SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration 

Plants (40 CFR Part 63, Subpart CCC) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants 

(40 CFR Part 63, Subpart CCC) (Renewal), EPA ICR Number 1821.07, OMB Control Number 

2060-0419

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Steel 

Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR part 63, 

subpart CCC) were proposed on September 18, 1997 (62 FR 49051), and promulgated on June 22, 

1999 (64 FR 33202). This rule applies to all facilities that pickle steel using hydrochloric acid or 

regenerate hydrochloric acid, and are either major sources or part of a facility that is a major source. 

This regulation does not apply to any pickling line that uses an acid other than hydrochloric acid or 

an acid solution containing either less than 6 percent hydrochloric acid (HCl) or at a temperature 

less than 100° F. This information is being collected to assure compliance with 40 CFR part 63, 

subpart CCC. 

In general, all 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 any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is inoperative. 

These notifications, reports, and records are essential in determining compliance, and are required 

of all affected facilities subject to NESHAP. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

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

Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an average of 1.14 

affected facilities at each plant site, and each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of 72 respondents (i.e. 64 of 82 existing steel pickling 

facilities and 8 acid regeneration plants using hydrochloric acid) per year will be subject to the 

standard, and no additional respondents will become subject to the standard in the next three years. 
2

All of the steel pickling, HCl process facilities and the hydrochloric acid regeneration 

plants in the United States are owned and operated by the steel pickling, HCl process facilities and 

the hydrochloric acid regeneration industry (the “Affected Public”). None of the facilities in the 

United States are owned by state, local, tribal or the Federal government. They are all privatelyowned, for-profit businesses. The burden to the “Affected Public” is listed below in Table 1: 

Annual Respondent Burden and Cost − NESHAP for Steel Pickling, HCl Process Facilities and 

Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal). The Federal 

government burden associated with the review of reports submitted by the respondent is shown

below in Table 2: Average Annual EPA Burden and Cost − NESHAP for Steel Pickling, HCl 

Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC)

(Renewal).

The Office of Management and Budget (OMB) approved the currently active Information 

Collection Request (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, hydrochloric acid emissions from continuous and batch 

pickling lines and acid regeneration units, and chlorine emissions from acid regeneration units 

cause or contribute to air pollution that may reasonably be anticipated to endanger public health or 

welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 63, 

subpart CCC.
3

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which were promulgated in accordance with the Clean Air Act. In addition, 

the collected information is 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.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart 

CCC.

3(a) Non-duplication

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 (76 FR 26900) on May 9, 2011. No comments were received on the burden 

published in the Federal Register.

3(c) Consultations

The Agency has consulted industry 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 
4

provisions in the standard, is the Online Tracking Information System (OTIS), which is operated 

and maintained by EPA’s Office of Compliance. OTIS is the EPA database for the collection, 

maintenance, and retrieval of all compliance data. We estimate that there are on average 72

existing respondents subject to the reporting requirements of this standard, and that no new sources

each year will become 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. In developing this 

ICR, we contacted: 1) the American Iron and Steel Institute (AISI), at (202) 452-7100; 2) the Steel 

Manufacturers Association, at (202) 296-1515; and 3) the U. S. Geological Survey at (703) 

648-7757. EPA did not receive any comments from the consultations. 

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

These reporting or recordkeeping requirements do not 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).
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3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are steel pickling, HCl 

process facilities and hydrochloric acid regeneration plants. The United States Standard Industrial 

Classification (SIC) codes for the respondents affected by the standards, which correspond to the 

North American Industry Classification System (NAICS) codes, are listed below for steel pickling, 

HCL process facilities and hydrochloric acid regeneration plants.

Standard (40 CFR, part 63, subpart CCC) SIC 

Codes

NAICS 

Codes

Steel Works, Blast Furnaces (including Coke Ovens), and Rolling Mills 

(except coke ovens not integrated with steel mills) 3312 331111

Rolled Steel Shape Manufacturing 3312 31221

Steel Wiredrawing and Steel Nails and Spikes (steel, wire drawing) 3315 331222

Cold-Rolled Steel Sheet, Strip and Bars 3316 331221

Steel Pipes and Tubes 3317 33121

4(b) Information Requested

(i) Data Items

In this ICR, all the data recorded or reported is required by the National Emission 

Standards for Hazardous Air Pollutants for Steel Pickling, HCl Process Facilities and 

Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC).

