**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal) 1. Identification of the**  **Information Collection 1(a) Title of the Information Collection**  NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal) , EPA I CR Number 1362.10, OMB Control Number 2060

- 0253

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the regulations published at 40 CFR Part 63, Subpart L were proposed on December 4, 1992, promulgated on October 27, 1993, and most recently amended on April 15, 2005 . These regulations appl y to all coke oven batteries, whether existing, new, reconstructed, rebuilt, or restarted. Italso applies to all batteries using conventional by

- product recovery processes , non recovery processes , or any new recovery

process es . New facilities include those that commenced construction or reconstruction after the date of proposal. This information is b eing collected to assure compliance with 40 CFR Part 63, Subpart L

. 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 any startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem 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 lea st five years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority . In the event that there is no such delegated authority, the reports are sent directly to the United States Environmental Protection Agenc y (EPA) regional office. Over the next three ye ars, an average of 19 respondents per ye ar will be subject to the standard, and no additional respondents will become subject to the standard. The respondents consist of two sectors within the coke industry

. The sectors comprise iron and steel integrated plants that produce coke for their operations ( five plants) and merchant plants that produce furnace and foundry

coke for sale on the open market ( fourteen plants). These 19 coke plants operate 59 coke oven batteries (i.e., the affected facilities). We estimate that by

- product batteries account for 80 percent of all coke oven batteries. The estimate is based on historical data on the distribution of by

- product versus non

- recovery batteries. The Office of M anagement and Budget (OMB) approved the currentl y active I CR without any

“Terms of Clearance.”2

The term “Affected Public” applies to owners and operators of coke oven batteries , and may be found in Table 1: Annual Respondent Burden and Cost

– NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal) . The burden to the “Federal Government” burden is attributed entirely to work performed by federal employees or government contractors, and may be found in Table 2: Average Annual EPA Burden and Co st

– NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (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 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 interval s, 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 certif

ications 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, particulate matter (PM) emissions from coke oven batteries cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart L

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure s compliance with the applicable regulations which w ere promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performanc e tests are required in order to determine an affected facility ’ s initial capability to co mply

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 the3

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 regulation . The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated , that leaks are being detected and repaired, and that the standard is 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. Nonduplication, Consultations , and Other Collection Criteria**  The requested recordkeeping an d reporting are required under 40 CFR Part 63, Subpart L. **3(a) Nonduplication** 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, no duplication exists. **3(b) Public No tice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (79 FR 30117) o n May 27, 2014. No comments were received on the burden published in the Federal Regi ster

. **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 Enforcement and Compliance History Online (ECHO) , which is operated and maintained by EPA's Office of Complianc e. ECHO 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 with an opportunity to comment on the burden associated with the standard when it was being developed and further4

amended, and the standard has been previously reviewed to determine the minimum information needed for compliance purpo ses. For the current renewal, EPA contacte d both the American Coke and Coal Chemicals Institut e at (202) 452

- 7198 and Sun Coke Energy , Inc. at (630) 824

- 1000

. **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 b y 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 re quirement is consistent with the Part 70 permit program and the five ye ar statute of limitations on which the permit program is based. T he retention of records for five years allow s EPA to establish the compliance history of a source , any pattern of non - c ompliance , and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond 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, C hapter 1, P art 2, S ubpart B

- Conf

identiality

of Business Information (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). **3(g) Sensitive Questions** T he reporting or recordkeeping requirem ents in the standard do not include sensitive questions.5

**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 new or existing by

- product or non

- recovery coke oven batteries. The United States Standard Industrial Classification (SI C) codes and corresponding North American In dustry Classification Sy stem (NAI CS) codes for respondents affected by the standard are listed in the followin g table.
**Standar d (40 CFR Part 63, Subpart L)**  **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 Batteries (40 CFR Part 63, Subpart L)

. A source must make the following notifications :
**Notification s**  Initial compliance certification 63.311(b ) Intention to construct a new, brownfield, or pa dup rebuild coke oven batteries 63.311(c)(1) , 63.5(d)(1)(ii), 63.9(b) (4)(i) Application for approval of construction/reconstruction (submitted as part of notification of intention to construct a new, brownfield, or padup rebuild coke oven battery) 63 .5(d), 63.9(b)(1)(iii) , 63.9(b)(4) E lection of compliance track 63.311(c)(2) Intention to conduct a PM performance test (new non

