	SF-83 SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Coke Oven Pushing Quenching and Battery Stacks

(40 CFR part 63, subpart CCCCC)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Coke Oven Pushing Quenching and Battery Stacks (40 CFR part
63, subpart CCCCC).

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Integrated Iron and Steel Manufacturing were proposed on July 3,
2001 (66 FR 35325) and, promulgated on April 14, 2003 (68FR18007).  The
respondents are owners or operators of coke plants that are major
sources of hazardous air pollutant (HAP) emissions.  The national
emission standard for hazardous air pollutants (NESHAP) applies to
emissions from pushing, soaking, quenching, and battery stacks on new
and existing coke oven batteries.

The final rule includes emission limitations, or work practice standards
for each type of affected source.  Emission limitations are established
for control devices applied to pushing emissions.  Work practice
standards are established for fugitive pushing emissions, soaking, and
quenching.  Battery stacks are subject to a daily average opacity limit.
 

Owners, or operators of by-product coke oven batteries must prepare and
operate by written operation and maintenance plans and work practice
plans for soaking.  Owners, or operators of by-product coke oven
batteries with horizontal flues are required to prepare and operate by a
written plan designed to prevent green pushes based on a study of
minimum flue temperatures.  Consistent with the NESHAP General
Provisions, all respondents also are required to prepare and operate by
a startup, shutdown, and malfunction plan.  

Owners, or operators must conduct an initial performance test to
demonstrate compliance with each emission and opacity limit and make
written compliance certifications for the work practice standards and
operation and maintenance requirements.  Subsequent performance tests
for each control device applied to pushing emissions are required twice
during each term of their title V operating permit.  Bag leak detection
systems, or continuous parameter monitoring systems (CPMS) also are
required, depending on the type of control device.  A continuous opacity
monitoring system (COMS) is required to demonstrate continuous
compliance with the opacity limit for battery stacks.  Installation,
inspection, and maintenance requirements are established for different
types of monitoring systems.      

Respondents must submit one-time notifications as required by the
NESHAP General Provisions, quarterly reports of deviations for battery
stacks, and semiannual reports of deviations from the rule requirements
for all other affected sources.  An immediate report is required if
actions taken in response to the startup, shutdown, or malfunction were
not consistent with the written startup, shutdown, and malfunction plan.
 Respondents must maintain records of specific information to ensure
that the rule requirements are being achieved and maintained.  

	There is an average of 19 respondents (i.e., coke plants) which are
operating 58 by-product batteries and 10 non-recovery batteries. We have
assumed that there will be no new respondents subject to this
regulation.  We have assumed that there is an average of 2.8 battery
stacks per plant for the purpose of calculating the burden, however, the
average accounts for those few plants that have a pair of batteries
served by one stack.  

In the development of this Information Collection Request (ICR), we
reviewed the Office of Management and Budget (OMB) “Terms of
Clearance” (TOC) section on the active ICR. There are no terms of
clearance.

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The Clean Air Act (CAA) provides authority to the Agency to establish
standards to control air pollution and to ensure compliance with
promulgated regulations through adequate recordkeeping and reporting by
the affected industries (i.e., respondents).  The regulations include
the New Source Performance Standards (NSPS) under section 111 of the
Act, the National Emission Standards for Hazardous Air Pollutants (
NESHAP), which includes the original NESHAP standards and the more
recent Maximum Achievable Control Technology (MACT), or NESHAP-MACT
standards under section 112 of the Act, and emission guidelines for the
designated types incinerators under section 129 of the CAA.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards are used
by regulatory agencies, the public and the regulated community for a
variety of reasons including the determination of the respondent’s
compliance status, analytical studies to demonstrate compliance trends,
and evaluations regarding the efficacy of the promulgated regulations.

The required recordkeeping and reporting also are used to: 1) certify
compliance with the regulations; 2) determine the respondent’s
compliance with the designated emission limitations; 

3) notify regulatory agencies when a standard is violated; 4) evaluate
continuous compliance through the use of emission or operational
parameter monitors; and 5) ensure that plant personnel are following the
required procedures and are periodically trained, as indicated.

3.  Nonduplication, Consultations, and Other Collection Criteria

3(a)  Nonduplication

The standards do not require duplication in the collection and reporting
of information.  If the subject standards have not been delegated, the
information is sent directly to the appropriate Environmental Protection
Agency (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.

