SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Benzene Emissions from Coke By-Product Recovery Plants 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Benzene Emissions from Coke By-Product Recovery Plants (40
CFR part 61, subpart L) (Renewal)

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the regulations published at 40 CFR part 61, subpart L, promulgated
on December 15, 1989, amended on February 12, 1999, and October 17,
2000, apply to benzene emissions from coke by-product recovery plants. 
These regulations apply to existing facilities and new facilities that
are furnace or foundry coke by-product recovery plants that produce
benzene emissions.  New facilities include those that commenced
construction, modification or reconstruction after the date of these
rules.  These regulations were revised on September 19, 1991, to allow
for the use of carbon adsorbers and vapor incinerators as alternative
means of complying with the standards for process vessels, storage
tanks, and tar-intercepting sumps.  The use of carbon adsorbers and
vapors incinerators instead of gas blanketing, the control technology on
which the standards were originally based, was made optional by the 1991
revision.  These regulations were further amended on February 12, 1999
to eliminate certain quarterly reporting obligations; to require, for
each carbon adsorber, a plan to handle benzene and removed carbon in
accordance with the regulations; and to specify reporting of the
monitoring method chosen for each vapor incinerator.  Information under
this ICR is being collected to assure compliance with 40 CFR part 61,
subpart L.

In general, all NESHAP standards require owners or operators of the
affected facilities to submit one-time-only notifications including:
notification of any physical or operational change to an existing
facility which may increase the regulated pollutant emission rate,
notification of the initial performance test, including information
necessary to determine the conditions of the performance test, and
performance test measurements and results.  Owners or operators 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 sources subject to
NESHAP.

Any owner or operator subject to the provisions of this part will
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.

Over the next three years, an average of seventeen sources per year will
be subject to the standard, and it is estimated that no additional
sources will become subject to the regulation in the next three years.  

There are approximately seventeen benzene emissions from coke by-product
recovery plants in the United States, which are owned and operated by
the benzene emissions from coke by-product recovery industry.  None of
the seventeen facilities in the United States are owned by state, local,
tribal or the Federal government.  They are owned and operated by
privately owned for-profit businesses.  You can find the burden to the
“Affected Public” listed below in Table 1: Annual Industry Burden
and Cost - NESHAP for Benzene Emissions from Coke By-Product Recovery
Plants (40 CFR part 61, subpart L).  The Federal government burden does
not include work performed by Federal employees.  The burden refers only
to work performed by contractors, which could be found listed below in
Table 2: Average Annual EPA Burden - for Benzene Emissions from Coke
By-Product Recovery Plants (40 CFR part 61, subpart L).

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

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants (HAP). 
These standards are applicable to new or existing sources of HAP and
shall require the maximum degree of emission reduction.  In addition,
section 114(a) states that the Administrator may require any owner or
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, benzene emissions from furnace or
foundry coke by-product recovery plants, cause or contribute to air
pollution that may reasonably be anticipated to endanger public health
or welfare.  Therefore, the NESHAP was promulgated for this source
category at 40 CFR part 61, subpart L.

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 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 tests, 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 ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
61, subpart L.

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 their 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 (72 FR 10735) on March 9, 2007. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by the EPA Office of Compliance.
 OTIS is the EPA database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts. 
Approximately seventeen respondents will be subject to the standard over
the three-year period covered by this ICR.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed, and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
first Federal Register notice.

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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

 	

These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the Part 70 permit program and the five-year statute of limitations
on which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond the five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

3(f)  Confidentiality

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

3(g)  Sensitive Questions

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
benzene emissions from coke by-product recovery plants.  The United
States Standard Industrial Classification (SIC) codes which correspond
to the North American Industry Classification System (NAICS) codes are
found in the following table:

40 CFR part 61, subpart L	SIC Codes	NAICS Codes

Coke Plants at Integrated Iron and Steel Facilities	3312	331111

Coke Plants Not at Integrated Iron and Steel Facilities	3312	324199



4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5, 40
CFR part 61, subpart V, and 40 CFR part 61, subpart A.  

