Burden Calculation Table

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden
Capital & O&M

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Sheet 1: # Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	0	19	0	0.00	19
2	0	19	0	0.00	19
3	0	19	0	0.00	19
Average	0	19	0	0.00	19
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.

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Sheet 2: # Responses

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	0	0	0
Notification of battery construction/ reconstruction (new, brownfield, and padup rebuild batteries) 1	0	0	0	0
Notification of election of compliance track	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	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	1	0	0
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	1.6
Performance test results	N/A
			Total	43.6
N/A - Not applicable			hrs/response:	1,814

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal)										Updated labor rates.
										TECH	$112.98
Burden item	A	B	C	D	E	F	G	H		MGMT	$149.35
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		CLER	$54.81
1. Applications	N/A
2. Surveys and studies	N/A									Source Type	No.
3. Acquisition, installation, and utilization of technology and systems	N/A									Existing	19
4. Reporting requirements										By-product plants	46
A. Familiarization with regulatory instructions	8	1	8	19	152	8	15	$19,141.13		Non-recovery plants	12
B. Required activities	See 5B									New	0
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	0	0	0	0
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/A
Adjustments to time periods or timelines	N/A
Changes in information already provided	N/A
Notification of battery closure g	2	1	2	0	0	0	0	0
Notification of malfunction h	26	1	26	2	52	2.6	5.2	$6,548.28
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	$6,548.28
Semiannual compliance certifications	2	2	4	19	76	3.8	7.6	$9,570.57
Report of coke oven gas venting through bypass/bleeder stack flare j	25	1	25	1.6	40	2	4	$5,037.14
Performance test results	N/A
Reporting Subtotal					428			46,845
5. Recordkeeping requirements
A. Familiarization with regulatory instructions	See 4A
B. Plan activities	See 5E
C. Create information	See 5F
D. Gather existing information	See 5E
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	$7,204,841.72
Certification program l	24	1	24	19	456	22.8	45.6	$57,423.40
Implement work practice plan	40	1	40	19	760	38	76	$95,705.66
Implement startup, shutdown, and malfunction plan	40	1	40	19	760	38	76	$95,705.66
Non-recovery plants
Coke oven doors: daily pressure monitoring m	0.5	365	182.5	3	547.5	27.38	54.75	$68,945.85
Coke oven doors: leak detection procedures n	1	365	365	2	730	36.5	73	$91,927.81
Charging operations: control equipment work practices o	0.5	365	182.5	3	547.5	27.38	54.75	$68,945.85
By-product plants
Daily leak inspection of collecting main	0.5	365	182.50	16	2,920	146	292	$367,711.22
Bypass/bleeder stack/flare system inspection p	0.5	365	182.50	16	2,920	146	292	$367,711.22
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	$186,626.04
G. Time to transmit or disclose information	1	2	2	19	38	1.9	3.8	$4,785.28
H. Time to train personnel	32	1	32	19	608	30.4	60.8	$76,564.53
I. Time for audits	N/A
Recordkeeping Subtotal					79,330			$8,686,894
TOTAL LABOR BURDEN AND COST (rounded)r					79,800			$8,730,000
TOTAL CAPITAL AND O&M COST (rounded)r								0
GRAND TOTAL (rounded)r								$8,730,000
Assumptions:
a EPA estimates an average of 19 existing coke plants will operate 58 coke oven batteries over the next 3 years. Of these plants, 16 will operate 46 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: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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 No reconstructions are assumed to occur during the 3 year renewal period.
e This burden applies to new sources only. All existing sources have previously submitted this notification.
f None of the plants with cokeside sheds have applied for the alternative door standard.
g No facilities are anticipated to permanently close over the 3-year ICR period.
h EPA assumes two plants per year may experience a malfunction, requiring EPA notification and a written 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 emissions are released through bypass/bleeder stacks without flaring, requiring notification and a written 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 reimburse States through permit fees. Based on an average of 3 coke ovens batteries per plant, the total person hours for inspections is estimated to be 8.25 hours, using the cost formula for calculating reimbursement costs included in the rule.
l This burden includes the indirect costs to respondents to provide certification to the observer provided by the State enforcement agency, or its contractor, including a 3-day EPA certification course.
m Owners or operators of three existing non-recovery 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 doors 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.
r Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L) (Renewal)
										Updated labor rates.
Burden item	A	B	C	D	E	F	G	H		TECH	$48.08
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		MGMT	$64.80
1. Report reviews										CLER	$26.02
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	0	0	0	0
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	0	0	0	0
M. Notification of malfunction h	2	1	2	2	4	0.2	0.4	$215.69
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 plan
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	$862.75
R. Semiannual compliance certifications k	2	2	4	19	76	3.8	7.6	$4,098.07
S. Report of coke oven gas venting through bypass/bleeder stack flare l	2	1	2	1.6	3.2	0.16	0.32	$172.55
T. Performance test results	N/A
TOTAL ANNUAL BURDEN AND COST (rounded)m					114			$5,350
Assumptions:
a EPA estimates an average of 19 existing coke plants will operate 58 coke oven batteries over the next 3 years. Of these plants, 16 will operate 46 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: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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.
c This burden applies to new sources only. All existing sources have previously submitted initial compliance certifications.
d No reconstructions are assumed to occur during the 3 year renewal period.
e This burden applies to new sources only. All existing sources have previously submitted this notification.
f None of the plants with cokeside sheds have applied for the alternative door standard.
g No facilities are anticipated to permanently close over the 3-year ICR period.
h EPA assumes two plants per year may experience a malfunction, requiring EPA notification and a written report.
i None of the plants have batteries on cold idle.
j All existing sources have previously submitted this plan.
k All plants are required to submit semiannual compliance 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 without flaring, requiring notification and a written report.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Capital & O&M

No capital and O&M costs for this ICR.