SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Steel
Pickling,
HCl
Process
Facilities
and
Hydrochloric
Acid
Regeneration
Plants
(
40
CFR
Part
63,
Subpart
CCC)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Steel
Pickling,
HCl
Process
Facilities
and
Hydrochloric
Acid
Regeneration
Plants
(
40
CFR
part
63,
subpart
CCC)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Steel
Pickling,
published
at
40
CFR
part
63,
subpart
CCC,
were
proposed
on
September
18,
1997
(
62
FR
49051)
and
promulgated
on
June
22,
1999
(
64
FR
33202).
This
rule
applies
to
all
facilities
that
pickle
steel
using
hydrochloric
acid
or
regenerate
hydrochloric
acid,
and
are
major
sources
or
are
part
of
a
facility
that
is
a
major
source.
This
regulation
does
not
apply
to
any
pickling
line
that
uses
an
acid
other
than
hydrochloric
acid
or
an
acid
solution
containing
less
than
6
percent
HCl
or
at
a
temperature
less
than
100
º
F.
This
rulemaking
establishes
limits
for
hydrochloric
acid
emissions
from
continuous
and
batch
pickling
lines
and
acid
regeneration
units
and
limits
for
chlorine
emissions
from
acid
regeneration
units.
Also,
operational
and
equipment
standards
are
established
for
stationary
acid
storage
vessels.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
by
the
owners/
operators
of
the
affected
facilities.
Consistent
with
the
NESHAP
General
Provisions
(
40
CFR
part
63,
subpart
A),
respondents
submit
one­
time
notifications
of
applicability
and
a
one­
time
report
on
performance
test
results
for
the
primary
emission
control
device.
Plants
also
must
develop
and
implement
a
Startup,
Shutdown,
and
Malfunction
Plan
(
SSMP)
and
submit
semiannual
reports
of
any
event
where
the
procedures
in
the
plan
were
not
followed.
Sources
are
required
to
submit
semiannual
reports.
NESHAP
subpart
CCC
also
requires
the
owner
or
operator
to
submit
a
written
maintenance
plan
for
each
emission
control
device.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
the
NESHAP.

Any
owner/
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
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
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.
2
According
to
EPA's
"
MACT
Tool"
database,
there
are
approximately
82
facilities
subject
to
the
NESHAP
subpart
CCC
standards.
Upon
further
consultation
with
the
EPA
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS),
we
have
determined
that
72
respondents
(
i.
e.,
64
of
82
existing
steel
pickling
facilities
and
8
acid
regeneration
plants
are
using
hydrochloric
acid)
are
currently
subject
to
the
standard.
Furthermore,
one
additional
respondent
will
become
subject
to
the
regulation
in
the
next
three
years.

OMB
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance".

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
section
114(
a)
states
that
the
Administrator
may
require
any
owner/
operator
subject
to
any
requirement
of
this
Act
to:

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

In
the
Administrator's
judgment,
hydrochloric
acid
emissions
from
continuous
and
batch
pickling
lines
and
acid
regeneration
units,
and
chlorine
emissions
from
acid
regeneration
units
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
standards
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
CCC.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standard
ensure
compliance
with
the
applicable
regulations
which
where
promulgated
in
accordance
with
the
Clean
Air
Act.
The
3
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.

Performance
tests
are
required
in
order
to
determine
an
affected
facility's
initial
capability
to
comply
with
the
emission
standard.
Continuous
emission
monitors
are
used
to
ensure
compliance
with
the
standard
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
the
standard
are
used
to
inform
the
Agency
or
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.
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.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
CCC.

3(
a)
Nonduplication
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
similar
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,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
70
FR
24020)
on
May
6,
2005.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
After
reviewing
our
internal
data
sources
and
discussing
the
industry
growth
rate
with
the
Agency
industry
experts,
we
have
determined
that
additional
consultations
with
industry
are
4
inappropriate
for
this
ICR
renewal.

The
standard
was
developed
with
the
participation
and/
or
consultation
with
industry
representatives.
In
addition,
the
Agency
has
performed
additional
reviews
to
determine
additional
burden
reduction
opportunities.
The
Agency
currently
collects
the
minimum
amount
of
information
necessary
to
ensure
compliance
with
the
standard.