 

(i)  Data Items

In this ICR, all the data recorded or reported is required by National
Emission Standards for Hazardous Air Pollutants for Benzene Emissions
from Coke By-Product Recovery Plants (40 CFR Part 61, Subpart L).

A source must make the following reports:

Notifications

Notification and application of construction, reconstruction or
modification	61.06, 61.07, and 61.138(i)

Notification of anticipated date of initial startup	61.09(a)(1)

Notification of actual startup	61.09(a)(2)

Notification of performance tests	61.13(f) and 61.14(c)

Notification of physical or operational change which may increase the
emission rate	61.15, and 61.10

Notification of implementation of equipment leakage requirements
61.138(e)

Notification that the requirements of 40 CFR part 61, subpart L and 60
CFR part 61, subpart V have been met	61.138(e)

Notification of intent to elect to comply with the requirements at 40
CFR Section 61.243 at least 90 days before implementation	61.138(h)

Performance test reports	61.13

Excess emissions reports	61.14

Reporting requirements of an owner or operator of any piece of equipment
subject to NESHAP subpart V	61.247

Semiannual general and maintenance inspection reports	61.138(f)

Semiannual reports of excess emission (alternative control options)
61.139(j)(2)



A source must keep the following records:

Recordkeeping 

Maintain records of monitoring data, monitoring system calibration
checks, and the occurrence and duration of periods where the monitoring
system is malfunctioning or inoperative.  Records shall be retained for
at least two years.	61.14(f)

Maintain records of the design of control equipment installed, including
detailed schematics, design specifications, and piping and
instrumentation diagrams, and the dates and descriptions of any changes
in the design specifications.	61.138(a)

Maintain records of semiannual inspections, annual maintenance
inspections and, where applicable quarterly leak detection inspections.
61.138(b), 61.138(f), and 61.135(d)

Maintain records of leak detection and repair logs for at least two
years.	61.138(c) 61.246, and 61.247

Maintain records of the design requirements of closed-vent system and
control devices.	61.138(c), 61.246, and 61.247

Maintain records of applicable valve information.	61.138(c), 61.246, and
61.247

Maintain records of design control device and plan operations and
corrective action, compliance tests, reference values of monitored
parameters, monitoring results and exceedances (alternative control
options).	61.139(i)(1-7)

Maintain records of annual furnace and foundry coke production for
furnace coke by-product recovery plants for at least two years.
61.138(d)

Maintain records of monitoring data, monitoring system calibration
checks, and the occurrence and duration of periods where the monitoring
system is malfunctioning or inoperative.  Records shall be retained for
at least two years.	61.14(f)

Recordkeeping requirements of an owner or operator of any piece of
equipment subject to NESHAP subpart V.	61.246



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a plant site.

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.

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate Continuous Monitoring Systems
(CMS) for opacity, or for pressure drop and liquid supply pressure for
closed systems, barrier fluid degassing systems, closed-vent systems to
a control device, closed-purge systems to a control device, seal
systems, and by monitoring equipments to repair.

Perform initial performance test, Reference Method 21 test, and repeat
performance tests if necessary.

Write the notification 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.



	Currently, sources are using monitoring equipment that provides
parameter data in an automated way e.g., continuous parameter monitoring
system.  Although personnel at the source still need to evaluate the
data, this type of monitoring equipment has significantly reduced the
burden associated with monitoring and recordkeeping.

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,
excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in 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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions under which
compliance was achieved.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.

Information contained in the reports is entered into OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is the
EPA database for the collection, maintenance, and retrieval of
compliance data for approximately 125,000 industrial and
government-owned facilities.  EPA uses OTIS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA
regional offices, and EPA headquarters.  EPA delegated Authorities can
edit, store, retrieve and analyze the data.

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

5(c)  Small Entity Flexibility

The majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these to be the minimum
requirements needed to ensure compliance and, therefore, cannot reduce
them further for small entities.  To the extent that larger businesses
can use economies of scale to reduce their burden, the overall burden
will be reduced.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Benzene Emissions from Coke By-Product Recovery Plants (40 CFR part 61,
subpart L).

