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 1821.08, OMB Control Number 

2060-0419.

1(b) Short Characterization/Abstract

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

regulations published at 40 CFR Part 63, Subpart CCC were proposed on September 18, 1997, 

promulgated on June 22, 1999, and amended on September 19, 2012. The 2012 Residual Risk 

and Technology (RTR) review deemed the risk under the existing rule to be acceptable, but 

eliminated an alternative compliance option for acid regeneration facilities to establish their own 

site-specific emission limits, removed exemption during startup, shutdown, and malfunction 

(SSM), and required certain performance test reports to be submitted electronically. 

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. New facilities include those that commenced construction or reconstruction 

after the date of proposal. 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 United 

States 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 that each plant site has only one respondent (i.e., the 
2

owner/operator of the plant site).

Over the next three years, an average of 100 respondents (95 steel pickling and 5 acid 

regeneration facilities) per year will be subject to the standard, and no additional respondents per 

year will become subject to the standard. 

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

without any “Terms of Clearance”.

All of the steel pickling, HCl process facilities and 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” may be found 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 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 Cost – NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid 

Regeneration Plants (40 CFR Part 63, Subpart CCC) (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 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 
3

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 were promulgated for this source category at 40 CFR Part 

63, Subpart CCC. 

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. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may 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 check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and 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. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart 

CCC. 

3(a) Nonduplication

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 its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. 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 (79 FR 30117) on May 27, 2014. No comments were received on the 
4

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 

provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The industry size is based on 

EPA’s estimates obtained during the development of the 2012 RTR. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted the American Iron and Steel Institute (AISI) at 

(202) 452-7122 and the Steel Manufacturers Association at (202) 296-1515. 

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. In this 

case, no comments were received. 

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 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five 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 five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.
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3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

The 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, and the 

corresponding North American Industry Classification System (NAICS) codes are shown below. 

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 that is recorded or reported is required by the NESHAP for Steel 

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

Subpart CCC).

A source must make the following reports:
6

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)

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)

Semiannual report including reporting of malfunctions 63.10(d)(5)(1), 

63.1164(c)

A source must keep the following records:

Recordkeeping

Occurrence and duration of malfunctions and any maintenance 

performed on the air pollution control equipment 

63.10(b)(2), 

63.1165(a)(1)-(4)

All measurements needed to demonstrate compliance with the standard 63.1165(a)(5)

Initial and subsequent performance test results 63.1165(a)(6)

Emission test results and other data needed to demonstrate a source is 

meeting waiver requirements 

61.13(g), 

63.1165(a)(7)
7

Recordkeeping

All reports, notifications, and applicability determination 63.9, 63.10(b), 

63.1165(a)(9)-(10)

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. 

The 2012 amendment requires facilities to submit electronic copies of required 

performance test reports to EPA’s WebFIRE database through an electronic emissions test report 

structure called the Electronic Reporting Tool (ERT). The requirement to submit performance 

test data electronically to EPA applies only to those performance tests conducted using test 

methods that are supported by the ERT. 

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

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 Method 1, 2, 3, 4 and 26 tests, 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 
8

Respondent Activities

providing information.

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, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (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 properly installed and operated. 

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. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by 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 by this regulation must be retained by the owner/operator for five 
9

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the

development of the regulation. Due to technical considerations involving the process operations 

and the 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 in below 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. 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 requirements is estimated to be 35,100 (Total Labor Hours from Table 1). 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: 
10

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 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.” 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(s) 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 $106 100 $10,600

TOTAL $0 $10,600

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

above table. 

The total operation and maintenance (O&M) costs for this ICR are $10,600. 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 $10,600. These are 

recordkeeping costs. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 
11

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 

$25,000. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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

100 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 100 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
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Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 100 0 0 100

2 0 100 0 0 100

3 0 100 0 0 100

Average 0 100 0 0 100

1

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

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 100. 