3(
d)
Effects
of
Less
Frequent
Collection
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
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
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
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
5
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
facilities
that
pickle
steel
using
hydrochloric
acid
or
regenerate
hydrochloric
acid
and
are
major
sources
or
are
part
of
a
facility
that
is
a
major
source.
The
SIC
(
U.
S.
Standard
Industrial
Classification)
codes
for
the
respondents
affected
by
40
CFR
part
63,
subpart
CCC
and
the
corresponding
NAICS
(
The
North
American
Industry
Classification
System)
codes
are
listed
below:

SIC
Code
and
Description
Corresponding
NAICS
Code
and
Description
3312
­
Steel
Works,
Blast
Furnaces
(
Including
Coke
Ovens),
and
Rolling
Mills
(
except
coke
ovens
not
integrated
with
steel
mills
331111­
Iron
and
Steel
Mills;
31221­
Rolled
Steel
Shape
Manufacturing
3315
­
Steel
Wiredrawing
and
Steel
Nails
and
Spikes
(
steel,
wire
drawing)
331222
­
Steel
Wire
Drawing
3316
­
Cold­
Rolled
Steel
Sheet,
Strip
and
Bars
331221
­
Rolled
Steel
Shape
Manufacturing
3317
­
Steel
Pipe
and
Tubes
33121
­
Iron
and
Steel
Pipe
and
Tube
Manufacturing
from
Purchased
Steel
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
40
CFR
part
63,
subpart
CCC.

A
source
must
make
the
following
reports:
6
Notification
Reports
Notification
when
an
area
source
subsequently
becomes
subject
to
the
rule
requirements.
63.9(
b)(
1),
63.1163(
a)(
1)

Notification
of
rule
applicability
63.9(
a)(
2),
63.1163(
a)(
2)

Notification
and
application
of
construction
or
reconstruction
63.9(
b)(
3­
4),
63.1163(
a)(
3­
4)

Notification
and
application
of
intent
to
construct
a
new
affected
source
63.9(
b)(
5),
63.1163(
a)(
5)

Request
for
an
extension
of
compliance
63.1163(
b)

Notification
that
the
source
is
subject
to
special
compliance
requirements
63.1163(
c)

Notification
of
performance
tests.
63.7(
b),
63.9(
e),
63.1163(
d)

Notification
of
physical
or
operational
change
which
may
increase
the
emission
rate.
N/
A
Notification
of
compliance
status
63.9(
h),
63.1163(
e)

Reports
for
40
CFR
Part
63,
Subpart
CCC
Report
of
performance
test
results
63.10(
d)(
2),
63.1164(
a)

Demonstration
of
continuous
monitoring
system,
if
applicable
63.9(
g)

Progress
reports,
if
applicable
63.6(
i),
63.1164(
b)

A
start­
up,
shutdown,
malfunction
(
SSM)
plan
and
periodic
SSM
reports
when
there
is
a
deviation
from
the
plan
63.10(
d)(
5)(
I),
63.1164(
c)(
1­
3)
7
A
source
must
keep
the
following
records:

Recordkeeping
Start­
ups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2),
63.1165(
a)

Emission
test
results
and
other
data
needed
to
determine
emissions
61.13(
g),
63.1165(
a)(
7)

All
reports
and
notifications
63.9,
63.10(
b),
63.1165(
a)(
10)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
3)

Records
are
required
to
be
retained
for
five
years.
The
first
two
years
of
records
must
be
retained
at
the
facility.
63.1165(
a­
c)

Electronic
Reporting
At
the
present,
respondents
are
using
monitoring
equipment
that
automatically
records
parameter
data,
e.
g.,
temperature,
pressure
drop,
leaks
and
spills
of
mercury,
etc.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

Also,
regulatory
agencies
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
electronic
reporting
systems
are
still
not
widely
used.
At
this
time,
it
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Owners
of
acid
regeneration
plants
shall
install,
calibrate,
maintain,
and
operate
systems
for
the
measurement
of
process
off
gas
temperature,
excess
air
proportion,
make­
up
water
flow,
and
recirculation
flow
rate
for
web
scrubbers
or
other
parameters
established
during
the
performance
test
for
an
alternative
control
device.

Perform
initial
performance
test,
Reference
Methods
1,
2,
3,
4
and
26A
test
or
approved
alternative
method,
and
repeat
performance
tests
if
necessary.
8
Respondent
Activities
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
the
purpose
of
collecting,
validating,
and
verifying
information.

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

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
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.

Transmit,
or
otherwise
disclose
the
information.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
EPA's
Air
Facility
System
(
AFS)
and
the
MACT
Tool
databases
through
the
Online
Tracking
Information
System
(
OTIS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
9
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
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
entered
into
the
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.