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.  Wherever 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.

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 3,137
(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 

Managerial 	$93.09     ($44.33 + 110%)

Technical	$64.47     ($30.70 + 110%)

Clerical	$39.65     ($18.88 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2003, “Table 2. Private industry, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

	

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	The only costs to the regulated industry resulting from information
collection activities required by the subject standard are labor costs. 
There are no capital/startup or operation and maintenance costs.

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

The only type of industry costs associated with the information
collection activity in the regulations is labor costs.  There are no
capital/startup or operation and maintenance costs.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $5,516.  

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

Managerial	$54.02   (GS-13, Step 5, $33.76 + 60%)

Technical	$40.08   (GS-12, Step 1, $25.05 + 60%)

Clerical	$21.70   (GS-6, Step 3, $13.56 + 60%)

These rates are from the Office of Personnel Management (OPM) 2004
General Schedule which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear in Table 2: Average Annual EPA Burden, NESHAP for Benzene
Emissions from Coke By-Products Recovery Plants (40 CFR part 61, subpart
L), below.

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

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

Number of Respondents

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	17	0	0	17

2	0	17	0	0	17

3	0	17	0	0	17

Average	0	17	0	0	17

1 It is estimated that no new sources will become subject to this
standard over the next three years.

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 17.

The total number of annual responses per year is calculated using the
following table:

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses

E=(BxC)+D

Semiannual emissions report	17	2	n/a	34



	Total (rounded)	34



The number of Total Annual Responses is 34

The total annual labor costs are $199,375.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost -
NESHAP for Benzene Emissions from Coke By-Products Recovery Plants (40
CFR part 61, subpart L), below.

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 labor costs are $199,375.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost:
NESHAP for Benzene Emissions from Coke By-Products Recovery Plants (40
CFR part 61, subpart L), below.  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 92 hours per response.

There are no annual capital/startup and O&M costs to the regulated
entities.  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 157 labor hours at a cost of $5,516.  See Table 2.
Annual Agency Burden and Cost: NESHAP for Benzene Emissions from Coke
By-Products Recovery Plants (40 CFR part 61, subpart L), below.

6(f)  Reasons for Change in Burden

The regulations have not changed over the past three years and are not
anticipated to change over the next three years.  There is only one
small change in the labor hours in this ICR compared to the previous
ICR.  The change was caused by different methods of rounding numbers. 
The previous ICR shows (3,138) as the labor hours, however, this ICR
uses the exact hours of (3,137).  The growth rate for the industry is
very low, negative or non-existent, so there is no significant change in
the overall burden.

Since there are no changes in the regulatory requirements and there is
no significant industry growth, the labor hours and cost figures in the
previous ICR are used in this ICR, and there is no change in burden to
industry.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 92 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 burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2007-0050.  An electronic version of the public docket is
available at http://www.regulations.gov which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the content of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search” than key in the
docket ID number identified in this document.  The documents are also
available for public viewing at the Enforcement and Compliance Docket
and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 1301 Constitution Avenue, N.W., 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 Docket is (202)
566-1752.  Also, you can send comments to the Office of Information and
Regulatory Affairs, Office of Management and Budget, 725 17th Street,
N.W., Washington, DC 20503, Attention: Desk Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OECA-2007-0050 and OMB Control
Number 2060-0185 in any correspondence.

Part B of the Supporting Statement

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

Table 1:  Annual Respondent Burden and Cost – NESHAP for Benzene
Emissions from Coke By-Product Recovery Plants (40 CFR Part 61, Subpart
L) 

Burden item	

(A)

Person

hours per occurrence	

(B)

No. of occurrences per respondent per year	

(C)

Person hours per respondent per year

(C=AxB)	

(D)

Respondents per year  a	

(E)

Technical person- hours per year

(E=CxD)	

(F)

Management person hours per year

(Ex0.05)	

(G)

Clerical person hours per year

(Ex0.1)

	

(H)

