SUPPORTING STATEMENT

AMENDMENTS TO NEW SOURCE PERFORMANCE STANDARDS (NSPS)

FOR

COAL PREPARATION AND PROCESSING PLANTS

September 2009

Part A of the Supporting Statement

1.	Identification of the Information Collection

(a)	Title and Number of the Information Collection.

	“Recordkeeping and Reporting Requirements for Coal Preparation and
Processing Plants (40 CFR Part 60, Subpart Y).”  The Office of
Management and Budget (OMB) has previously approved the information
collection requirements for the existing rule.  OMB control number
2060-0122 has been assigned to the ICR revision.  The EPA ICR tracking
number is 1062.12, and this is a revision of the existing ICR based on
review of the NSPS.

(b)	Short Characterization.

  SEQ CHAPTER \h \r 1 Respondents who are required to perform this
information collection are the owners and operators of coal preparation
and processing plants that are subject to the New Source Performance
Standards (NSPS) for coal preparation and processing plants in 40 CFR
Part 60, Subpart Y.  These amendments include revisions to the emission
limits for particulate matter (PM) and opacity standards for thermal
dryers, pneumatic coal cleaning equipment, and coal handling equipment
(coal processing and conveying equipment, coal storage systems, and coal
transfer and loading systems) located at coal preparation and processing
plants which commence construction, modification, or reconstruction
after April 28, 2008.  The amendments also establish a sulfur dioxide
(SO2) emission limit and a combined nitrogen oxide (NOx) and carbon
monoxide (CO) emissions limit for thermal dryers located at coal
preparation and processing plants which commence construction,
modification, or reconstruction after May 27, 2009. 

Affected owners and operators subject to the rule are required to
install and operate air emission controls and meet certain work practice
standards.  Work practices are implemented on a site-specific basis
according to a fugitive coal dust emissions control plan prepared by the
affected owners and operators.  To demonstrate initial and continuous
compliance with the rule requirements, affected owners and operators
need to collect information to meet specific monitoring, inspection,
recordkeeping, and reporting requirements.

For affected facilities mechanically vented through a control device,
respondents are required to conduct initial and subsequent emissions
testing to show compliance with the applicable PM limits using EPA
Method 5 of 40 CFR part 60, appendix A-4.  Thereafter, subsequent Method
5 performance tests must be conducted either annually or biannually as
determined by the results of the most recent Method 5 test.  Similar
emissions testing requirements are specified in the rule amendments
using the appropriate EPA test methods for new, reconstructed, or
modified thermal coal dryers subject to the SO2 and combined NOx/CO
emission limits.

For affected facilities subject to opacity emissions limits, respondents
are required to conduct initial emissions testing to show compliance
with the applicable opacity limits using EPA Method 9 of 40 CFR part 60,
appendix A-4.  Thereafter, subsequent Method 9 performance tests must be
conducted at intervals determined by the results of the most recent
Method 9 test.  As an alternative to subsequent Method 9 performance
testing, the rule amendments allow affected owners and operators to
elect to conduct monitoring as follows: (1) monthly visual observations
of process and control equipment and, if any deficiencies are observed,
the necessary maintenance must be performed as expeditiously as
possible; and (2) daily walkthrough observations consisting of a single
15-second observation (i.e., visible emissions or no visible emissions)
of each affected facility and, if any visible emissions are observed,
within 24 hours corrective actions must be conducted and the owner or
operator must demonstrate that there are no visible emissions. 
Additional monitoring options to subsequent Method 9 performance testing
available under the rule amendments that owners and operators can choose
to use for an affected facility, when applicable, are installation and
operation of a continuous opacity monitoring system (COMS) or a digital
opacity monitoring system.

The rule amendments include separate opacity testing and monitoring
requirements for coal truck dump operations.  EPA determined that a
different approach for Method 9 opacity performance testing is warranted
due to the intermittent nature of coal truck dumping.  Coal truck dump
operations are subject to the same opacity limits as other coal-handling
operations.  The rule amendments require quarterly performance tests
using an appropriate adaptation of Method 9.