 

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

It is our policy to carefully review any comments received since the
last ICR renewal including those submitted in response to the first
Federal Register notice and to respond appropriately.  In this case, no
comments were received.  The Agency’s internal industry experts have
been consulted.  The Agency’s internal data sources and any
projections of industry growth over the next three years also 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 Air Facility Subsystem (AFS), which is operated and
maintained by EPA's Office of Compliance.  AFS is EPA’s database for
the collection, maintenance, and retrieval of all compliance data. 
Approximately 19 respondents (i.e., 19 coke plants with 56 coke oven
batteries) are currently subject to the regulation and our consultations
with Agency industry experts regarding the growth rate for the industry
indicated that an additional one respondent per year will become subject
to the regulation over the next three years.

It should be noted that the respondents, the 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 previously has been reviewed to determine the
minimum information needed for compliance purposes.

  

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

Neither the reporting, nor the recordkeeping requirements violate the
regulations established by Office of Management and Budget (OMB) at 5
CFR Part 1320, Section 1320.5.  However, most NESHAP standards and a few
NSPS standards require records to be kept more than three years.  In
general, these standards require the respondents to maintain all
records, including reports and notifications, for five years.  The
five-year record retention requirement is consistent with the permit
program at 40 CFR part 70, 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 the respondent for purposes of determining the
appropriate level of enforcement action.  Historically, EPA notes that
the most flagrant violations have extended beyond a five-year period. If
records are retained for less than five years, EPA would be deterred
from pursuing the most flagrant violations due to the destruction of
records documenting noncompliance.

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

The recordkeeping and reporting requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The Standard Industrial Classification (SIC) code(s) and corresponding
North American Industry Classification System (NAICS) for the
respondents are listed below. Approximately 19 respondents (i.e., 19
coke plants with 56 coke oven batteries) are affected.



Category	SIC 

code	NAICS code	Examples of regulated entities

Coke plants	3312	331111	Coke plants integrated with steel mills

Coke Plants	3312	324199	Coke plants not at integrated iron and steel
mills



This table is not meant to be exhaustive, but rather provides a guide
for readers regarding the entities likely to be regulated by this
standard.  To determine whether the standard applies to a particular
entity, review the applicability provisions in the standard.

4(b)  Information Requested

(i)  Data Items

Notification Reports

Initial notification requirements	63.9(b)(1)

Notification of compliance status when a source becomes subject to the
standard	63.9(h), 63.7340(a)

Notification that source is subject to special compliance requirements,
if applicable	63.9(d)

Notification of performance test   SEQ CHAPTER \h \r 1 	63.7(b),
63.9(e), 63.5755(a)

Rescheduled of performance test	63.7(b)(2)

Demonstration of continuous monitoring system	63.9(g), 63.7340(a)

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)

Performance test results	63.10(d)(2),

63.5755

Startup, shutdown and malfunction plan	63.6(e)(3), 63.7310©

Operation and maintenance plan for capture systems, control devices
applied to pushing emissions, and by-product coke oven batteries
63.7300(b-c)

Immediate startup, shutdown and malfunction reports	63.6(e)(3),
63.10(d)(5), 63.7341(d)

Plan for soaking emissions	63.7294

Plan to prevent green pushes from by-product coke oven batteries with
horizontal flues	

63.7292

Progress reports for compliance extension (if applicable)	63.6(i)  SEQ
CHAPTER \h \r 1 

Quarterly and semiannual compliance reports 	63.7341(b-c)



	A source must keep the following records:

Recordkeeping

Startup, shutdown and malfunction plan	63.6(e)(3), 63.7342(a)(2)

All reports and notifications	63.10(b)(1), 63.7342(a)(1)

Records of startup, shutdown, and malfunction of process equipment
63.10(b)(2)(i), (iv), (v), 63.7342(a)(2)

Records of malfunctions of air pollution control equipment
63.10(b)(2)(ii)

Any applicability determination that demonstrates why owner or operator
believes source is unaffected	63.10(b)(3)

Records of maintenance of air pollution control equipment
63.10(b)(2)(iii)

Records of performance tests, performance evaluations, and opacity and
visible emissions observations	63.10(b)(2)(viii),  63.7342(a)(3)

Five-year retention of records	63.10(b)(1),   SEQ CHAPTER \h \r 1 

63.7342(d)



	Electronic Reporting

Some respondents use monitoring equipment that automatically records
parameter data.  Although personnel at the affected facility must
evaluate the data, 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.