A source must make the following reports:

Notifications

Notification when an area source subsequently becomes subject 

to the rule requirements 63.9(b)(1), 63.1163(a)(1)

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

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

Notification and application of intent to construct a new 

affected source 63.9(b)(5), 63.1163(a)(5)

Request for an extension of compliance 63.1163(b)
6

Notifications

Notification that the source is subject to special compliance 

requirements 63.1163(c)

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

Notification of physical or operational change which may

increase the emission rate N/A

Notification of compliance status 63.9(h), 63.1163(e)

Reports

Report of performance test results 63.10(d)(2), 63.1164(a),

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

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

A startup, shutdown, malfunction (SSM) plan and periodic 

SSM reports when there is a deviation from the plan

63.10(d)(5)(1), 

63.1164(c)(1-3)

A source must keep the following records:

Recordkeeping 

Startups, shutdowns, malfunctions, periods where the 

continuous monitoring system is inoperative 63.10(b)(2), 63.1165(a)

Emission test results and other data needed to determine 

emissions 61.13(g), 63.1165(a)(7)

All reports and notifications 63.9, 63.10(b), 

63.1165(a)(10)

Record of applicability 63.10(b)(3)

Records for sources with continuous monitoring systems 63.10(3)

Records are required to be retained for five years 63.1165(a-c)

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.
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Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate systems for the measurement of process gas 

temperature, excess air proportion, make-up water flow, and recirculation flow rate for web 

scrubbers or other parameters established during the performance test for an alternative control 

device.

Perform initial performance test, Reference Methods 1, 2, 3, 4, and 26, tests or approved 

alternative method, and repeat performance tests if necessary.

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.

Currently, sources are using monitoring equipment that provide 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).
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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 

below in Table 1: Annual Respondent Burden and Cost − NESHAP for Steel Pickling, HCl 

Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC)

(Renewal).

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 
9

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 25,316 (Total Labor Hours from Table 1 below). 

These hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

 

This ICR uses the following labor rates: 

Managerial $121.42 ($57.82 + 110%) 

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

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, “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 type 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 monitor and other costs, such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/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)

Flow-meters with 

high/low alarms $830 0 $0 $106 72 $7,632

$0 $7,632

The total capital/startup costs for this ICR are zero. This is the total of column D in the 
10

above table.

The total operation and maintenance (O&M) costs for this ICR are $7,632. 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 years of the ICR is estimated to be $7,632.

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 

$18,657.

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

 Managerial $62.27 (GS-13, Step 5, $39.92 + 60%) 

 Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

 Clerical $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. 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 

Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 

63, Subpart CCC) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 72 

respondents will be subject to the standard. It is estimated that no additional new source will 

become subject to the rule. The overall average number of respondents, as shown in the table 

below, is 72 per year.

The number of respondents is calculated using the following table which addresses the 

three years covered by this ICR.
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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 72 0 0 72

2 0 72 0 0 72

3 0 72 0 0 72

Average 0 72 0 0 72

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

To avoid double-counting respondents, column D is subtracted. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 72.

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 applicability 0 1 0 0

Notification of construction/reconstruction 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of special compliance 

requirements 0 1 0 0

Notification of initial performance test 0 1 0 0

Notification of compliance status 0 1 0 0

Report of monitoring exceedances 14.4 2 0 28.8

Report of no excess emissions 57.6 2 0 115.2

Startup, shutdown, malfunction report 3.6 2 0 7.2

Total 151.2

The number of Total Annual Responses is 151 (rounded).

The total annual labor costs are $2,425,767. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Steel Pickling, HCl 

Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC)

(Renewal).
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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 hours are 25,316. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost - NESHAP for Steel Pickling, HCl Process 

Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 168 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $7,632. 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 414 

labor hours at a cost of $18,657. See below Table 2: Average Annual EPA Burden and Cost -

NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants 

(40 CFR Part 63, Subpart CCC) (Renewal).

6(f) Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the previous ICR. This is due 

to two considerations. First, the regulations have not changed over the past three years and are not 

anticipated to change over the next three years. Secondly, the growth rate for the industry is very

low, negative or non-existent, so there is no significant change in the overall burden. However, 

there is an increase in the total labor and Agency costs as currently identified in the OMB 

Inventory of Approved Burdens. This increase is not due to any program changes. The change 

in cost estimates reflects updated labors rates available from the Bureau of Labor Statistics. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 168 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; 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.
13

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-2011-0248. 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-2011-0248 and OMB 

Control Number 2060-0419 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.
Table 1: Annual Respondent Burden and Cost – NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid 

Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal)

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 

personhours per 

year

(E=CxD)

(F)

Management 

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. Reporting requirements

 A. Read instructions 4 1 4 0 0 0 0 $0

 B. Required activities

 Initial performance test 125 1 125 0 0 0 0 $0

 Repeat performance test c125 1 125 0 0 0 0 $0

 Annual performance test d, e 125 1 125 72 9,000 450 900 $991,728.00

 Startup, shutdown, malfunction plan 40 1 40 0 0 0 0 $0

 Maintenance plan 40 1 40 0 0 0 0 $0

 Maintenance plan revision f40 1 40 7.2 288 14.4 28.8 $31,735.30

 C. Create information See 3B 

 D. Gather existing information See 3B 

 E. Write Report

 Notification of applicability g2 1 2 0 0 0 0 $0

 Notification of construction/reconstruction 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 

 requirements 

N/A

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

 Notification of compliance status 4 1 4 0 0 0 0 $0

 NESHAP waiver application h N/A

 Report of performance test See 3B

 Report of monitoring exceedances i16 2 32 14.4 460.8 23.04 46.08 $50,776.47

 Report of no excess emissions j8 2 16 57.6 921.6 46.08 92.16 $101,552.94

 Startup, shutdown, malfunction report k8 2 16 3.6 57.6 2.88 5.76 $6,347.05

Subtotal for Reporting 12,337.2 $1,182,139.76
15

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 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Total Cost 