Semiannually, the respondent would be required to prepare and submit to
EPA a compliance report describing any periods of control device
operation during which the monitored values of the specified control
device operating parameters deviated from the boundaries established
during the most recent performance test.  For the affected facilities,
respondents would be required to collect and maintain records in a
logbook of the air pollution control equipment inspections and repairs,
as specified in the rule.

2.	Need for and Use of the Collection

(a)  	Need/Authority for the Collection.

	EPA is charged under section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect:

. . . application of the best system of emission reduction which (taking
into account the cost of achieving such reduction and any non-air
quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated. Section
111(a)(l).

EPA refers to this charge as selecting the best demonstrated technology
(BDT).  Section 111 also requires that the Administrator review and, if
appropriate, revise such standards every eight years.

	In addition, CAA section 114(a) states that the Administrator may
require any owner or 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, particulate emissions from coal
preparation and processing plants cause or contribute to air pollution
that may reasonably be anticipated to endanger public health or welfare.
 Therefore, the NSPS was promulgated for this source category at 40 CFR
part 60, subpart Y.

(b)  	Use/Users of the Data.

  SEQ CHAPTER \h \r 1 The information collected would be used by EPA
personnel to: 1) identify new, reconstructed, or modified sources at
coal preparation and processing plants subject to the standards, 2)
ensure that the NSPS is being properly applied; 3) identify those
facilities that should be inspected; 4) identify those facilities that
may benefit from compliance assistance activities; and 5) ensure that
the emission control devices are being properly operated and maintained
on a continuous basis to reduce PM emissions from affected coal-handling
operations, and PM, SO2, NOx, and CO emissions from affected thermal
coal dryers.

	

To minimize the burden, much of the information EPA needs to determine
compliance would be recorded and retained on-site at the facility.  Such
information would be reviewed by the enforcement personnel during an
inspection and would not need to be routinely reported to EPA.  For
situations other than when a deviation from the rule requirements has
occurred, information required to be reported has been reduced to the
extent practical.

3.	Nonduplication, Consultations, and Other Collection Criteria

(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 EPA.  If a
State or local EPA has adopted their own similar standards to implement
the Federal standards, a copy of the report submitted to the State or
local EPA can be sent to the Administrator in lieu of the report
required by the Federal standards.  Therefore, no duplication exists.

(b)	Public Notice Required Prior to ICR Submission to OMB.

	This section is not applicable because this is a rule related ICR.

(c)	Consultations.

	During development of the rule amendments, EPA held meetings and
conference calls with representatives of the following trade
associations, companies, and control equipment manufacturers:  Utility
Air Regulatory Group (UARG), National Mining Association (NMA), American
Petroleum Institute (API), Peabody Energy Corporation (formerly Peabody
Coal), Benetech, Inc., and Dust Solutions, Inc.  More information is
available in the docket for this rulemaking.

(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 likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

(e)	General Guidelines.

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR 1320.5.

(f)	Confidentiality.

	The required information has been determined not to be confidential. 
However, any information submitted to EPA for which a claim of
confidentiality is made will be safeguarded according to EPA 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).

(g)	Sensitive Questions.

	None of the reporting or recordkeeping requirements contain sensitive
questions.

4.	The Respondents and the Information Requested

(a)	Respondents/NAICS Codes.

	The North American Industry Classification System (NAICS) codes for
respondents affected by the standards are listed in the following table.

Standard (40 CFR part 60, subpart Y)	NAICS Code

Bituminous Coal and Lignite Surface Mining	212111

Bituminous Coal Underground Mining 	212112

Fossil Fuel Electric Power Generation	212112

Fossil Fuel-Fired Electric Steam Generating Units in Indian Country
921150

Anthracite Mining 	212113

Support Activities for Coal Mining	213113

Paper (except Newsprint) Mills	322121

Petrochemical Manufacturing	325110

All Other Petroleum and Coal Products Manufacturing	324199

Cement Manufacturing	327310

All Other Petroleum and Coal Products Manufacturing	324199

Iron and Steel Mills	331111



(b)	Information Requested.