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.



Regulatory agencies, to the extent possible, are relying more on
automated techniques such as electronic submissions of reports, and are
improving their tracking systems and database systems to enhance the use
of these techniques.  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.

5.  The Information Collected: Agency Activities, Collection
Methodology, and Information Management

5(a)  Agency Activities 

EPA conducts one or more of 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 Air Facility System (AFS).



5(b)  Collection Methodology and Management

The required data and reports can be evaluated on-site by conducting a
partial compliance evaluation, full compliance evaluation or inspection,
or through an off-site review of compliance monitoring records and
reports.  Evaluation reports and inspection results are maintained by
the Agency, or delegated authority.

The results of these evaluations are 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 delegated
authorities can retrieve and analyze the data.

5(c)  Small Entity Flexibility

A small entity for this industry is defined as a firm having no more
than 1,000 employees. Three of the existing coke plants are small
entities.  None of the coke plants owned by small businesses is at risk
of closure as a result of the rule.  The rule provides a maximum degree
of operational flexibility, and the ICR requirements are the minimum
necessary to demonstrate compliance.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1, attached.

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. 
The individual burdens are expressed under standardized headings
believed to be consistent with the concept of burden under the Paperwork
Reduction Act.  Where appropriate, the specific tasks and major
assumptions have been identified when calculating the burden.  Responses
to this information collection are mandatory.

6(a)  Estimating Respondent Burden

The respondent burden is shown in Table 1.  The labor hours in Table 1
are based on Agency studies and background documents from the
development of the regulation, Agency knowledge and experience with the
standard, 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	$100.99 ($48.09 + 110%)   

Technical	$87.97   ($41.89 + 110%)

Clerical	$43.81   ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December, 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 percent
to account for the benefit packages available to those employed by
private industry.

	

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

The annual burden for respondent activities includes labor costs,
capital/start up costs and operating and maintenance (O&M) costs.   The
capital/startup costs are one-time costs when a facility becomes subject
to the regulation.  We have assumed that existing respondents have
already purchased leak detectors and continuous opacity monitors, as
required by the rule.  The capital cost for bag leak detection systems
is $9,000 each and for COMs is $37,000 each, based on the rule economic
impact analysis.  However, there are no capital costs associated with
this rule since we have assumed that there will be no new sources
becoming subject to this rule.  The annual operation and maintenance
cost for this ICR is $160,000 per year.  This is based on the ongoing
costs to maintain 18 bag leak detectors at a cost of $ 500/year each and
20 continuous opacity monitors at a cost of $ 8,000/year each.

(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/

Startup Cost for One Respondent	

(C)

Number of New Respondents 	

(D)

Total Capital/ Startup 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)

Leak detectors	$9,000	0	$0.00	$500	19	$9,500.00



Continuous Opacity Monitors	

$37,000	

0	

$0.00	

$8,421	

19 	

$160,000.00



Total 

	

$0.00

	

$169,500.00

*   Based on the assumption of one bag leak detection system per
respondent (i.e., 18 systems) and 1.05 COMs per respondent (i.e., 20
COMs) based on 19 respondents.

6(c)  Estimating Agency Burden and Costs

The only costs to the Agency are those 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 and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
$19,767, which is shown in 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 from the Office of Personnel Management (OPM) “2005
General Schedule”, which excludes locality rates of pay.

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

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	

19	

0	

0	

19



2	

0	

19	

0	

0	

19



3	

0	

19	

0	

0	

19



Average	

0	

19	

0	

0	

19

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.  

To avoid double-counting respondents column D is subtracted.  The
average Number of Respondents over the three-year period of this ICR is
shown in column D.  This number appears on the OMB 83-I form in block
13(a), Number of respondents. 

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



Notification of compliance status	

0	

1	

0	

0



Notification/application  of  construction	

0	

1

	

0	

0



Notification of actual startup 	

0	

1	

0	

0



Notification of performance test and test plan	

0	

1	

0	

0



Report of performance test results 	

6.4	

1	

0	

6.4



Report of semiannual compliance reports   	

19	

2	

0	

38

Report of quarterly compliance reports	

17	

4	

0	

68



Report of startup, shutdown, malfunction 	

1	

1	

0	

1



Total	

	

	

	

113.4



The number of Total Annual Responses, 113 (rounded), is shown in column
E.  This number is shown on the OMB 83-I form in block 13(b), Total
annual responses.

