1821ss09

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 1821.09, OMB Control Number 2060-0419.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) were proposed on September 18, 1997, promulgated on June 22, 1999, and amended on September 19, 2012. This rule applies to all facilities that pickle steel using hydrochloric acid (HCl) 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 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 containing these documents and retain the file for at least five years following the date of such reports and records. All reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.

The Affected Public includes steel pickling, HCl process facilities and HCl regeneration plants in the United States. The ‘burden’ to the “Affected Public” 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). The Federal Government’s ‘burden’ is attributed entirely to work performed by either Federal employees or government contractors and may be found 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). There are approximately 100 facilities, which are owned and operated by the steel pickling (95 facilities) and acid regeneration (5 facilities) industries. None of the 100 facilities in the United States are owned by either state, local, tribal or the Federal government. We assume that they will all respond to EPA inquiries.

Based on our consultations with industry representatives, there is an average of 1.14 affected facilities at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 100 respondents (95 steel pickling and 5 acid regeneration facilities) per year will be subject to these standards, and no additional respondents per year will become subject to these same standards.

The Office of Management and Budget (OMB) approved the currently-active ICR without any “Terms of Clearance”.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. 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, HCl emissions from continuous and batch pickling lines and acid regeneration units, and chlorine emissions from acid regeneration units, either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/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 these standards 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 standards. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance.

The notifications required in these standards 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 that these standards are being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

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

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

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. If a state or local agency has adopted 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, duplication does not exist.

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 (82 FR 29552) on June 29, 2017. No comments were received on the ‘burden’ published in the Federal Register for this renewal.

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 these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 100 respondents will be subject to these standards over the three-year period covered by this ICR, and there will be no new respondents per year through the period.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed, and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both 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 to 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 these 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 these 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.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in these standards 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
Iron and Steel Mills and Ferroalloy Manufacturing	3312	331110
Steel Wire Drawing	3315	331222
Rolled Steel Shape Manufacturing	3316	331221
Iron and Steel Pipe and Tube Manufacturing from Purchased Steel	3317	331210

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are 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:

Notifications
Notification that area source has become 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)
Application of construction or reconstruction	§§ 63.9(b)(3-4), 63.1163(a)(3-4)
Application of intent to construct new affected source	§§ 63.9(b)(5), 63.1163(a)(5)
Request for an extension of compliance	§ 63.1163(b)
Notification that 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 that may increase the emission rate	N/A
Notification of compliance status	§§ 63.9(h), 63.1163(e)
Notification of demonstration of continuous monitoring system	§ 63.9(g)

Reports
Report of initial and periodic 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 and monitoring exceedances/no excess emissions	§§ 63.10(e)(3), 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)
All reports, notifications, and applicability determinations	§§ 63.10(b), 63.1165(a)(8)-(10)
Records for sources with continuous monitoring systems	§§ 63.10(c), 63.1165(b)
For hydrochloric acid regeneration plant, daily record of each inspection for each requirement under the maintenance program for all required systems and components	§ 63.1160(b)(2)(iii)
Records are required to be retained for five years	§§ 63.1165

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.

Under the rule, facilities must 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 26A tests, and repeat performance tests if necessary. Establish operating parameters for control devices (e.g., scrubbers) and the process parameters required to be monitored for hydrochloric acid regeneration plants (i.e., process offgas temperature and proportion of excess air fed to the process). 

Prepare an operation and maintenance plan for each emission control device.

For hydrochloric acid regeneration plant, develop and implement a written maintenance program for all required systems and components.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.

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 the Enforcement and Compliance History Online (ECHO) and ICIS.

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 standards; 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 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 regulations. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of ‘Burden’ under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may neither conduct nor 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 35,000 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $149.35 ($71.12+ 110%)

Technical $112.98 ($53.80 + 110%)

Clerical $54.81 ($26.10 + 110%)

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.” 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 standards 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 regulations. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other related costs.

(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 the record-keeping 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 such activities as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $47,000.

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

Managerial $64.80 (GS-13, Step 5, $40.50 + 60%)

Technical $48.08 (GS-12, Step 1, $30.05 + 60%)

Clerical $26.02 (GS-6, Step 3, $16.26 + 60%)

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 Federal 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 these standards. It is estimated that no additional respondents per year will become subject to these same standards. 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:

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
NESHAP waiver application	0	1	0	0
Report of initial performance test	0	1	0	0
Report of monitoring exceedances, including results of annual performance test	20	2	0	40
Report of no excess emissions, including results of annual performance test	80	2	0	160
			Total	200

The number of Total Annual Responses is 200.

The total annual labor costs are $3,840,000. 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 below in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 35,000 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 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 1,010 labor hours at a cost of $47,000; see 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(f) Reasons for Change in Burden

There is a minimal decrease in labor hours from the most-recently approved ICR due to revising the assumption for the number of labor hours required to draft a revised operation and maintenance plan. This ICR assumes it takes less time to revise an existing operation and maintenance plan than it does to implement an initial plan.