	(i)	Data Items, Including Recordkeeping Requirements. All data in this
ICR that is recorded and/or reported is required by NSPS for Coal
preparation and processing plants (40 CFR part 60, subpart Y).

A source must make the following reports:

Reports for 40 CFR Part 60

	Subpart A	Subpart Y

Construction/reconstruction	60.7(a)

	Anticipated startup	60.7(a)

	Notification of actual startup	60.7(a)

	Initial performance test	60.8

	Initial performance test results	60.8	60.258(c)

Physical or operational change	60.7(a)

	Repeat performance test results	60.8	60.258(d)

Semi-Annual Excess Emission Reports	60.7(c)	60.258(b)



	A source must maintain the following records:



Recordkeeping for 40 CFR Part 60

	Subpart A	Subpart Y

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative	60.7(b)

	Maintain a written or electronic logbook

60.258(a)

Records are required to be retained for two (2) years	60.7(f)

	Records of ongoing monitoring	60.7(f)

	Fugitive Coal Dust Emissions Control Plan

60.254(c)

Bag Leak Detection System Site-Specific Plan

60.256(c)



	(ii)	Respondent Activities. The respondent activities required by
subpart Y are listed in the following tables.

Respondent Activities

Read instructions.

Perform initial performance test using appropriate Reference Method, 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 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.

Transmit, or otherwise disclose the information.



5.	The Information Collected: EPA Activities, Collection Methodology,
and Information Management

(a)	EPA Activities.

	EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

EPA Activities

Observe initial performance tests and repeat performance tests if
necessary.

Review notifications and reports, including performance test reports,
emission control plans, and excess emissions reports, required to be
submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS)
database.

Analyze and maintain data in the WebFIRE database.



(b)	Collection Methodology and Management.

	Following notification of startup, EPA or delegated authority might
inspect a coal preparation and processing plant to determine whether the
required air pollution control devices are properly installed and
operated.  Performance test reports are used by EPA to determine an
affected facility’s initial and subsequent compliance with the
applicable emissions limits.  Selected data and records maintained by
the respondents are tabulated for use in air compliance and enforcement
programs.

	Certain information contained in the reports is entered into the AIRS
Facility Subsystem (AFS), which is operated and maintained by EPA’s
Office of Compliance, and into the WebFire database.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
and annual emission inventory data for over 100,000 industrial and
government-owned facilities.  EPA uses the AFS 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 Web Factor Information Retrieval (FIRE) Data System is a database
management system containing EPA’s recommended emission estimation
factors for criteria and hazardous air pollutants.  FIRE includes
information about industries and their emitting processes, the chemicals
emitted, and the emission factors themselves.  FIRE allows easy access
to criteria and hazardous air pollutant emission factors obtained from
the Compilation of Air Pollutant Emission Factors (AP 42), Locating and
Estimating (L and E) documents, and the retired AFSEF and XATEF
documents.

	The records required by this regulation must be retained by the owner
or operator for two years.

(c)	Small Entity Flexibility

	There is a distribution of business sizes for the businesses that have
coal preparation and processing plants.  EPA is not aware of any small
entities in the coal preparation and processing regulated industry.  The
subpart Y standards are applicable to facilities that process (i.e.,
break, crush, screen, clean, or dry) more than 181 megagrams (200 tons)
of coal per day.  Since NSPS are applicable to facilities built in the
future, it is not clear if any future affected facilities would be owned
by small entities.  However, due to technical considerations involving
the process operation and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  EPA considers these requirements the minimum needed to
ensure compliance and, therefore, cannot reduce them further for small
entities.  To the extent that larger business can use economies of scale
to reduce their burden, the overall burden will be reduced.

(d)	Collection Schedule.