The Total Hours Requested, 25,208 (rounded), is shown on the OMB 83-I
form in block 13(c).  The total annual labor cost may be found in Table
1.  Annual Respondent Burden and Cost:  NESHAP for Coke Oven Pushing
Quenching and Battery Stacks (40 CFR part 63, subpart CCCCC).

The average annual Agency burden and cost over next three years is shown
in Table 2.  Annual Burden and Cost for The Federal Government: NESHAP
for Coke Oven Pushing Quenching and Battery Stacks (40 CFR part 63,
subpart CCCCC).

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.  

(i) Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The annual labor costs are not shown on the OMB 83-I form.  Details
regarding these estimates may be found in Table 1.  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 223 hours per response.  

The total annual capital/startup and O&M costs to the regulated entity
are 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) Cost.

(ii) The Agency Tally

The average annual Agency burden hours and cost over next three years
are shown in Table 2.

6(f)  Reasons for Change in Burden

The increase from 2,209 hours to 25,208 hours in the annual labor burden
to industry from the most recently approved ICR is due to adjustments. 
The increase in burden from the most recently approved ICR is due the
assumption that all existing sources are in full compliance with the
rule on-going monitoring, record keeping and reporting requirements
since the compliance date has passed.  The active ICR burden calculation
was based on sources only complying with the initial rule requirements.

The increase from $ 83,000 to $ 169,500 in the total annualized capital
and operations and maintenance (O&M) costs is due to the assumption that
respondents are in full compliance with the rule on-going requirements,
as mentioned above.  Even when there are no capital and startup costs
for this renewal of the ICR, the costs for operation and maintenance of
bag leak detectors and continuous opacity monitors increased
significantly since we are accounting such costs for all three years of
this ICR. 

	The Federal government burden increase from 111 to 179 hours is due to
the increased number of periodic reports required to be reviewed since
respondents will be in full compliance with rule requirements.  The
costs associated with the review of reports offset the cost associated
with inspections (i.e., labor and travel costs associated with observing
performance tests) which we deleted since these 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 223 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, disclose, or provide information to, or
for a Federal agency.  This includes the time needed to review
instructions; to 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; to adjust the existing ways to comply with any
previously applicable instructions and requirements; to train personnel
to be able to respond to a collection of information; to search data
sources; to complete and review the collection of information; and to
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-2005- 0050, 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,
N.W., Washington, D.C.  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.  An electronic version of
the public docket is available online at   HYPERLINK
"http://www.regulations.gov"  http://www.regulations.gov .  Use this web
site to submit or view public comments, to 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 “docket search,” then key in the Docket ID Number identified
above.  You can also send comments to the Office of Information and
Regulatory Affairs, Office of Management and Budget, 725 17th Street,
N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OECA-2005-0050 and OMB Control
Number 2060-0521 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 Coke Oven
Pushing Quenching and Battery Stacks

(40 CFR part 63, subpart CCCCC)

	Burden item	

(A)

Person-

hours per

occurrence	

(B)   

No. of

occurrences

per respondent

	

(C)

Person-

hours per

respondent

(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. Acquisition, Installation, and

   Utilization of Technology and

   Systems	

40	

1	

40	

0.0	

0.0	

0.0	

0.0	

$0.00



4. Reporting Requirements	

	

	

	

	

	

	

	





A. Read instructions	

2	

1	

2	

0.0	

0.0	

0.0	

0.0	

$0.00



B. Required activities  c, d	

	

	

	

	

	

	

	





   Method 5 performance test  e	

40	

1.5c	

60	

6.4	

384.0	

19.2	

38.4	

$37,401.79



  Startup, shutdown, malfunction

   Plan	

40	

1	

40	

0.0	

0.0	

0.0	

0.0	

$0.00



Operation and maintenance plans for  by-product coke oven batteries and
capture systems and control devices applied to pushing emissions	

40	

1	

40	

0.0	

0.0	

0.0	

0.0	

$0.00



Work practice plan for batteries with horizontal flues (one plant)	

40	

1	

40	

1	

40.0	

2.0	

4.0	

$3,896.02



Method 9 daily observations for   fugitive pushing emissions  f  	

2.8	

365	

1,022	

17	

17,374	

868.7	

1,737.0	

$1,692,218.76



Weekly sampling for total dissolved solids (TSD)  g	

2.3	

52	

119.6	

19	

2,272.4	

113.6	

227.2	

$221,329.12



Monthly inspections and maintenance of affected sources, control
devices, and continuous parameter monitoring systems e	

2	

12	

24	

19	

456.0	

22.8	

45.6	

$44,414.63



C. Create information	

See 4B	

	

	

	

	

	

	





D. Gather existing information	

See 4B	

	

	

	

	

	

	





E. Write report	

	

	

	

	

	

	

	





   Notification of applicability	

2	

1	

2	

0.0	

0.0	

0.0	

0.0	

$0.00



   Notification of constr./reconstr.	