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

5(
c)
Small
Entity
Flexibility
During
the
development
of
the
NESHAP
for
steel
pickling,
it
was
determined
that
there
are
no
small
businesses
that
would
be
subject
to
the
NESHAP
or
incur
adverse
economic
impacts.
For
firms
that
are
not
small
entities
by
this
definition,
the
rule
provides
flexibility
to
the
regulated
community
in
the
choice
of
emission
limits
or
performance
standards.
Provisions
also
are
included
to
allow
additional
time
to
comply
if
needed
for
the
installation
of
capture
or
control
equipment.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Steel
Pickling,
HCl
Process
Facilities
and
Hydrochloric
Acid
Regeneration
Plants
(
40
CFR
Part
63,
Subpart
CCC).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
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.
10
6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
25,448
(
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.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
97.46
($
46.41
+
110%)
Technical
$
83.71
($
39.86
+
110%)
Clerical
$
42.55
($
20.26
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
flow
monitors
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Star
tup
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Star
tup
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

Flowmeters
with
high/
low
alarms
$
830
1
$
830
$
106
72.3
$
7,663.8
11
The
total
capital/
startup
costs
for
this
ICR
are
$
830.
This
cost
is
associated
with
the
new
source
buying
two
recording
flow
meters
with
high/
low
alarms
and
its
supporting
equipment.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
7,664
(
rounded).
This
cost
is
associated
with
all
sources
having
O&
M
costs
associated
with
two
recording
flowmeters
with
high/
low
alarms
which
have
a
lifetime
of
15
years.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
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
$
8,494
(
rounded).
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.
The
figures
on
the
OMB
83­
I
form
reflect
the
rounding
up
of
each
cost
individually,
so
the
total
cost
is
$
9,000
(
rounded).

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
16,784
(
see
Table
2
attached).

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

Managerial
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
Technical
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Burden
and
Cost
to
the
Federal/
State
Government:
NESHAP
for
Steel
Pickling,
HCl
Process
Facilities
and
Hydrochloric
Acid
Regeneration
Plants
(
40
CFR
Part
63,
Subpart
CCC),
attached.
12
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
on
average
over
the
next
three
years,
approximately
72
existing
respondents
will
be
subject
to
the
standard.
It
is
estimated
that
one
additional
respondent
will
become
subject
to
this
standard
over
the
three
year
period
of
this
ICR.
The
overall
average
number
of
respondents,
as
shown
in
the
table
below
is
72.3
per
year.

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

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0.3
72
0
0
72.3
2
0.3
72
0
0
72.3
3
0.3
72
0
0
72.3
Average
0.3
72
0
0
72.3
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.
.
To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
72
(
rounded).
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
number
of
Total
Annual
Responses
is
153
(
rounded),
as
described
below.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.
13
Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)

Number
of
Respondents
(
C)

Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
of
applicability
0.3
1
N/
A
0.3
Notification
of
construction/
reconstruction
0.3
1
N/
A
0.3
Notification
of
actual
startup
0.3
1
N/
A
0.3
Notification
of
special
compliance
requirements
0.3
1
N/
A
0.3
Notification
of
initial
performance
test
0.3
1
N/
A
0.3
Notification
of
compliance
status
0.3
1
N/
A
0.3
Report
of
monitoring
exceedances
14.4
2
N/
A
28.4
Report
of
no
excess
emissions
57.6
2
N/
A
115.2
Startup,
shutdown,
malfunction
report
3.6
2
N/
A
7.2
Total
152.6
6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
total
annual
labors
hours
are
25,448
(
rounded).
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
2,054,373
(
rounded).
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Steel
Pickling,
HCl
Process
Facilities
and
Hydrochloric
Acid
Regeneration
Plants
(
40
CFR
Part
63,
Subpart
CCC),
attached.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
166
(
rounded)
hours
per
response.
14
The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
8,494
(
rounded).
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
418
labor
hours
at
a
cost
of
$
16,784.
See
Table
2:
Annual
Agency
Burden
and
Cost:
NESHAP
for
Steel
Pickling,
HCl
Process
Facilities
and
Hydrochloric
Acid
Regeneration
Plants
(
40
CFR
Part
63,
Subpart
CCC),
attached.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
labor
burden
from
the
most
recently
approved
ICR
(
from
25,104
to
25,448
hours)
is
due
to
an
adjustment.
The
adjustment
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
increase
in
the
number
of
new
or
modified
sources.
In
addition,
there
was
a
small
increase
on
the
annualized
cost
associated
with
continuous
emission
monitoring
for
the
renewal
of
the
ICR
due
to
the
operation
and
maintenance
costs
for
more
existing
sources.