- recovery coke oven batteries onl y) 63.311(c)(3) Initial performance test 63.7(b )(1), 63.9(e) Rescheduled initial performance test 63.7(b)(2) Request for an extension of compliance 63.9(c) Request to waive requirements 63. 7(h)(3), 63.10(f)6
**Notification s**  Notification that source is subject to special compliance requirements: obtaining an exemption from control requirements for by pass \ bleeder stacks by

committing to permanent closure of a battery or using an equivalent alternative control sy stem for the stacks; obtaining an alternative standard for coke oven doors on a battery equipped with a shed , including development of a site

specific test plan 63.9(d)

Opacity and visible emission observations (submitted as part of notification of initial performance test) 63.9(f) Notification requirements for coke ovens with a shed using a continuous monitoring system for opacity of emissio ns discharged from the emission control equipment, and meeting the alternative standard (submitted as part of notification of initial performance test) 63.305(f)(4), 63.9(g)

Compliance status 63.9(h) , 63.309(k) Adjustment to time periods or postmark deadlines 63.9( i ) Change in information already provided 63.9(j) Battery closure 63.307(e)(1) Notification of malfunction 63.310(d) Request for startup of cold

- idle battery 63.304(b)(6) A source must make the following reports: **Reports** Emission control work practice plan for each coke oven battery 63.306(a) Revised work practice plan 63.306(d)(4) Finding of whether work practices caused exceedances of emission limitation (submitted as part of any work practice plan revisions) 63.306(d)(3) Report of malfunction 63.310(e) , 63.10(d)(5) Semiannual compliance certification report 63.311(d) Venting of coke oven gas other than through a flare sy stem 63.311(e) Performance test results 63.10(d)(2), 63.309(k) Opacity or visible emission observations (submitted as part of performance test results) 63.10(d)(3)7

A source must keep the following records: **Recordkeeping** All reports and notifications 63.10(b)(1) M alfunctions 63.10(b)(2) Record of internal reports forming the basis of each malfunction notification 63.310(f) , 63.311(f)(6) Startup, shutdown, and malfunction plan 63.310(f), 63.6(e)(3) Any applicability

determination that demonstrates why owner or operator believes source(s) is/are unaffected

. 63.10(b)(3)
For n on - recovery coke oven batteries, records of : daily operating parameters , design characteristics , and compliance demonstration

. 63.311(f)(1) For an approved alternative emission limitation , records of : monitoring parameters indicating exhaust flow rate is maintained, continuous opacity

monitoring s ys tem, and quarterly visual inspection of the shed. 63.311(f)(2) , 63.10(c)

Records of work practice plan, revisions, and implementation of plan requirements for specific emission points. 63.311(f)(3

- 4) Design drawings and engineering specifications for the by pass/bleeder stack flare sy stem or approved alternative control device or s ys tem. 63.311(f)(5)

Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. A lthough 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. **(ii) Respondent Activities Respondent Activities**  Familiarization with the regulatory requirements. Daily performance tests by

a certified observer, commencing on the applicable date and using Method 303 or 303A for each new and existing coke oven battery, are needed to determine compliance with the vis ible emission limitations for coke oven doors, topside port lids, offtake sy stems, and charging operations. Develop and implement an emission control work practice plan for each coke oven battery

.8 **Respondent Activities** For coke ovens equipped with sheds choosing to comply with an alternative to the emission limitation standards, submit an initial test plan and, once approved, conduct an initial performance test using Method 5 (determine the efficiency of control equipment), Method 9 (measure opacity of emissions from contro l device), and Method 22 (measure visible emissions that escape the shed) to get approval to use alternative standard. For coke ovens equipped with sheds complying with the alternative standard, conduct weekly performance tests using Method 303 to determ ine compliance . I f the visible emission limitation is achieved for 12 consecutive observations, switch to monthly tests until an exceedance occurs, at which time the weekl y tests shall be resumed. Install, calibrate, maintain, and operate continuous monitoring sy stem for opacity emissions discharged from the control sy stem at coke oven doors equipped with sheds and complying with the alternative standard. For non