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 anticipated 

startup 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

Waiver application 0 1 0 0

Report of performance test 0 1 0 0
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Total Annual Responses

Report of monitoring 

exceedances 20 2 0 40

Report of no excess emissions 80 2 0 160

Total 200

The number of Total Annual Responses is 200. 

The total annual labor costs are $3,530,000. 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).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 35,100. Details regarding these estimates may be found 

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). 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 

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

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

information is estimated to average 175 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $10,600. 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 552 

labor hours at a cost of $25,000. See 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). 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 
14

tasks because the typical duties of clerical staff are to proofread the reports, make copies and 

maintain records.

6(f) Reasons for Change in Burden

The increase in burden and cost from the most recently approved ICR is due to an 

adjustment. It is not due to any program changes. During the 2012 RTR, EPA did not add 

additional requirements, other than reporting performance test results through the WebFIRE 

interface if the test methods used are those supported by the Electronic Reporting Tool (ERT).

However, we updated the estimated average number of respondents subject to Subpart CCC 

from 72 to 100. The increase in the number of facilities results in an overall increase in the 

respondent and Agency burden and in O&M costs. 

6(g) Burden Statement

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

is estimated to average 175 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and 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.

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 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-2014-0064. 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 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, 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 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 
15

Information 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-2014-0064 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.
16

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) (B) (C) (D) (E) (F) (G) (H)

Person 

hours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Person 

hours per 

respondent 

per year

(C=AxB)

Respondents 

per year 

a

Technical 

personhours per 

year

(E=CxD)

Management 

person hours 

per year

(Ex0.05)

Clerical 

person 

hours per 

year

(Ex0.1)

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 1 125 100 12,500 625 1250 $1,445,568.75 

 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 10 400 20 40 $46,258.20 

 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 
17

 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 20 640 32 64 $74,013.12 

 Report of no excess emissions j8 2 16 80 1280 64 128 $148,026.24 

Subtotal for Reporting 17,043 $1,713,866.31 

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 k

3 52 156 100 15600 780 1560 $1,804,069.80 

 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 l0.25 3 0.75 100 75 3.75 7.5 $8,673.41 

 I. Time for audits N/A

Subtotal for Recordkeeping 18,026 $1,812,743.21 

TOTAL LABOR BURDEN AND COST (rounded) 35,069 $3,526,610 

Capital & O&M $10,600 

Grand TOTAL $3,537,210 

Assumptions:

a

 We have assumed that there are approximately 100 respondents 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 has passed and no additional requirements, other than electronic reporting of performance test results, were added under the 2012 RTR amendment. 

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 “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 
18

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 or through the WebFIRE interface if the test methods used are those 

supported by the Electronic Reporting Tool (ERT).

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.

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

l

 We have assumed that each respondent will take 15 minutes three times per year to transmit or disclose information.

Note: Figures may not add up exactly due to rounding.
19

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) (B) (C) (D) (E) (F) (G) (H)

EPA 

personhours per 

occurrence

No. of 

occurrences 

per plant 

per year

EPA 

personhours per 

plant per 

year

(C=AxB)

Plants per 

year 

a

Technical 

person- hours 

per year

(E=CxD)

Management 

person-hours 

per year

(Ex0.05)

Clerical 

person-hours 

per year

(Ex0.1)

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 20 160 8 16 $8,374.40 

 Review of no excess emissions report 

d

2 2 4 80 320 16 32 $16,748.80 

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

Subtotals Labor Burden and cost 480 24 48 $25,123.20 

TOTAL ANNUAL BURDEN AND 

COST (rounded) 552 $25,123 
20

Assumptions:

 a

 We have assumed that there are approximately 100 respondents 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 and no additional requirements, other than electronic reporting of performance test results, were added under the 2012 RTR amendment.

b

 This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for 

Managerial (GS-13, Step 5), $46.67 for Technical (GS-12, Step 1) and $25.25 Clerical (GS-6, Step 3). These rates are from the Office of Personnel Management 

(OPM) “2014 General Schedule”, which excludes locality rates of pay.

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 no waiver application is expected.

Note: Figures may not add up exactly due to rounding.