However,
the
Federal/
state
burden
significantly
decreased
in
this
renewal
of
the
ICR
(
from
$
99,336
to
$
16,784)
since
we
deleted
all
costs
associated
with
inspection
activities
which
are
exempt
under
the
Paperwork
Reduction
Act.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
166
hours
per
response.
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
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
15
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2005­
0047,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
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
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
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
Number
OECA­
2005­
0047
and
OMB
Control
Number
2060­
0419
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
16
TABLE
1.
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Steel
Pickling,
HCl
Process
Facilities
and
Hydrochloric
Acid
Regeneration
Plants
(
40
CFR
Part
63,
Subpart
CCC)

Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
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.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
b
4
1
4
0.3
1.20
0.06
0.12
$
111.41
B.
Required
activities
Initial
performance
test
b,
h
125
1
125
0.3
37.50
1.88
3.75
$
3,481.91
Repeat
performance
test
d
125
1
125
0
0.00
0.00
0.00
$
0.00
Annual
performance
test
c
125
1
125
72
9,000.00
450.00
900.00
$
835,542.00
Startup,
shutdown
and
malfunction
plan
b
40
1
40
0.3
12.00
0.60
1.20
$
1,114.06
Maintenance
plan
b
40
1
40
0.3
12.00
0.60
1.20
$
1,114.06
Maintenance
plan
revision
f
40
1
40
7.2
288.00
14.40
28.80
$
26,737.34
C.
Create
information
See
3B
D.
Gather
existing
information
See
3B
E.
Write
report
17
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
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
Notification
of
applicability
g
2
1
2
0.3
0.60
0.03
0.06
$
55.70
Notification
of
construction/
reconstruction
h
2
1
2
0.3
0.60
0.03
0.06
$
55.70
Notification
of
actual
startup
g
2
1
2
0.3
0.60
0.03
0.06
$
55.70
Notification
of
special
compliance
requirements
i
N/
A
Notification
of
performance
test
d
2
1
2
0.3
0.60
0.03
0.06
$
55.70
Notification
of
compliance
status
g
4
1
4
0.3
1.20
0.06
0.12
$
111.41
NESHAP
waiver
application
i
N/
A
Report
of
performance
test
d
See
3B
Report
of
monitoring
exceedances
j
16
2
32
14.4
460.80
23.04
46.08
$
42,779.75
Report
of
no
excess
emissions
j
8
2
16
57.6
921.60
46.00
92.16
$
85,559.50
Startup,
shutdown,

malfunction
report
k
8
2
16
3.6
57.60
2.88
5.76
$
5,347.47
4.
Recordkeeping
Requirements
18
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
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
A.
Read
instructions
See
3B
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
all
information
required
by
standards
l,
m
3
52
156
72.3
11,278.80
563.94
1,127.88
$
1,047,101.20
F.
Time
to
train
personnel
4
1
4
0.3
1.20
0.06
0.12
$
111.41
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
N/
A
H.
Time
to
transmit
or
disclose
information
m
0.25
3
0.75
72.3
54.23
2.71
5.42
$
5,034.33
I.
Time
for
audits
N/
A
Subtotal
Burden
and
Cost
22,128.53
1,106.43
2,212.85
$
2,054,372.60
TOTAL
BURDEN
AND
COST
(
Rounded)
25,448
$
2,054,373
Assumptions:
a
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry
which
are
technical
at
$
83.71,
management
at
$
97.46,
and
clerical
at
$
42.55.

b
We
have
assumed
that
there
are
approximately
72
existing
respondents,
i.
e.,
66
of
82
existing
steel
pickling
facilities
and
8
acid
regeneration
plants
are
using
hydrochloric
acid,
and
are
currently
subject
to
the
standard.
We
have
further
assumed
that
one
additional
respondent
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
We
have
further
assumed
that
all
existing
sources
are
in
compliance
with
the
regulation
since
the
compliance
date
of
this
19
rule
has
passed.

c
Estimated
hours
for
performance
test
and
report
by
EPA
Method
26A.

d
The
new
source
will
be
required
to
conduct
an
initial
performance
test
and
we
assume
will
not
have
to
repeat
it.

e
All
existing
sources
(
72)
are
required
to
conduct
an
annual
performance
test
to
either
measure
the
HCl
mass
flows
at
the
control
device
inlet
and
outlet
or
the
concentration
of
HCl
exiting
the
control
device
and
report
the
results
in
the
semiannual
reports.

f
Assumes
10%
of
all
existing
sources
(
or
7.2)
must
write
a
revised
maintenance
plan.

g
The
new
source
will
be
required
to
meet
initial
notifications
requirements.

h
Assumes
one
reconstructed
source
at
one
facility
over
the
3­
yr
period,
for
0.3
occurrences
per
respondent
(
1/
3=
0.3).

i
Assumes
no
respondents
will
request
a
NESHAP
waiver.

j
Assumes
20%
of
respondents
(
or
14.4)
report
excess
emissions
semiannually
and
the
remaining
80
%
(
or
57.04
sources)
report
no
excess
emissions
over
the
3­
year
period.

k
Assumes
5%
of
respondents
(
or
3.6)
will
have
a
startup,
shutdown,
or
malfunction
event
not
managed
according
to
the
plan
that
requires
a
semiannual
report.

l
Assumes
3
hours
per
respondent
per
week.

m
Assumes
an
average
of
3
reports
per
respondent
per
year
(
e.
g.,
notifications,
performance
test
reports
and
immediate
and
periodic
reports).

