**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR**  **Part 63, Subpart CCCCC**  **) (Renewal)**  **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 ) (Renewal), EPA I CR Number 1995 .05 , OMB Control Number 2060

- 0521. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous A ir Pollutants (NESHAP) for NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks **(** 40 CFR part 63, subpart CCCCC ) were proposed on July

3, 2001 (66 FR 35325) , promulgated on April 14, 2003 (68 FR 18007) , and amended on August 2, 2005 (70 FR 44285). These regulations appl y to owners or operators of both existing and new coke plants that are major sources of hazardous air pollutant (HAP) emissions

. The NESHAP applies to emissions from pushing, soaking, quenching, and battery stacks on both new and e xisting coke oven batteries. New facilities include those that commenced construction, modification or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart CCCCC

. In general, al l NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of an y startup, shutdown, or malfunctio n in the operation of an affected facility, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESH AP

. 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 th e delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of 2.8 affected battery

stacks at each plant site and that each plant site has only one respondent (i.e. the owner/operator of the plant site). Over the next three ye ars, an average of 19 respondents per ye ar ( operating 58 by

- product batteries and 10 non

- recovery batteries ) will be subject to the standard , and no additional respondent per year will become subject to the standard. Th e active (previous) IC R had the following Terms of Clearance (TOC):2 This request is approved for three ye ars. Prior to resubmission of this information collection request for renewal, the agency should reassess estimates of burden taking into account rec ent experience with the program. EPA has addressed each item of concern in the TOC by consulting with industry

trade associations, and other interested parties. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal) . The burden to the “Federal Government” is attributed entirely to work performed by either F ederal employ ees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal).
**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 re quirement 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 o r 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 emission s is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, hazardous air pollutant (HAP) emissions from coke plants either cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP w as promulgated for this source category at 40 CFR part 63, subpart CCCCC

.3

**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 test a record of the operating parameters under which compliance was achieved may b e 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 properl y installed and operated, leaks are being detected and repaired and the standard is being met. The performance test may also be observed. The required quarterl y and semiannual reports are used to determine periods of excess emissions, identify

problems at the facility , verify operation/maintenance procedures , and for compliance determinations.
**3. Non**
**- duplication, Consultations, and Other Collecti**  **on Criteria** The requested recordkeeping and reporting are required under 40 CFR p art 63, s ubpart CCCCC

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y 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, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was p ublished in the Federal Register (76 FR 26900) on May 9, 2011. No comments were received on the burden published in the Federal Register

.4

**3(c) Consultations** The Agency

has consulted i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. 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 Sy stem (OTIS ) which is operated and maintained b y EPA's Office of Compliance. OTI S is EPA’s 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. 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 infor mation needed for compliance purposes. In developing this I CR, w e contacted : 1) the American Coke and Coal Chemicals Institute , at (202) 452

- 7198 ; and 2) the Association for Iron & Steel Technology , at (724) 814

- 3062

. 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 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 ye ar records retention requirement is consistent the Part 70 permit program and the five year statute of li mitations on which the permit program is based. The retention of records for five ye ars allows EPA to establish the compliance history of a source, an y 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 five ye ars. In addition, EPA would be prevented from pursuing the violators due to either the destruction or nonexistence of essential records.5

**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**
T he reporting or recordkeeping requirements in the standard do not include sensitive question s. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are owners or operators of existing and new coke plants . The United States Standard Industrial Classification (SI C ) code s for the respondents affected b y the standard and the corresponding North American Industry Classification Sy stem (NAICS ) codes for owners or operators of existing and new coke plants are listed in the following table

.
**Standard (**  **40 CFR P**  **art 63, S**  **ubpart CCCCC )**  **SIC Codes NAICS Codes**  Iron and Steel Mills 3312 331111 All Other Petroleum and Coal Products Manufacturing 3312 324199 **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC). A source must make the following reports:

**Notification s**  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, 63.9(d)6
**Notification s**  if applicable Notification of performance test 63.7(b), 63.9(e), 6 3.5755(a) Rescheduled of performance test 63.7(b)(2) Demonstration of continuous monitoring sy stem 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 (c) Operation and maintenance plan for capture s ys tems , 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), 63.734(d) 63.10(d)(5) Plan for soaking emissions 63.7294 Plan to prevent green pushes from b y - product coke oven batteries with horizontal flues 63.7292 Progress reports for compliance extension (if applicable) 63.6(i) Quarterl y 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)7 **Recordkeeping** 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