- recovery

coke oven batteries, daily monitoring of pressure in oven or common tunnel to ensure a negative pressure; implement work practices requirement for charging operations at existing batteries; and install, operate , and maintain control sy stem for the capture and collection of emissions at new batteries. For a b y- product recovery , a b rownfield or padup , rebuild coke oven battery, install, operate , and maintain a b ypass/bleeder stack flare s ys tem capable of controlling 120 percent of the normal gas flow generated by the battery , unless the owner or operator has been approved for an alternative control device or s ys tem that achieves at least 98 percent destruction or control of coke oven emissions. For b y- product coke oven, daily inspection of the collecting main for leaks according to Method 303. 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.9 **Respondent Activities** Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. **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, 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 Integrated Compliance Information Sy stem (ICIS) and ECHO. **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 compl y with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and e nforcement 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 reported b y state and local governments in the IC IS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air po llution compliance and enforcement b y local and state regulatory agencies, 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 five10

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 bus inesses) 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 the ir burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

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

– NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (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 IC R. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 80,000 ( Total Labor Hours from Table 1). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHP program , the previousl y approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 129

. 93 ($ 61.87 + 110%)11 Technical $ 103

. 97 ($ 49.51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” Th e rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are no capital/startup or operation and maintenance (O&M) costs. There are no annual O&M costs associated with c ontinuous emission monitors because none of the sources use them to monitor opacity emissions discharged from the control device.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or O&M costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency are those costs as sociated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 5, 300

. This cost is based on the average hourl y labor rate as follows:

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 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 Batteries (40 CFR Part 63, Subpart L) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** 12

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 respon dents per ye ar will become subject. However, we assume one existing respondent will reconstruct a battery over the three

- ye ar period. The overall average number of respondents, as shown in the table below, is 19 per ye ar. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 , 2 (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 2 (E)

Number of Respondents (E=A+B+C

- D)

1 0 .33 19 0 0 .33 19 2 0 .33 19 0 0 .33 19 3 0 .33 19 0 0 .33 19 Average 0 .33 19 0 0 .33 19 1 New respondents include sources with constructed, reconstructed , and modified affected facilities. 2 EPA assumes one existing plant will reconstruct a battery over the 3

- year ICR period (3

- yr average = 0.33 sites/yr = 1 site/3 yrs). We also assume that the design capacity of the reconstructed battery will not exceed that of its predecessor. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the 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

Initial compliance certification 0 1 0 0 Notification of battery construction/ reconstruction(new, 0.33 1 0 0.3313 **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
brownfield, and padup rebuild batteries) 1 Notification of election of compliance track 0 1 0 0
Notification of performance test N/A Reschedule of performance test N/A Request for an extension of compliance N/A
NESHAP waiver application N/A Notification of source being subject to special requirements, including site

- specific test plan N/A

Notification of compliance status N/A Adjustments to time periods or timelines N/A
Changes in information already provided N/A
Notification of battery closure 0.33 1 0 0.33 Notification of malfunction 2 1 0 2 Request for startup of cold

- idle battery N/A
Emission control work practice plan N/A

Revised emission control work practice plan N/A
Report of malfunction (including findings of whether work practices caused exceedances of emission limit) 2 1 0 2

Semiannual compliance certifications 19 2 0 38
Report of coke oven gas venting through bypass/bleeder stack flare 1.6 1 0 1.614 **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

Performance test results N/A Total 44 N/A

– Not applicable 1 EPA assumes one existing plant will submit a notification to reconstruct a battery over the 3

- year ICR period (3

- yr average = 0.33 sites/yr = 1 site/3 yrs). We also assume that the design capacity of the reconstructed battery will not exceed that of its predecessor. Under the NESHAP, such sources are only required to submit a notification of battery reconstruction. The number of Total Annual Responses is 4 4, after rounding

. The total annual labor costs are $ 8,020, 000

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

– NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hour s and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 below , respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 80,000

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

– NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal)

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty

pical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting an d recordkeeping burden for this collection of information is estimated to averag e 1,8 00 h ours per response . There are no total annual capital/startup and O&M costs to the regulated entity

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally**15

The average annual Agency burden and cost over the next three years is estimated to be 116 labor hours at a cost of $ 5,261

. See Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal)