N/
A
=
Not
Applicable.
20
TABLE
2.
Annual
Burden
and
Cost
to
the
Federal/
State
Government:
NESHAP
for
Steel
Pickling,
HCl
Process
Facilities
and
Hydrochloric
Acid
Regeneration
Plants
(
40
CFR
Part
63,
Subpart
CCC)

Activity
(
A)

EPA
hours
per
occurrence
(
B)
Number
of
occurrences
per
respondent
per
year
(
C)

EPA
hours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,
$
b
Report
Review:
New
Sources
c
Notification
of
applicability
2
1
2
0.3
0.6
0.03
0.06
$
27.97
Notification
of
construction
or
reconstruction
2
1
2
0.3
0.6
0.03
0.06
$
27.97
Notification
of
actual
start
up
2
1
2
0.3
0.6
0.03
0.06
$
27.97
Notification
of
special
compliance
requirements
N/
A
Notification
of
performance
test
2
1
2
0.3
0.6
0.03
0.06
$
27.97
Notification
of
compliance
status
2
1
2
0.3
0.6
0.03
0.06
$
27.97
Review
of
performance
test
report
4
1
4
0.3
0.6
0.03
0.06
$
27.97
Review
of
repeat
test
report
4
1
4
0
0
0
0
$
0.00
Report
Review:
Existing
Sources
d
Review
of
excess
emissions
report
e
4
2
8
14.4
115.2
5.76
11.52
$
5,370.74
Review
of
no
excess
emissions
report
e
2
2
4
57.6
230.4
11.52
23.04
$
10,741.48
Review
of
startup,
shutdown,

malfunction
report
f
2
2
4
3.6
14.40
0.72
1.44
$
671.47
Review
of
waiver
application
g
2
1
0
0
0
0
0
$
0.00
Subtotal
Burden
and
Cost
(
Salary)
363.6
18.18
36.36
$
16,783.69
21
Activity
(
A)

EPA
hours
per
occurrence
(
B)
Number
of
occurrences
per
respondent
per
year
(
C)

EPA
hours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,
$
b
TOTAL
BURDEN
AND
COST
(
rounded)
418
$
16,784
Assumptions:

a
We
have
assumed
that
there
are
approximately
72
existing
respondents,
i.
e.,
66
of
82
existing
steel
pickling
facilities
and
8
acid
regeneration
plants
are
using
hydrochloric
acid,
and
are
currently
subject
to
the
standard.
We
have
further
assumed
that
one
additional
respondent
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
We
have
further
assumed
that
all
existing
sources
are
in
compliance
with
the
regulation
since
the
compliance
date
of
this
rule
has
passed.

b
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:
Managerial
at
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6),
Technical
at
$
41.57
(
GS­
12,
Step
1,

$
25.98
x
1.6),
and
Clerical
at
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"

which
excludes
locality
rates
of
pay.

c
Assumes
one
reconstructed
source
at
one
facility
over
the
3­
yr
period,
for
0.3
occurrences
per
respondent
(
1/
3=
0.3).
The
new
source
will
be
required
to
comply
with
initial
notification
requirements.
We
will
assumed
that
the
source
will
not
have
to
repeat
the
initial
performance
test.

d
All
existing
sources
(
72)
are
required
to
conduct
an
annual
performance
test
to
either
measure
the
HCl
mass
flows
at
the
control
device
inlet
and
outlet
or
the
concentration
of
HCl
exiting
the
control
device
and
report
the
results
in
the
semiannual
reports.

e
Assumes
20%
of
respondents
(
or
14.4)
report
excess
emissions
semiannually
and
the
remaining
80
%
(
or
57.04
sources)
report
no
excess
emissions
over
the
3­

year
period.

f
Assumes
5%
of
respondents
(
or
3.6)
will
have
a
startup,
shutdown,
or
malfunction
event
not
managed
according
to
the
plan
that
requires
a
semiannual
report.

g
No
waiver
application
expected.
