78
19
1,482
74.1
148.2
$
139,630
E.
Time
to
transmit
or
disclose
information
1
2
2
19
38
1.9
3.8
$
3,580
F.
Time
to
train
personnel
32
1
32
19
608
30.4
60.8
$
57,284
G.
Time
for
audits
N/
A
Subtotal
69,669
3,483
6,967
$
6,564,046
TOTAL
LABOR
BURDEN
AND
COST
80,119
hours
$
6,564,046
Annualized
cost
of
capital
p
$
0
Operation
and
maintenance
p
$
0
Footnotes:

a
There
are
19
respondents
that
are
currently
owners
or
operators
of
new
or
existing
byproduct
or
non­
recovery
coke
oven
batteries
subject
to
40
CFR
Part
63,

subpart
L.
As
of
March
2005,
these
19
coke
plants
were
operating
55
coke
oven
batteries
(
affected
facilities);
44
are
by­
product
batteries
operated
at
16
plants,

and
11
are
non­
recovery
batteries
operated
at
three
plants.
No
additional
respondents
(
new
sources)
are
expected
over
the
next
three
years.

b
This
ICR
uses
the
following
labor
rates:
$
100.59
for
managerial
labor,
$
84.86
for
technical
labor,
and
$
43.28
for
clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2005,
A
Table
2.
Civilian
Workers,
by
occupational
and
industry
group.@
The
rates
are
from
column
1,
A
Total
compensation.@
The
rates
reflect
an
increase
of
110%
to
account
for
overhead
costs.

c
Daily
performance
tests
are
conducted
by
a
certified
observer
provided
by
the
State
enforcement
agency
for
each
emission
point
on
each
battery.
Respondents
reimburse
States
through
permit
fees.
Based
on
an
average
of
3
coke
ovens
batteries
per
plant,
the
total
person
hours
for
inspections
is
estimated
at
8.25
hours
using
the
cost
formula
for
calculating
reimbursement
costs
included
in
the
rule.

d
This
burden
includes
the
indirect
costs
to
respondents
to
provide
certification
to
the
observer
provided
by
the
State
enforcement
agency
or
its
contractor
including
a
3­
day
EPA
certification
course.

e
The
owners
or
operators
of
three
existing
non­
recovery
plants
are
required
to
either
conduct
leak
detection
procedures
or
monitor
oven
pressure
each
day.
The
plants
have
elected
to
monitor
pressure.

f
The
promulgated
rule
amendments
(
70
FR
19992,
April
15,
2005)
require
visible
emission
observations
of
doors
for
two
non­
recovery
plants
that
are
not
on
the
LAER
extension
track.

g
The
owners
or
operators
of
three
existing
non­
recovery
plants
are
required
to
implement
specified
work
practices
for
the
control
of
emissions
from
charging
operations
and
to
document
the
performance
of
each
procedure.

h
All
17
of
the
by­
product
coke
plants
must
install
and
maintain
flares.

i
None
of
the
plants
with
cokeside
sheds
have
applied
for
the
alternative
door
standard.

j
All
sources
have
submitted
this
notification
(
the
deadline
was
January
1,
1998).

k
Assume
that
one
plant
would
submit
a
notification
to
reconstruct
a
battery
over
the
3­
year
period.
15
l
Assume
that
one
plant
per
year
may
experience
a
malfunction
requiring
notification
to
inform
the
Agency
and
a
written
report.

m
Assume
that
one
plant
over
a
three
year
period
is
expected
to
permanently
close
one
or
more
batteries
and
submit
the
required
notification.

n
Ten
percent
of
the
16
by­
product
plants
(
1.6)
are
expected
to
experience
a
venting
episode
where
emissions
are
released
through
bypass/
bleeder
stacks
without
flaring
requiring
notification
and
a
written
report.

o
All
of
the
existing
plants
have
already
submitted
initial
compliance
certifications.

p
There
are
no
capital
costs
or
operation
and
maintenance
costs
associated
with
this
ICR.
16
TABLE
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT:

NESHAP
for
Coke
Oven
Batteries
(
40
CFR
Part
63,
Subpart
L)