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records.
**6(f) Reasons for Change in Burden**  There is an adjustment decrease in the total estimated respondent labor burden as currentl y identified in the OMB Inventory of Approved Burdens. This decrease is not due to any program change s. Rather, it was due to a discrepancy identified in the previous renewal, in which the number of b y- product plants conducting dail y leak inspections and bypass/bleeder stack/flare s ys tem inspections was overestimated. EPA has revised the estimates in this I CR to reflect the approp riate number of b y- product plants. The net result of this adjustment was a decrease in respondent burden hours

. There is also a small adjustment increase in the number of responses due to a correction. The previous ICR did not account for the notification of reconstruction, notification of battery closure, and malfunction report in calculating the number of respons es. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to averag e 1,8 00 hours per response. Burden means the total time, effort, or financial resources expended by persons to gene rate, 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 stems for the purposes of collecting, validating, and veri fying 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 i nformation; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA 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 m ethods 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

- 2014

- 0044. An electronic version of the public docket is16

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 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 Compliance 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 holiday 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

- 2014

- 0044 and OMB Control Number 2060

–0253 i n any correspondence. **Part B of the Supporting Statement** This part is not applicable because no s tatistical methods were used in collecting this information.17

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

**– NESHAP for Coke Oven Batteries (40 CFR Part 63,**  **Subpart L) (Renewal)**

**Burden item A**  **B C**  **D E**  **F G**  **H Person** 
**** **hours per**  **occurrence Annual** 

**occurrences per**  **respondent Person** 
**- hours** 

**per respondent per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year (CxD)**  **Managem ent** 

**hours per year (Ex0.05)**  **Clerical**

**hours per year**  **(Ex0.10) Annual cost** 

**($) b**  1. Applications N/A 2. Surveys and studies N/A 3. Acquisition, installation, and utilization of technology and systems N/A
4. Reporting requirements A. Read instructions See 5A B. Required activities See 5B C. Write notifications/reports Initial compliance certification c 3 1 3 0 0 0 0 0 Notification of battery construction/ reconstruction (new , brownfield, and padup rebuild batteries) d 2 1 2 0.33 0.66 0.03 0.07 76.33

Notification of election of compliance track e 2 1 2 0 0 0 0 0 Notification of performance test N/A Reschedule of performance test N/A Request for an extension of compliance N/A NESHAP waiver application N/A Notification of source being subject to special requirements, including site

- specific test plan f N/A
Notification of compliance status N/A18

**Burden item A**  **B C**  **D E**  **F G**  **H Person** 
**** **hours per**  **occurrence Annual** 

**occurrences per**  **respondent Person** 
**- hours** 

**per respondent per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year (CxD)**  **Managem ent** 

**hours per year (Ex0.05)**  **Clerical**

**hours per year**  **(Ex0.10) Annual cost** 

**($) b**  Adjustments to time periods or timelines N/A Changes in information already provided N/A Notification of battery closure g 2 1 2 0.33 0.66 0.03 0.07 76.33 Notification of malfunction h 26 1 26 2 52 2.6 5.2 6,013.57 Request for startup of cold

- idle battery i N/A Emission control work practice plan N/A Revised emission control work practice plan N/A Report of malfunction (including findings of whether work practices caused exceedances of emission limit) h 26 1 26 2 52 2.6 5.2 6,013.57

Semiannual compliance certifications 2 2 4 19 76 3.8 7.6 8,789.06 Report of coke oven gas venting through bypass/ bleeder stack flare j 25 1 25 1.6 40 2 4 4,625.82

Performance test results N/A **Reporting Subtotal 255**  **25,595** 5. Recordkeeping requirements A. Read instructions 8 1 8 19 152 7.6 15.2 17,578.12 B. Plan activities See 5E C. Create information See 5F D. Gather existing information See 5E19

**Burden item A**  **B C**  **D E**  **F G**  **H Person** 
**** **hours per**  **occurrence Annual** 

**occurrences per**  **respondent Person** 
**- hours** 

**per respondent per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year (CxD)**  **Managem ent** 

**hours per year (Ex0.05)**  **Clerical**

**hours per year**  **(Ex0.10) Annual cost** 

**($) b**  E. Implement activities All plants Daily performance tests/visible observations k 8.25 365 3,011.25 19 57,213.75 2,860.69 5,721.38 6,616,512.73 Certification program l 24 1 24 19 456 22.8 45.6 52,734.35 Im plement work practice plan 40 1 40 19 760 38 76 87,890.58 Im plement startup, shutdown, and malfunction plan 40 1 40 19 760 38 76 87,890.58
Non

