**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 1821.0 7 , 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 t o 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 affect ed 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office.
Based on our consultations w ith 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 ye ars, 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 respondent s 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 privatel yowned , 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 currentl y a ctive Information Collection Request (I CR) 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, s ection 114(a) states that the Administrator may require any o wner 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 s uch 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 reasonabl y 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 reason ably

b e 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. Inaddition, 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 i nitial 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 p arameters 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 properl y installed and operated, that leaks are being detected and repaired, and that the standards are b eing 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 directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report submi tted to the state or local agency can be sent to the Administrator in lieu of the report required b y 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 IC R was published in the Federal Register ( 76 FR 26900 ) on May 9 , 20 11 . 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 reporting4

provisions in the standard , is the Onlin e Tracking Information System ( OTIS ) , which is operated and maintained b y EPA’s Office of Compliance. OTI S 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 source s each ye ar will become subject to the standard over the three

- ye ar period covered b y 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 dev eloping this ICR, we contacted : 1) the American Iron and Steel Institute (A IS I) , 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 polic y t o respond after a thorough review of comments received since the last ICR renewal as well as those submitt ed in response to the first Federal Register n otice. **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 b y these standards was collected less frequentl y, the proper op eration 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 1 320, 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 with the P art 70 permit program and the five

- ye ar 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 so urce, 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 ye ars. 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 i s made will be safeguarded according to the Agency policies set forth in title 40, chapt er 1, part 2, subpart B

- Confidentiality

of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).5

**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 (SI C) codes for the respondents affected by the standards, which correspond to the North American Industry Classificatio n Sy stem (NAI CS) codes, are listed below for steel pickling, HCLprocess 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 M ills (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 subsequentl y b ecomes 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 phys ical 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, re gulatory

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 th e respondents use electronic reporting.7 **Respondent Activities** Read instructions. Install, calibrate, maintain, and operate s ys tems 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 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 and providing information. Adjust the existing way s 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 s ys tem. Although personnel at the source still need to evaluate the data, this ty pe 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 report s, 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 )

.8

**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 properl y installed and operational. P erformance test reports are used b y the Agency to discern a source’s initial ca pability 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.
In formation contained in the reports is entered into OTI S 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. E PA uses OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory

agencies, EPA regional offices, and EPA headquarters. EPA

- delegated a uthorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner or operator for five ye ars. **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 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 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

f or each information collection activity w ithin this request is shown below in Table 1: Annual Respondent Burden and Cost

− NESHAP for Steel Pickling, HC l 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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specif ic 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, a9

collection of information unless it displays a currently val id 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) Estimatin**  **g 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%) 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 C ompensation. ” The rates have been increased b y 1 10 percent to account for the benefit packages available to those employed 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 s ubject 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 m aintenance 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 I CR are zero. This is the total of column D in the10

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 ye ars of the I CR is estimated to be $7,632. **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. 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 $ 18,65 7

. This cost is based on the average hourl y 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) “ 20 11 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 Cos t

- 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 o ver 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 ye ar. The number of respondents is calculated using the following table which addresses the three ye ars covered b y this I CR.11 **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

- ye ar period of this ICR is 72

. 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 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 $ 2,425,7 67 . 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)

.12

**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 Tabl es 1 and 2, respectivel y, 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 $ 18,65 7 . 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 IC R compared to the previous ICR. This is due to two considerations. F irst, 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 currentl y identified in the OMB Inventory of Approved Burd ens. 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 co llection 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 includ es the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information ; adjust the existing way s 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 s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R 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 sy stem, 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 In formation Center in the EPA Docket Center (EPA/DC), EPA West, Ro om 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

- 17 52

. Also, yo u 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 meth ods were used in collecting this information.**Table 1:**  **A nnual**  **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 person**  **** **hours per year**  **(E=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. 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 c 125 1 125 0 0 0 0 $0 Annual performance test d, e 125 1 125 72 9,000 450 900 $991,7 28

. 0 0 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 f 40 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 g 2 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 i 16 2 32 14.4 460.8 23.04 46.08 $50,77 6

. 4 7 Report of no excess emissions j 8 2 16 57.6 921.6 46.08 92.16 $101,55 2

. 94 Startup, shutdown, malfunction report k 8 2 16 3.6 57.6 2.88 5.76 $6,347. 05 **Subtotal for Reporting** 12,337 .2 $1,182,1 39 .7 615

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

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

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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 standards l 3 52 156 72 11,232 .00 561.6 0 1,123.2 0 $1,237,6 76

. 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 m 0.25 3 0.75 72 54 .00 2.7 0 5.4 0 $5,950. 36 I. Time for audits N/A **Subtotal for Recordkeeping** 12,97 8.9 22,014 1,100.7 2,201.4 $2,425,766.66 **TOTAL LABOR BURDEN AND COST (rounded)** 25,316 $2,425,7 67

**Assu mptions:**  a We have assumed that there are approximately 72 respondents, i.e., 64 of 82 existing steel pickling facilities and 8 acid regeneration plants u sing hydrochloric acid, are subject to the standard. We have further assumed that no additional respondent per year will become subject to the regulati on in the next three years. We have further assumed that all existing sources are in compliance with the re gulation 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, Septem ber 2011 “ Table 1 2 : Civilian workers , by occupational and industry group. ” The rates are from column 1, “ Total com pensation. ” The rat es have been increased by 1 10 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 contro l d evice 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 w rite a revised maintenance plan. g We have assumed that all new source s will be required to meet initial notification requirements.16

h We h ave 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 a ssumed 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 a ccording to the plans. l We have a ssumed 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.17

**Table 2:**  **A verage**  **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 person**  **** **hours per occurrence**  **(B)**

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

**EPA person**  **** **hours per plant per**  **year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E) Technical**  **person**   ** hours per** **year (E=CxD)**  **(F)**

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

**Clerical person**  **** **hours 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 c 4 2 8 14.4 115.2 0 5.76 11.52 $5,9 70

. 17 Review of no excess emissions report d 2 2 4 57.6 230.4 0 11.52 23.04 $11,9 40

. 36 Review of startup, shutdown, malfunction Report e 2 2 4 3.6 14.4 0 0.72 1.44 $746.2 6 Review of waiver application f 2 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 $18,65 7

**Assu mptions:**  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 follo wi ng hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $ 62

. 27 for Managerial (GS

- 13, Step 5, $3 9

. 92 x 1.6), $4 6

. 21 for Technical (GS

- 12, Step 1, $2 8

. 8 8 x 1.6) and $2 5

. 01 Clerical (GS

- 6, Step 3, $1 5 .6 3 x 1.6). T hese rates are from the Office of Personnel Management (OPM) “ 20 11 General Schedule ”, which excludes locality rates of pay.18

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 a ccording to the plans f We have assumed that no waiver application is expected.