Burden
Item
(
A)
Person
hours
per
occurrence
(
B)
Occurrences
per
plant
per
year
(
C)
Plants
per
year
a
(
D)
Technical
hours/
year
(
E=
A*
B*
C)
(
E)
Management
hours/
year
(
F=
0.05*
D)
(
F)
Clericalhours
year
(
G=
0.1*
D)
(
G)
Cost
b,

$

Report
Review:

Site­
specific
test
plan
N/
A
NESHAP
waiver
application
N/
A
Compliance
extension
request
N/
A
Work
practice
plan
c
N/
A
Startup,
shutdown
and
malfunction
plan
c
N/
A
Construct/
reconstruct
a
new
battery,
a
brownfield
battery,
or
a
padup
rebuild
battery
d
2
1
0.33
0.66
0.033
0.066
$
31
Request
for
startup
of
cold­
idle
battery
e
N/
A
Notification
of
election
of
compliance
track
f
N/
A
Request
for
alternative
door
standard
g
N/
A
Notification
of
closure
of
batteries
h
2
1
0.33
0.66
0.033
0.066
$
31
Malfunction
notification
i
2
1
2
4
0.2
0.4
$
186
Malfunction
report
i
8
1
2
16
0.8
1.6
$
746
Report
of
venting
of
coke
oven
gas
through
a
bypass/
bleeder
stack
flare
j
2
1
1.6
3.2
0.16
0.32
$
149
Initial
compliance
certification
k
N/
A
Semiannual
compliance
certifications
l
2
2
19
76
3.8
7.6
$
3,543
Subtotal
Burden
and
Cost
100.5
5.0
10.1
$
4,686
TOTAL
BURDEN
AND
COST
116
hours
$
4,686
17
Footnotes:

a
There
are
19
respondents
that
are
currently
owners
or
operators
of
new
or
existing
byproduct
or
non­
recovery
coke
oven
batteries
subject
to
40
CFR
Part
63,

subpart
L.
As
of
March
2005,
these
19
coke
plants
were
operating
55
coke
oven
batteries
(
affected
facilities);
44
are
by­
product
batteries
operated
at
16
plants,

and
11
are
non­
recovery
batteries
operated
at
three
plants.
No
additional
respondents
(
new
sources)
are
expected
over
the
next
three
years.

b
This
ICR
uses
the
following
average
hourly
labor
rates:
56.02
for
Managerial
(
GS­
13,
Step
5,
$
35.01
x
1.6),
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
for
Technical
and
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)
for
Clerical.
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
A
2005
General
Schedule
@
which
excludes
locality
rates
of
pay.

c
These
plans
have
already
been
submitted.

d
Assume
that
one
plant
over
the
3
year
period
will
reconstruct
or
rebuild
a
battery.

e
There
are
no
batteries
on
cold
idle.

f
All
sources
have
submitted
this
notification
(
the
deadline
was
January
1,
1998).

g
None
of
the
plants
with
cokeside
sheds
have
applied
for
the
alternative
door
standard.

h
Assume
that
one
plant
over
a
three
year
period
is
expected
to
permanently
close
batteries
and
submit
the
required
notification.

i
Assume
that
one
plant
per
year
may
experience
a
malfunction
requiring
notification
to
inform
the
Agency
and
a
written
report.

j
Ten
percent
of
the
16
by­
product
plants
are
expected
to
experience
a
venting
episode
where
emissions
are
released
through
bypass/
bleeder
stacks
without
flaring
requiring
notification
and
a
written
report.

k
All
sources
have
already
submitted
this
initial
notification.

l
All
plants
are
required
to
submit
semiannual
compliance
certifications.
18
ATTACHMENT
1.
INFORMATION
REQUIREMENTS
FOR
THE
RULE
AMENDMENTS
Plans
Citation
Written
work
practice
procedures
for
oven
damper
adjustment/
monitoring
for
non­
recovery
batteries
63.303(
c)

Operation
and
maintenance
plan
for
bag
leak
detection
systems
for
new
non­
recovery
batteries
63.309(
m)

Revision
to
startup,
shutdown,
and
malfunction
plan
for
nonrecovery
coke
oven
batteries
63.6(
e)(
3),
63.310(
f)

