| Table 1: Annual Respondent Burden and Cost – NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal) |
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| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person hours per respondent per year (AxB) |
(D) Respondents per year a |
(E) Technical person- hours per year (CxD) |
(F) Management person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total Cost Per year b |
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Notes: |
| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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Labor Rates |
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| 3. Acquisition, Installation, and Utilization of Technology and Systems |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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Technical |
117.92 |
updated 9/20/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group |
| 4. Reporting Requirements |
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Management |
147.40 |
updated 9/20/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group |
| A. Familiarize with rule requirement |
2 |
1 |
2 |
16 |
32 |
1.6 |
3.2 |
$4,191.74 |
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Clerical |
57.02 |
updated 9/20/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group |
| B. Required activities c, d |
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| Method 5 performance test e, c |
40 |
1.5 |
60 |
6.4 |
384 |
19.2 |
38.4 |
$50,300.93 |
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Number of Respondents: |
16 |
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| Startup, shutdown, malfunction plan |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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By-product Batteries |
30 |
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| Operation and maintenance plans for by-product coke oven batteries and capture systems and control devices applied to pushing emissions |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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Non-recovery Batteries |
20 |
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| Work practice plan for batteries with horizontal flues (one plant) |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$5,239.68 |
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| Method 9 daily observations for fugitive pushing emissions f |
Tracy Curtis:50 batteries at 16 facilities = 3.1 battery per facility. Assume 1 hour per battery per facility.
3.1 |
365 |
1,141 |
Stephen Treimel:
Changed this to 16. Assume all 16 plants have observation requirements.
16 |
18,250 |
912.5 |
1,825.0 |
$2,390,604.00 |
Updated person hrs and # of respondents to reflect correct number of batteries and plants |
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2015 updates: Per Donna Lee Jones, US Steel Gary Works and US Steel Granite City Works shut down since last ICR period. These 2 facilities operate 5 by-product batteries. |
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| Weekly sampling for total dissolved solids (TSD) g |
2.3 |
52 |
119.6 |
16 |
1,913.6 |
95.7 |
191.4 |
$250,666.29 |
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2018 updates: Number of respondents changes from 17 to 16. Number of batteries updated to 30 by-product and 20 non-recovery per industry input. |
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| Monthly inspections and maintenance of affected sources, control devices, and continuous parameter monitoring systems e |
2 |
12 |
24 |
16 |
384 |
19.2 |
38.4 |
$50,300.93 |
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| C. Create information |
See 4B |
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| D. Gather existing information |
See 4B |
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| E. Write report |
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| Notification of applicability |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of constr./reconstr. |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of anticipated startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of special compliance |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Requirements |
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| Compliance extension request |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance testc |
2 |
1.5 |
3 |
0 |
0 |
0 |
0 |
$0 |
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| Site-specific test plan |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| NESHAP waiver application |
N/A |
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| Report of performance test h |
See 4B |
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| Semiannual compliance reports h |
40 |
2 |
80 |
16 |
1280 |
64 |
128 |
$167,669.76 |
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| Quarterly compliance reports for battery stacks i |
12 |
4 |
48 |
Stephen Treimel:
The rule only requires the 11 by-product recovery plants to submit quarterly reports.
11 |
528 |
26.4 |
52.8 |
$69,163.78 |
Updated # of respondents |
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| Emergency startup, shutdown, or malfunction reports j |
4 |
1 |
4 |
1 |
4 |
0.2 |
0.4 |
$523.97 |
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| Subtotal for Reporting Requirements |
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26,238 |
$2,988,661 |
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| 5. Recordkeeping Requirements |
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| A. Familiarize with rule requirement |
See 4A |
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| B. Plan activities |
3 |
1 |
3 |
0 |
0 |
0 |
0 |
$0 |
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| C. Implement activities |
12 |
1 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| D. Develop record system |
3 |
1 |
3 |
0 |
0 |
0 |
0 |
$0 |
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| E. Time to enter information |
1 |
52 |
52 |
16 |
832 |
41.6 |
83.2 |
$108,985.34 |
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| F. Time to train personnel |
3 |
1 |
3 |
0 |
0 |
0 |
0 |
$0 |
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| G. Time to adjust existing ways to comply with previously applicable requirements |
3 |
1 |
3 |
0 |
0 |
0 |
0 |
$0 |
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| H. Time to transmit or disclose information k |
0.25 |
2 |
0.5 |
16 |
8 |
0.4 |
0.8 |
$1,047.94 |
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| I. Time for audits |
N/A |
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83 |
responses/yr |
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| Subtotal for Recordkeeping Requirements |
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966 |
$110,033 |
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326 |
hr/resp |
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| TOTAL LABOR BURDEN AND COST (rounded) l |
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27,200 |
$3,100,000 |
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| Capital and O&M Cost (rounded) l |
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$143,000 |
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| GRAND TOTAL (rounded) l |
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$3,240,000 |
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| Assumptions: |