- recovery plants Coke oven doors: daily pressure monitoring m 0.5 365 182.5 3 547.5 27.38 54.75 63,315.91 Coke oven doors: leak detection procedures n 1 365 365 2 730 36.5 73 84,421.22 Charging operations: control equipment work practices o 0.5 365 182.5 3 547.5 27.38 54.75 63,315.91 By

- product plants Daily leak inspection of collecting main 0.5 365 182.50 16 2,920 146 292 337,684.86 By pass/bleeder stack/flare system inspection p 0.5 365 182.50 16 2,920 146 292 337,684.86 Initial/regular performance test/monitoring of opacity (coke oven doors with sheds complying with alternative standard) q N/A

F. Time to record information required by rule 1.5 52 78 19 1,482 74.1 148.2 171,386.63 G. Time to transmit or disclose information 1 2 2 19 38 1.9 3.8 4,394.5320

**Burden item A**  **B C**  **D E**  **F G**  **H Person** 
**** **hours per**  **occurrence Annual** 

**occurrences per**  **respondent Person** 
**- hours** 

**per respondent per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year (CxD)**  **Managem ent** 

**hours per year (Ex0.05)**  **Clerical**

**hours per year**  **(Ex0.10) Annual cost** 

**($) b**  H. Time to train personnel 32 1 32 19 608 30.4 60.8 70,312.46 I. Time for audits N/A **Recordkeeping Subtotal 79,505**  **7,995,123 TOTAL ANNUAL BURDEN AND COST (ROUNDED)**  **79,760 8,020,717**  **TOTAL ANNUAL CAPITAL AND O&M COST 0**  **GRAND TOTAL (LABOR, CAPITAL, AND O&M) 8,020,717**  N/A

– Not Applicable **Assu mptions:**  a EPA estimates an average of 19 existing coke plants will operate 59 coke oven batteries over the next 3 years. Of these plants, 16 will operate 47 by

- product batteries and 3 will operate 12 non

‐ recovery batteries. The distribution of by

- product versus non

- recovery batteries is based on historical ICR data showing that by

- product batteries account for 80% of all coke oven batteries. Non

- recovery batteries account for the remaining 20%. b This ICR uses the following labor rates: $103.97 (technical), $129.93 (managerial), and $51.79 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry. c This burden applies to new sources only. All existing sources have previously submitted initial compliance certifications. d EPA assumes one existing plant will submit a notification to reconstruct a battery over the 3

- year ICR period (3

- yr average = 0.33 sites/yr = 1 site/3 yrs). We also assume that the design capacity of the reconstructed battery will not exceed that of its predecessor. Under the NESHAP, such sources are only required to submit a notification of battery reconstruction. e This burden applies to new sources only. All existing sources have previously submitted this notification. f None of the plants with co keside sheds have applied for the alternative door standard. g EPA assumes one plant will permanently close one of its batteries and submit the required notification over the 3

- year ICR period (3

- yr average = 0.33 sites/yr = 1 site/3 yrs). h EPA assumes two plants per year may experience a malfunction, requiring EPA notification and a w ritten report. i None of the plants have batteries on cold idle. j EPA expects 10% of the 16 by

- product plants (1.6 plants) to experience a venting episode where emission s are released through bypass/bleeder stacks without flaring, requiring notification and a w ritten report. k Daily performance tests are conducted by a certified observer provided by the State enforcement agency for each emission point on each battery. Respondents reim burse States through permit fees. Based on an average of 3 coke ovens batteries per plant, the total person hours for in spections is estimated to be 8.25 hours, using the cost formula for calculating reimbursement costs included in the rul e. l This burden includes the indirect costs to respondents to provide certification to the observer provided by the State enforce ment agency, or its contractor, including a 3

- day

EPA certification course.21

m Owners or operators of three existing non

- reco very plants are required to either conduct leak detection procedures or monitor oven pressure daily. These plants have elected to monitor pressure. n The promulgated rule amendments (70 FR 19992, April 15, 2005) require visible emission observations of d oors for two non

- recovery plants that are not on the lowest achievable emissions rate (LAER) extension track. o Owners or operators of three existing non

- recovery plants are required to implement specified work practices for the control of emissions from charging operations and to document the performance of each procedure. p All 16 by