Site­
specific
test
plan
for
new
non­
recovery
batteries
63.7(
c),
63.309(
k)

Reports
Notification
of
performance
test
63.7(
b),
63.311(
c)

Initial
compliance
certifications
63.9(
h),
63.311(
b)

Semiannual
compliance
report
63.311(
d)

Records
Performance
tests
and
opacity
observations
63.10(
b)(
2)(
viiii),
63.311(
f)(
1)

Bag
leak
detection
systems
63.10(
b)(
2)(
vi),
63.311(
f)(
1)

Records
required
to
demonstrate
continuous
compliance
with
work
practices
63.10(
b)(
2)(
viii),
63.311(
f)(
1)
19
ATTACHMENT
2.
INFORMATION
REQUIREMENTS
FOR
THE
1993
RULE
Notifications
Citation
Intention
to
construct
a
new,
brownfield,
or
padup
rebuild
coke
oven
battery
63.311(
c)(
1),
63.5,
63.9(
b)

Notification
of
compliance
status
when
a
source
becomes
subject
to
the
standard
63.9(
h),
63.311(
c)(
2)

Notification
that
source
is
subject
to
special
compliance
requirements:
obtaining
an
exemption
from
control
requirements
for
bypass\
bleeder
stacks
by
committing
to
permanent
closure
of
a
battery
or
using
an
equivalent
alternative
control
system
for
the
stacks;
and
obtaining
an
alternative
standard
for
coke
oven
doors
on
a
battery
equipped
with
a
shed
63.9(
d)

Initial
performance
test
63.7(
b),
63.9(
e)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Notification
requirements
for
coke
ovens
with
a
shed
using
a
continuous
monitoring
system
for
opacity
of
emissions
discharged
from
the
emission
control
equipment;
and
meeting
the
alternative
standard
63.9(
g),
63.305(
f)(
4)

Demonstration
of
continuous
monitoring
system
63.9(
g)

Change
in
information
already
provided
63.9(
j)

Request
for
an
extension
of
compliance
with
relevant
standard
63.9(
c)

Reports
Application
for
approval
of
the
construction
or
reconstruction
of
a
new
major
affected
source,
or
reconstruction
of
a
major
affected
source
63.5(
6)(
d),
63.9(
b)(
1)(
iiii)

Performance
test
results
60.8
(
a),
61.13(
f),
63.10(
d)(
2),
63.309
Report
of
opacity
and
visible
emission
observations
63.9(
f)

Emission
control
work
practices
plan
for
each
coke
oven
battery
63.306(
a)

Opacity
or
visible
emissions
63.10(
d)(
3)

Periodic
startup,
shutdown
and
malfunction
reports
63.10(
d)(
5)(
I)

Initial
compliance
certification
63.9(
h),
63.111(
b)

Submit
semiannual
compliance
certifications
63.9(
h),
63.311(
d)

Records
Startup,
shutdown
and
malfunction
plan.
63.6(
e)(
3),
63.1(
b)(
2),
63.310,
63.311(
f)(
6)

All
reports
and
notifications.
63.10(
b)(
1)
20
Any
applicability
determination
that
demonstrates
why
owner
or
operator
believes
source(
s)
is/
are
unaffected.
63.10(
b)(
3)

Copy
of
the
coke
oven
emission
control
work
practice
plan
and
revisions,
and
records
related
to
implementation
of
plan
requirements.
63.306,
63.311(
f)(
3­
4)

For
an
approved
alternative
emission
limitation:
monitoring
records
of
parameters
that
indicate
the
exhaust
flow
rate
is
maintained,
records
for
the
continuous
opacity
monitoring
system,
and
quarterly
visual
inspection
of
the
shed.
63.10(
c),
63.311(
f)(
2)

For
the
bypass/
bleeder
stack
flare
system
or
an
approved
alternative
control
device:
design
of
drawings
and
of
engineering
specifications.
63.311(
f)(
5)

For
non­
recovery
coke
oven
batteries:
records
of
daily
operating
parameters
and
design
characteristics.
63.111(
f)(
1)