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| a There is an average of 16 respondents (i.e., coke plants operating 30 by-product batteries and 20 non-recovery batteries). We have assumed that there will be no new sources subject to this regulation. |
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| b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
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| c We have assumed that existing respondents have already comply with initial rule requirements and are in full compliance with periodic requirements including quarterly and semiannual reports. New respondents would have to comply with the initial rule requirements including notifications and performance tests for add-on control devices. |
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| d Monitoring and recordkeeping of operations for respondents include: monthly inspection of capture and control systems; daily Method 9 observations; weekly sampling for dissolved solids for quenching operations; work practices for batteries with horizontal flues (one plant); and Method 5 testing for particulate matter. |
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| e The rule requires that every 2.5 years (or 0.4 times per year over the 3 years of the ICR), each control device applied to pushing emissions must be sampled by Method 5 for particulate matter. From past analysis, we have determined that there is an average of 1.5 emission points per respondent that need to be tested. There is an average of 6.4 respondents per year (16*0.4) submitting Method 5 performance test reports. |
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| f Assumes one hour of observations per day per battery. |
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| g The measuring of the total dissolved solids (TDS) in the make-up water used for quenching is a requirement. In past analysis, we determined there is an average of 2.3 quenching towers per facility. |
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| h The rules requires the submittal of quarterly compliance reports for all battery stacks. If no deviation occurred and no continuous monitoring systems were out of control, only a summary report is required. For other affected sources, semiannual reports are required for any deviation from an emission limitation (including an operating limit), work practice standard, or O&M requirement. |
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| i 40 CFR 63.7341(b) requires quarterly reporting for the COMS monitoring opacity of emissions from the stacks on by-product recovery coke ovens, which are present at eleven plants. |
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| j It assumes that one respondent per year will have a startup, shutdown and malfunction (SSM) occurrence that is not managed according to the SSM plan. |
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| k It assumes 15 minutes to transmit recorded information |
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| l Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Renewal) |
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| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per plant per year |
(C) Hours per plant per year (AxB) |
(D) Plants per year a |
(E) Technical person- hours per year (CxD) |
(F) Management person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total Cost Per year b |
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Notes: |
| Initial performance test |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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Labor Rates |
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| Repeat performance test-Retesting preparation |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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Technical |
48.75 |
Updated 9/20/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule. |
| Repeat performance- Retesting |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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Management |
65.71 |
Updated 9/20/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule. |
| Report Review |
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Clerical |
26.38 |
Updated 9/20/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule. |
| Notification of construction/reconstruction |
N/A |
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| Notification of anticipated startup |
N/A |
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| Notification of actual startup |
N/A |
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| Notification of special compliance requirements |
N/A |
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| Notification of initial performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Review of repeat Method 5 performance test report |
8 |
1 |
8 |
6.4 |
51.2 |
2.56 |
5.12 |
$2,799.28 |
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| Review of semi-annual compliance report e |
8 |
0.4 |
3.2 |
16 |
51.2 |
2.56 |
5.12 |
$2,799.28 |
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| Review of NESHAP waiver application |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Review of quarterly compliance report for battery stacks f |
1 |
4 |
4 |
11 |
44 |
2.2 |
4.4 |
$2,405.63 |
Adjusted person-hrs and occurances to accurately reflect 1 hr, 4x/year. |
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| Review of emergency startup, shutdown, and malfunction report g |
4 |
1 |
4 |
1 |
4 |
0.2 |
0.4 |
$218.69 |
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| TOTAL ANNUAL COST h |
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173 |
$8,220 |
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| Assumptions: |
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| a There are an average of 16 respondents (i.e., coke plants operating 30 by-product batteries and 20 non-recovery batteries). We have assumed that there will be no new sources subject to this regulation. |
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| b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay. |
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| c We have assumed that existing sources have complied with the initial rule requirements. New respondents are required to conduct performance test for add-on control equipment, submit initial notifications and prepare startup, shutdown and malfunction (SSM) plans. |
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| d Every 2.5 years (or about 0.4 times per year, if averaged over the three-year period of ICR), respondents must sample each emission point using Method 5 for particulate matter and submit a report of results. |
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| e Sources are required to submit semiannual compliance reports and startup, shutdown and malfunction (SSM) reports if there is an occurrence that is not managed according to the SSM plan. |
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| f 40 CFR 63.7341(b) requires the submittal of quarterly compliance reports for the COMS monitoring opacity on the battery stacks at the eleven coke plants utilizing by-product recovery ovens. |
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| g It assumes that one respondent will have a startup, shutdown and malfunction (SSM) occurrence that is not managed according to the SSM plan. |
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| h Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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