2	

1	

2	

0.0	

0.0	

0.0	

0.0	

$0.00



   Notification of anticipated              startup	

2	

1	

2	

0.0	

0.0	

0.0	

0.0	

$0.00



   Notification of actual startup	

2	

1	

2	

0.0	

0.0	

0.0	

0.0	

$0.00



   Notification of special compliance

   requirements	

2	

1	

2	

0.0	

0.0	

0.0	

0.0	

$0.00



   Compliance extension request	

2	

1	

2	

0.0	

0.0	

0.0	

0.0	

$0.00



   Notification of performance test	

2	

1.5c	

3	

0.0	

0.0	

0.0	

0.0	

$0.00



   Site-specific test plan	

40	

1	

40	

0.0	

0.0	

0.0	

0.0	

$0.00



   Notification of compliance status	

8	

1	

8	

0.0	

0.0	

0.0	

0.0	

$0.00



   NESHAP waiver application	

N/A	

	

	

	

	

	





   Report of performance test  h	

See 4B	

	

	

	

	

	





  Semiannual compliance reports  h	

40	

2	

80	

2	

160.0	

8.0	

16.0	

$15,584.08



  Quarterly compliance reports for    battery stacks  f	

12	

4	

48	

17	

816.0	

40.8	

81.6	

$79,478.81



 Emergency startup, shutdown, or 

 malfunction reports   i	

4	

1	

4	

1	

4	

0.2	

0.4	

$389.60



5.  Recordkeeping Requirements	

	

	

	

	

	

	

	





A.  Read instructions	

See 4A	

	

	

	

	

	





B.  Plan activities	

3	

1	

3	

0.0	

0.0	

0.0	

0.0	

$0.00



C.  Implement activities	

12	

1	

12	

0.0	

0.0	

0.0	

0.0	

$0.00



D.  Develop record system	

3	

1	

3	

0.0	

0.0	

0.0	

0.0	

$0.00



E.  Time to enter information	

1	

52	

52	

19	

988.0	

49.4	

98,8	

$96,231.69



F.  Time to train personnel	

3	

1	

3	

0.0	

0.0	

0.0	

0.0	

$0.00



G.  Time to adjust existing ways to

    comply with previously

    applicable requirements	

3	

1	

3	

0.0	

0.0	

0.0	

0.0	

$0.00



H.  Time to transmit or disclose

information   j	

0.25	

2	

0.5	19	9.5	0.5	1.0	$930.02



I.  Time for audits	

N/A	

	

	

	

	

	





TOTAL LABOR BURDEN AND COST	

	

	

	

	

21,919.9	

1,1096.0	

2,192.0	

$2,191,874.52



TOTAL LABOR BURDEN AND COST  (Rounded)



	

25,208	

$2,191,875



Assumptions:

a   There is an average of 19 respondents (i.e., coke plants operating
58 by-product batteries and 10 non-recovery batteries).  We have assumed
that there will be no new sources subject to this regulation.  

b  This ICR uses the following labor rates: $100.99 per hour for
Executive, Administrative, and Managerial labor; $87.97 per hour for
Technical labor, and $43.81 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December, 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.

c    SEQ CHAPTER \h \r 1 We have assumed that existing respondents have
already comply with initial rule requirements and are in full compliance
with periodic requirements including quarterly and semiannual reports. 
New respondents would have to comply with the initial rule requirements
including notifications and performance tests for add-on control
devices. 

d   Monitoring and recordkeeping of operations for respondents include:
monthly inspection of capture and control systems; daily Method 9
observations; weekly sampling for dissolved solids for quenching
operations; work practices for batteries with horizontal flues (one
plant); and Method 5 testing for particulate matter.

e  The rule requires that every 2.5 years (or 0.4 times per year over
the 3 years of the ICR), each control device applied to pushing
emissions must be sampled by Method 5 for particulate matter.  We have
determined that there is an average of 1.5 emission points (24 control
devices for 16 respondents =  24/16 = 1.5 per respondent) that need to
be tested.  There is an average of 6.4 respondents per year (16*0.4)
submitting Method 5 performance test reports.  