Cost, $  b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting requirements









     A.  Read instructions 	See 3C







	     B.  Required activities









           Initial performance test	32	1	32	0	0	0	0	$0

           Repeat performance test	32	0.2	6.4	0	0	0	0	$0

           Annual maintenance inspection c	0.5	1	0.5	17	9	0.5	0.9	$663

     C.  Create information	See 3B







	     D.  Gather existing information	See 3E







	     E.  Write Report









           Notification of construction/reconstruction	2	1	2	0	0	0	0	$0

           Notification of anticipated/actual startup	2	1	2	0	0	0	0	$0

           Notification of initial performance test	2	1	2	0	0	0	0	$0

           Notification of physical/operational chances	8	1	8	0	0	0	0	$0

           Semiannual emissions report d	12	2	24	17	408	20	41	$29,792

4.  Recordkeeping requirements









     A.  Read instructions 	See 3A







	     B.  Plan activities









           Maintenance Plan	See 3A







	     C.  Implement Activities 









           File and maintain records e	33	4	132	17	2,244	112	224
$163,979

           Performance evaluation for Method 21 f	2	2	4	17	68	3	7	$4,941

     D.  Develop record system	N/A







	     E.  Time to enter information	N/A







	     F.  Time to train personnel	N/A







	     G.  Time for audits	N/A







	Subtotals Labor Burden and cost  



	2,729	136	273	$199,375

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	3,137	$199,375



Assumptions:

a  We have assumed that the average number of major sources that will be
subject to the rule will be the 17 existing sources.  There will be no
additional new sources per year that will become subject to the rule
over the three-year period of this ICR.

b  This ICR uses the following labor rates: $93.09 per hour for
Executive, Administrative, and Managerial labor; $64.47 per hour for
Technical labor, and $39.65 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, June 2003, (Table 10. Private industry, by occupational and
industry group.(  The rates are from column 1, (Total compensation.( 
The rates have been increased by 110 percent to account for the benefit
packages available to those employed by private industry.

c  We have assumed that each respondent will take 0.5 hours to complete
the annual maintenance inspection.

d  We have assumed that each respondent will take twelve hours at two
times per year to write semiannual emissions report.

e  We have assumed that each respondent will take thirty-three hours at
four times per year to file and maintain records.

f  We have assumed that each respondent will take two hours at two times
per year to complete the performance evaluation for Method 21.

Table 2:  Average Annual EPA Burden - NESHAP for Benzene Emissions from
Coke By-Product Recovery Plants (40 CFR Part 61, Subpart L) 

Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

 per year	

(C)

EPA person

hours per

plant per year

(C=AxB)	

(D)

Plants per year  a	

(E)

Technical

person-

hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $ b

Initial performance test









      New plant	40	1	40	0	0	0	0	$0

Report review









      Notification of construction	2	1	2	0	0	0	0	$0

      Notification of anticipated startup	2	1	2	0	0	0	0	$0

      Notification of actual startup	2	1	2	0	0	0	0	$0

      Notification of performance test	2	1	2	0	0	0	0	$0

      Report of performance test	8	1	8	0	0	0	0	$0

      Review semiannual excess emissions and

       exemption reports	4	2	8	17	136	7	14	$5,516

Subtotals Labor Burden and cost



	136	7	14	$5,516

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	157	$5,516



 	Assumptions:

a  We have assumed that the average number of major sources that will be
subject to the rule will be the 17 existing sources.  There will be no
additional new sources per year that will become subject to the rule
over the three-year period of this ICR.

   	b  This cost is based on the following labor rates which incorporate
a 1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial

 	 rate of $54.02 (GS-13, Step 5, $33.76 x 1.6), Technical rate of
$40.08 (GS-12, Step 1, $25.05 x 1.6), and Clerical rate of $21.70 (GS-6,
Step 3, $13.56 x 1.6).  These

  	rates are from the Office of Personnel Management (OPM) (2003 General
Schedule( which excludes locality rates of pay.

   	c  We have assumed that each respondent will take four hours two
time per year to review the excess emissions and exception reports.

  	

   

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