- ye ar retention of records 63.10(b)(1), 6 3.7342(d) Electronic Reporting Some of the r espondents 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 sy stems to transmit data electronically . However, electronic reporting s ys tems 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing an d providing information. Adjust the existing way s to comply with an y previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.8

Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has sign ificantly 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 connectio n with the acquisition, analy sis, 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to c ompl y 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. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agenci es, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibili ty** 9

A 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 ty pes 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 require ments 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 sp ecific frequency

for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal)

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

. The A genc y m ay

not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next thre e y ears from these recordkeeping and reporting requirement s is estimated to be 25,879 hours ( Total Labor Hours from Table 1 below ). T hese 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 I CR uses the following labor rates: Managerial $ 121.42 ($ 57.82 + 110%) Technical $ 99.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.72 + 110%)10

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ T otal compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employ ed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the 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 monitors and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**
**Capital/Sta rtup 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 $500 19 $9,500
Continuous Opacity Monitors $37,000 0 $0 $8,421 19 $ 159,999

Total $0 $ 169, 499 The total capital/startup costs for this I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 169,500 (rounded)

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the IC R is estimated to be $169,500 combined

. These are the recordkeeping costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the11

examination of records maintained by the respondents , periodic inspection o f 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 $ 9,536

. This cost is based on the average hourl y labor rate as follows: Manag erial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 1 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 below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 19 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below is 19 per year. The number of respondents is calc ulated using the following table that addresses the three ye ars covered b y 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 19 0 0 19
2 0 19 0 0 19
3 0 19 0 0 19 Average 0 19 0 0 19 1 New respondent include sources with constructed, reconstructed and modified affected facilities C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the12

average Number of Respondents over the three ye ar period of this ICR is 19

. The total number of annual responses per ye ar 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 construct ion 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 Re port of startup , shutdown, malfunction 1 1 0 1 Total 113.4
The number of Total Annual Responses is 113 (rounded)

. The total annual labor costs are $2,479,750

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal). **6(e) Bottom Line 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, respectivel y, and summarized below. **(i) Respondent Tally**  The total annual labor hours are 25,879 at a cost of $2,479,750

. Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 9 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $169,50013

combined

. 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 y ears is estimated to be 212 labor hours at a cost of $9,536 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal). **6(f) Reasons for Change in Burden** There is an increase in costs for both the respondents and the Agency from the most recentl y approved ICR. The increase in burden cost is due to adjustments in labor rates

. This I CR uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs

. There is an increase of 33 hour s in labor hours for the Agency related to a mathematical error in calculating the number of compliance reports per plant per ye ar in the previous ICR. There is no change in the estimation methodolo gy for labor hours to the respondents in this I CR compared to the previous I CR. This is due to two considerations : 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three years ; and 2) the growth rate for respondents is very low, negative, or non

- existent. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 9 hours per response. “ Burden ” means the total time, e ffort, 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 sy s tems 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 an y 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 requ ired to respond to, a collection of information unless it display s a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency 's need for this information, the accur acy 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 I CR under Docket ID Number EPA

–HQ

– OECA

–2011

– 0269

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft14

collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Complian ce Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holi day s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 1927

. Also, you can send comments to the Office of In formation 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 EPA

–HQ

– OECA

–2011

– 0269 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.15

**Table 1: Annual Respondent Burden and Cost**

**– NESHAP for Coke Oven Pushing, Quenching,**  **and Battery Stacks (40 CFR**  **Part 63, Subpart CCCCC) (Renewal)**

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(AxB) (D)**  **Respondents per year**  **a (E)** 

**Technical person**  **** **hou rs per**  **year (CxD)**  **(F)**

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person hours**  **per year (Ex0.1)**  **(H)**

**Total Cost Per year**  **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 4. Reporting Requirements A. Read instructions 2 1 2 0 0 0 0 $0 B. Required activities c, d Method 5 performance test e, c 40 1.5 60 6.4 384 19.2 38.4 $42,313.73 Startup, shutdown, malfunction plan 40 1 40 0 0 0 0 $0 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 Work practice plan for batteries with horizontal f lues (one plant) 40 1 40 1 40 2 4 $4,407.68 Method 9 daily observations for fugitive pushing emissions f 2.8 365 1,022 17 17,374 868.7 1 , 737.4 $1,914,475.81 Weekly sampling for total dissolved solids (TSD) g 2.3 52 119.6 19 2,272.4 113.62 227.24 $250,400.30 Monthly inspections and maintenance of affected sources, control devices, and continuous parameter mo nitoring systems e 2 12 24 19 456 22.8 45.6 $50,247.55 C. Create information See 4B D. Gather existing information See 4B16