f   Daily Method 9 observations of 4 pushes per battery stacks one hour
per day per battery.  We have assumed that 38 of the 53 battery stacks
at 17 plants will have burden that can be attributed to the rule since
the other plants were doing this type of monitoring.   before the rule. 
There is an average of 2.8 battery stacks per plant required to be
tested for Method 9 for the burden calculation although we know that a
few plants have a pair of batteries served by one stack.  

g  The measuring of the total dissolved solids (TDS) in the make-up
water used for quenching is a requirement. Since there are about 43
quenching towers (average over the 19 respondents is about 2.3 quenching
towers per facility).

h   The rules requires the submittal of quarterly compliance reports for
all battery stacks.  If no deviation occurred and no continuous
monitoring systems were out of control, only a summary report is
required.  There is an average of 6.4 respondents per year (16*0.4)
submitting Method 5 performance test reports.  For other affected
sources, semiannual reports are required for any deviation from an
emission limitation (including an operating limit), work practice
standard, or O&M requirement.

i   It assumes that one respondent per year will have a startup,
shutdown and malfunction (SSM) occurrence that is not managed according
to the SSM plan.

j   It assumes 15 minutes to transmit recorded information	Table 2. 
Annual Burden and Cost for The Federal Government:  NESHAP for Coke Oven
Pushing Quenching and Battery Stacks (40 CFR part 63, subpart CCCCC)

	Activity	

(A)

Hours per

occurrence	

(B)

Hours per

plant per year	

(C)

Plants

per year	

(D)

Technical

person-hours

per year

(D=BxC)	

(E)

Management

person-hours

per year

(Dx0.05)	

(F)

Clerical

person-hours

per year

(Dx0.1)	

(G)

Cost, $a



Initial performance test	

40	

40	

0	

0	

0	

0	

$0.00



Repeat performance test-Retesting preparation	

2	

2	

0	

0	

0	

0	

$0.00



Repeat performance- Retesting	

40	

40	

0	

0	

0	

0	

$0.00



Report Review	

	

	

	

	

	

	





   Notification of construction/reconstruction	

N/A	

	

	

	

	

	





   Notification of anticipated startup	

N/A	

	

	

	

	

	





   Notification of actual startup	

N/A	

	

	

	

	

	





   Notification of special compliance requirements 	

N/A	

	

	

	

	

	





   Notification of initial performance test	

2	

2	

0	

0	

0	

0	

$0.00



   Notification of compliance status d	

2	

2	

0	

0	

0	

0	

$0.00



   Review of repeat Method 5 performance test 

   Report 	

8	

8	

6.4	51.2	2.56	5.12	$2,387.00



   Review of semi-annual compliance  report d	

8	

2	

19	32	1.6	3.2	$1,491.87



   Review of NESHAP waiver application	

2	

2	

0	

0	

0	

0	

$0.00



   Review of quarterly  compliance  report for battery    stacks  f	

4	

4	

17	68	3.4	6.8	$3,170.23

   Review of emergency startup, shutdown, and            malfunction
report g	

4	

1	

1	

4.0	

0.2	

0.4	

$186.48



TOTAL BURDEN AND COST (SALARY)	

	

	

	

155.2	

7.8	

15.5	

$7,235.58



TOTAL ANNUAL COST





179	

$7,236



Assumptions:

b   This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) (2005 General Schedule( which
excludes locality rates of pay.  

c   We have assumed that existing sources have comply with the initial
rule requirements.  New respondents are required to conduct performance
test for add-on control equipments, submit initial notifications and
prepare startup, shutdown and malfunction (SSM) plans.  

d   Every 2.5 years (or about 0.4 times per year, if average over the
three year period of ICR), respondents must sample each emission point
using Method 5 for particulate matter, and submit a report of results. 

 e  Sources are required to submit semiannual compliance reports and
startup, shutdown and malfunction (SSM) reports if there is an
occurrence that is not managed according to the SSM plan.  

f  The rules requires the submittal of quarterly compliance reports for
battery stacks.  There is an average of 6.4 respondents per year
(16*0.4) submitting Method 5 performance test reports.  

g  It assumes that one respondent will have a startup, shutdown and
malfunction (SSM) occurrence that is not managed according to the SSM
plan.

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