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 neither conduct nor 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), WJC 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) 566-1752. Also, you can send comments to the Office of 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.

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 person- hours 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. Familiarization with regulatory requirements	1	1	1	100	100	5	10	$12,593
B. Required activities
Initial performance test c	125	1	125	0	0	0	0	$0
Repeat initial performance test c	125	0.2	25	0	0	0	0	$0
Periodic performance tests d, e	125	1	125	100	12500	625	1250	$1,574,107.50
Operation and maintenance plan	40	1	40	0	0	0	0	$0
Operation and maintenance plan revision f	20	1	20	10	200	10	20	$25,185.72
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write Report
Notification of applicability g	2	1	2	0	0	0	0	$0
Notification of construction/ reconstruction g	2	1	2	0	0	0	0	$0
Notification of anticipated startup g	2	1	2	0	0	0	0	$0
Notification of actual startup g	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of initial performance test g	2	1	2	0	0	0	0	$0
Notification of compliance status g	4	1	4	0	0	0	0	$0
NESHAP waiver application h	N/A
Report of initial and periodic performance tests	See 3B
Report of monitoring exceedances, including malfunctions i	16	2	32	20	640	32	64	$80,594.30
Report of no excess emissions j	8	2	16	80	1280	64	128	$161,188.61
Reporting Subtotal					16,928			$1,853,669
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement Activities	See 3B
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	$1,964,486.16
F. Time to train personnel	4	1	4	0	0	0	0	$0
G. Time to transmit or disclose information l	0.25	3	0.75	100	75	3.75	7.5	$9,444.65
H. Time for audits	N/A
Recordkeeping Subtotal					18,026			1,973,931
TOTAL LABOR BURDEN AND COST (rounded) m					34,954			$3,830,000
TOTAL CAPITAL and O&M COSTS (rounded) m								$10,600
GRAND TOTAL (rounded) m						35,000		$3,840,000

^a We have assumed that there are approximately 100 respondents subject to the standard (95 steel pickling and 5 acid regeneration facilities). We have further assumed that no additional respondent per year will become subject to the regulation in the next three years. Since there are no new respondents estimated, initial performance tests, initial operation and maintenance plans, and initial notifications do not apply.

^b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017 “Table 12: Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

^c We have assumed that each new respondent will be required to conduct an initial performance test and 20 percent will have to repeat this test. Since there are no new respondents estimated, these requirements do not apply.

^d Each respondent is required to conduct a periodic performance test to measure either: (1) the HCl mass flows at the control device inlet and outlet or (2) the concentration of HCl exiting the control device. The test results must be reported within 2 months of the test date. Periodic performance tests must be conducted either annually or according to an alternative schedule that is approved by the applicable permitting authority, but no less frequently than every 2.5 years or twice per title V permit term. We are assuming that all periodic performance tests are conducted annually.

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

^f We have assumed that 10 percent of respondents must write a revised operation and maintenance plan for each emission control device.

^g We have assumed that all new sources will be required to meet initial notification requirements. Since there are no new respondents estimated, these requirements do not apply.

^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.

^m Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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 person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours 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 c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Notification of compliance status c	2	1	2	0	0	0	0	$0
Review of initial performance test report d	4	1	4	0	0	0	0	$0
Review of repeat initial performance test report d, e	4	0.2	0.8	0	0	0	0	$0
Existing Sources
Review of excess emissions report f	4	2	8	20	160	8	16	$8,211.20
Review of no excess emissions report g	2	2	4	80	320	16	32	$17,254.91
Review of periodic performance test report h	4	1	4	100	400	20	40	$21,568.64
Review of waiver application i	2	1	2	0	0	0	0	$0
TOTAL (rounded) j					1,010			$47,000

^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. Since there are no new respondents estimated, initial performance tests and initial notifications do not apply.

^b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 for Managerial (GS-13, Step 5), $48.08 for Technical (GS-12, Step 1) and $26.02 Clerical (GS-6, Step 3). These rates are from the Office of Personnel Management (OPM) “2017 General Schedule”, which excludes locality rates of pay.

^c We have assumed that all new sources will be required to meet initial notification requirements. Since there are no new respondents estimated, these requirements do not apply.

^d We have assumed that each respondent will take 4 hours to participate in the performance tests. Since there are no new respondents estimated, these requirements do not apply.

^e We have assumed that 20 percent of new respondents will have to repeat the performance tests due to failure. Since there are no new respondents estimated, these requirements do not apply.

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

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

^h Periodic performance tests are submitted at least twice every 5 years (title V permit term), but may be required by the permitting authority to be submitted as frequently as annually. We assume that all periodic performance tests are conducted annually.

ⁱ We have assumed that no waiver application is expected.

^j Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.