- product coke plants must install and maintain flares. q None of the plants with cokeside sheds have applied for the alternative door standard. Note: Figures may not add exactly due to rounding.22

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

**– NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal)** 

**Burden item A**  **B C**  **D E**  **F G**  **H EPA**  **person -**  **hours per**  **occurrence Annual** 

**occurrences per**  **respondent EPA** 

**person -**  **hours per respondent**  **per year (AxB) Respondents** 

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Annual** 

**cost ($)**  **b** 1. Report review s A. Initial compliance certification c 2 1 2 0 0 0 0 0 B. Notification of battery construction/ reconstruction (new, brownfield, and padup rebuild batteries) d 2 1 2 0.33 0.66 0.03 0.07 34.54

C. Notification of election of compliance track e N/A D. Notification of performance test N/A E. Reschedule of performance test N/A F. Request for an extension of compliance 4 1 4 0 0 0 0 0 G. NESHAP waiver application 4 1 4 0 0 0 0 0 H. Notification of source being subject to special requirements, including site

- specific test plan f 16 1 16 0 0 0 0 0
I. Notification of compliance status N/A J. Adjustments to time periods or timelines N/A K. Changes in information already provided N/A L. Notification of battery closure g 2 1 2 0.33 0.66 0.03 0.07 34.54 M. Notification of malfunction h 2 1 2 2 4 0.2 0.4 209.36 N. Request for startup of cold

- idle battery i N/A O. Emission control work practice plan j 24 1 24 0 0 0 0 0 P. Revised emission control work practice plan23

**Burden item A**  **B C**  **D E**  **F G**  **H EPA**  **person -**  **hours per**  **occurrence Annual** 

**occurrences per**  **respondent EPA** 

**person -**  **hours per respondent**  **per year (AxB) Respondents** 

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Annual** 

**cost ($)**  **b** Q. Report of malfunction (including findings of whether work practices caused exceedances of emission limit) h 8 1 8 2 16 0.8 1.6 837.44

R. Semiannual compliance certifications k 2 2 4 19 76 3.8 7.6 3,978 S. Report of coke oven gas venting through bypass/bleeder stack flare l 2 1 2 1.6 3.2 0.16 0.32 167.49
T. Performance test results N/A **TOTAL ANNUAL BURDEN AND COST (ROUNDED)**  **116 5,261**  N/A

– Not Applicable **Assu mptions:**  a EPA estimates an average of 19 existing coke plants will operate 59 coke oven batteries over the next 3 years. Of these plants, 16 will operate 47 by

- product batteries and 3 will operate 12 non

‐ recovery batteries. The distribution of by

- product versus non

- recovery batteries is based on historical ICR data showing that by

- product batteries account for 80% of all coke oven batteries. Non

- recovery batteries account for the remaining 20%. b This ICR uses the following labor rates: $46.67 (technical), $62.90 (managerial), and $25.25 (clerical). These rates are fro m the Office of Personnel Management (OPM), 2014 General Schedule, which excludes locality rates of pay. The rates have been incr eased by 60 percent to account for the benefit packages available to government employees. c This burden applies to new sources only. All existing sources have previously submitted initial co mp liance certifications. d EPA assumes one existing plant will submit a notification to reconstruct a battery over the 3

- year ICR period (3

- yr average = 0.33 sites/yr = 1 site/3 yrs). We also assume that the design capacity of the reconstructed battery will not exceed that of its predecessor. Under the NESHAP, such sources are only required to submit a notification of battery reconstruction. e This burden applies to new sources only. All existing sources have previously submi tted this notification. f None of the plants with cokeside sheds have applied for the alternative door standard. g EPA assumes one plant will permanently close one of its batteries and submit the required notification over the 3

- year ICR period (3

- yr average = 0.33 s ites/yr = 1 site/3 yrs). h EPA assumes two plants per year may experience a malfunction, requiring EPA notificati on and a w ritten report. i None of the plants have batteries on cold idle. j All existing sources have previou sly submitted this plan. k All plants are required to submit semiannual co mp liance certifications. l EPA expects 10% of the 16 by

- product plants (1.6 plants) to experience a venting episode where emissions are released through bypass/bleeder stacks without24

flaring, requiring notification and a w ritten report. Note: Figures may not add exactly due to rounding.