Per year b

4. Recordkeeping requirements

 A. Read instructions See 3B

 B. Plan activities N/A

 C. Implement Activities N/A

 D. Develop record system N/A

 E. Time to enter information

 Records of all information required by

 standardsl

3 52 156 72 11,232.00 561.60 1,123.20 $1,237,676.54

 F. Time to train personnel 4 1 4 0 0 0 0 $0

 G. Time to adjust existing ways to comply with

 previously applicable requirements

N/A

 H. Time to transmit or disclose information m0.25 3 0.75 72 54.00 2.70 5.40 $5,950.36

 I. Time for audits N/A

Subtotal for Recordkeeping 12,978.9

22,014 1,100.7 2,201.4 $2,425,766.66

TOTAL LABOR BURDEN AND COST (rounded) 25,316 $2,425,767

Assumptions:

a

 We have assumed that there are approximately 72 respondents, i.e., 64 of 82 existing steel pickling facilities and 8 acid regeneration plants using hydrochloric acid, are 

subject to the standard. We have further assumed that no additional respondent per year will become subject to the regulation in the next three years. We have further 

assumed that all existing sources are in compliance with the regulation since the compliance date of this rule as passed.

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, September 2011 “Table 12: 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.

c

 We have assumed that each new respondent will be required to conduct an initial performance test and will not have to repeat this test.

d

 We have assumed that it will take 125 hours for each respondent to complete the annual performance test and report.

e

 Each of the respondents are required to conduct an annual performance test to either measure the HCl mass flows at the control device inlet and outlet or the 

concentration of HCl exiting the control device and report the results in the semiannual reports.

f

 We have assumed that 10 percent of respondents must write a revised maintenance plan.

g

 We have assumed that all new sources will be required to meet initial notification requirements.
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h We have assumed that no respondent will request a NESHAP waiver application.

i We have assumed that 20 percent of respondents will report excess emissions on a semiannual basis.

j We have assumed that 80 percent of respondents will report no excess emissions on a semiannual basis.

k

 We have assumed that 5 percent of respondents will have a startup, shutdown, or malfunction event occur that is not managed according to the plans.

l

 We have assumed that each respondent will take three hours each week to record all information required by the standard. 

m

 We have assumed that each respondent will take 15 minutes three times per year to transmit or disclose information.
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Table 2: Average Annual EPA Burden and Cost − NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid 

Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

Report Review

 New Sources

 Notification of applicability 2 1 2 0 0 0 0 $0

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

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

 Notification of special compliance 

 requirements

N/A

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

 Notification of compliance status 2 1 2 0 0 0 0 $0

 Review of performance test report 4 1 4 0 0 0 0 $0

 Review of repeat test report 4 1 4 0 0 0 0 $0

 Existing Sources

 Review of excess emissions report c4 2 8 14.4 115.20 5.76 11.52 $5,970.17

 Review of no excess emissions report d2 2 4 57.6 230.40 11.52 23.04 $11,940.36

 Review of startup, shutdown, malfunction

 Report e 

2 2 4 3.6 14.40 0.72 1.44 $746.26

 Review of waiver application f2 1 2 0 0 0 0 $0

Subtotals Labor Burden and cost 360 18 36 $18,656.79

TOTAL ANNUAL BURDEN AND COST 

(rounded)

414 $18,657

Assumptions:

 a

 We have assumed that there are approximately seventy-two respondents, i.e., 64 of 82 existing steel pickling facilities and 8 acid regeneration plants using

 hydrochloric acid, are subject to the standard. We have further assumed that no additional respondent per year will become subject to the regulation in the next three

years. We have further assumed that all existing sources are in compliance with the regulation since the compliance date of this rule as passed.

b

 This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for 

Managerial (GS-13, Step 5, $39.92x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from 

the Office of Personnel Management (OPM) “2011 General Schedule”, which excludes locality rates of pay.
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c

 We have assumed that 20 percent of respondents will report excess emissions on a semiannual basis

 d

 We have assumed that 80 percent of respondents will report no excess emissions on a semiannual basis.

e

 We have assumed that 5 percent of respondents will have a startup, shutdown, or malfunction event occur that is not managed according to the plans

f

 We have assumed that no waiver application is expected.