E. Write report Notification of applicability 2 1 2 0 0 0 0 $0 Notification of constr

uction/reconstr

uction 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 special compliance 2 1 2 0 0 0 0 $0 Requirements Compliance extension request 2 1 2 0 0 0 0 $0 Notification of performance test c 2 1.5 3 0 0 0 0 $0 Site

- specific test plan 40 1 40 0 0 0 0 $0 Notification of compliance status 8 1 8 0 0 0 0 $0 NESHAP waiver application N/A Report of performance test h See 4B Semiannual compliance reports h 40 2 80 2 160 8 16 $17,630.72 Quarterly compliance reports for battery stacks f 12 4 48 17 816 40.8 81.6 $89,916.67 Emergency startup, shutdown, or malfunction reports i 4 1 4 1 4 0.2 0.4 $440.77 **SUBTOTAL for**  **Reporting Requirements**  **24,732 .**  **36** 5. Recordkeeping Requirements A. Read instructions See 4A B. Plan activities 3 1 3 0 0 0 0 $0 C. Implement activities 12 1 12 0 0 0 0 $0 D. Develop record system 3 1 3 0 0 0 0 $0 E. Time to enter information 1 52 52 19 988 49.4 98.8 $108,869.70 F. Time to train personnel 3 1 3 0 0 0 0 $0 G. Time to adjust existing ways to com ply w ith previously applicable requirements 3 1 3 0 0 0 0 $0 H. Time to tr ansmit or disclose information j 0.25 2 0.50 19 9.50 0.48 0.95 $1,046.8217

I. Time for audits N/A **SUBTOTAL for**  **Recordkeeping Require**  **ments 1,147**  **.13 TOTAL LABOR BURDEN AND COST (Rounded)**  **25,879 $2,479,750** 
**Assu mptions:** 
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: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, Septemb er 2011, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 11 0% to account for the benefit packages available to those employed by private industry.
c 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; w eekly 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 ne ed 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 b atte ry 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 w ere 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 th at 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 information18

**Table 2: Average Annual EPA Burden and Cost**

**– NESHAP for Co**  **ke Oven Pushing, Quenching, and Battery Stacks (40 CFR**  **Part 63, Subpart CCCCC) (Renewal)**

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per plant per year**  **(C)**

**Hours per plant per**  **year (AxB) (D)** 

**Plants per year**  **a (E)** 

**Technical person**  **- hours**  **per year (CxD)**  **(F)**

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person hours**  **per year (Ex0.1)**  **(H)**

**Total Cost Per year**  **b**
Initial performance test 40 1 40 0 0 0 0 $0 Repeat performance test

- Retesting preparation 2 1 2 0 0 0 0 $0 Repeat performance

- Retesting 40 1 40 0 0 0 0 $0 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 1 2 0 0 0 0 $0 Notification of compliance status d 2 1 2 0 0 0 0 $0 Review of repeat Method 5 performance test report f 8 1 8 6.4 51.2 2.56 5.12 $2,653.41 Review of semi

- annual compliance report d 8 0.4 3.2 19 60.8 3.04 6.08 $3,150.93 Review of NESHAP w aiver application 2 1 2 0 0 0 0 $0 Review of quarterly compliance report for battery stacks f 4 1 4 17 68 3.4 6.8 $3,524.07 Review of emergenc y startup, shutdown, and malfunction report g 4 1 4 1 4 0.2 0.4 $207.30 **TOTAL ANNUAL BURDEN AND**  **COST 212**  **$9,536**19

**Assu mptions:**  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 $62.27 (GS

- 13, Step 5, $38.92 + 60%), Technical rate of $46.21 (GS

- 12, Step 1, $28. 88 + 60%), and Clerical rate of $25.01 (GS

- 6, Step 3, $15.63 + 60%). These rates are from the Office of Personnel Management (OPM) “2011 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 conduc t 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 emi ssion 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 report s 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 t o the SSM plan

.