	The specific frequency for each information collection activity within
this request is shown in Table 2:  Annual Burden of Reporting and
Recordkeeping Requirements, NSPS for Coal preparation and processing
plants (40 CFR part 60, subpart Y).

6.	Estimating the Burden and Cost of the Collection

	Tables 1a, 1b, and 1c [Year 1 Respondent Burden of Reporting and
Recordkeeping Requirements, NSPS for Coal Preparation and Processing
plants (40 CFR part 60, subpart Y), Year 2 Respondent Burden of
Reporting and Recordkeeping Requirements, NSPS for Coal Preparation and
Processing Plants (40 CFR part 60, subpart Y), and Year 3 Respondent
Burden of Reporting and Recordkeeping Requirements, NSPS for Coal
Preparation and Processing Plants (40 CFR part 60, subpart Y)] document
the computation of individual burdens for the recordkeeping and
reporting requirements applicable to the industry for the subpart
included in this ICR for each of the first 3 years.  Table 1d contains a
summary of the respondent burden costs and hours detailed in Tables 1a,
1b, and 1c.

	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.

	EPA 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.

(a)	Estimating Respondent Burden.

	The total number of respondents was estimated using data compiled from
the last 10 years of coal preparation and processing plant air permits
indicating the growth of and types of equipment used by the industry. 
Using this information it is estimated that an additional 22 new coal
preparation and processing plants will become subject to the regulation
over the 5-year NSPS review period.  Thus, it is estimated that there
would be 14 coal preparation and processing plants subject to the rule
amendments over the 3-year ICR period (22/3 = 13.2 rounded to 14).  All
of these 14 coal preparation and processing plants are estimated to be
constructed in the first year of the 3-year ICR period.  Furthermore,
based on industry trends for new coal preparation and processing plants,
it is assumed none of the new 14 plants will include the use of the
types of coal thermal dryers or pneumatic tables subject to the rule
amendments.

	All 14 of the coal preparation and processing plants are assumed to
consist of coal processing and conveying equipment, coal storage
systems, coal transfer and loading systems, and open storage piles.  The
burden estimates are based on the conservative control implementation
assumption that all affected owners and operators will choose to use
enclosures vented to fabric filters for the affected facilities at their
plants to comply with the rule.  In actuality many owners and operators
are expected to choose alternative controls allowed under the rule for
many affected sources, when applicable, such as fogging systems, wet
suppression, and passive enclosure containment systems (PECS) that do
not require Method 5 performance testing.  Both Method 5 and Method 9
testing are usually conducted by a contractor such that the cost of the
emissions testing is an annual operations and maintenance cost.  This is
assuming that no plant employs a certified smoke reader.  Finally, it is
assumed that 2 of the 14 coal preparation and processing plants will
have the type of coal truck dump affected facilities subject to the rule
amendments.

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 9,193
hours per year (Total Labor Hours from Tables 1a, 1b, and 1c).  These
hours are based on EPA studies and background documents from the
development of the regulation, EPA knowledge and experience with the
NSPS program, the previously approved ICR, and any comments received.

(b)  	Estimating Respondent Costs.

	(i)	Estimating Labor Costs. Labor rates and associated costs are based
on Bureau of Labor Statistics (BLS) data.  Technical, management, and
clerical average hourly rates for private industry workers were taken
from the United States Department of Labor, Bureau of Labor Statistics,
June 2009, “Table 2. Civilian Workers, by occupational and industry
group,” available at   HYPERLINK
"http://www.bls.gov/news.release/ecec.t02.htm" 
www.bls.gov/news.release/ecec.t02.htm .  Wages for occupational groups
are used as the basis for the labor rates with a total compensation of
$46.61 per hour for technical, $54.95 per hour for managerial, and
$23.04 per hour for clerical.  These rates represent salaries plus
fringe benefits and do not include the cost of overhead.  An overhead
rate of 110 percent is used to account for these costs.  The
fully-burdened hourly wage rates used to represent respondent labor
costs are: technical at $97.88, management at $115.40, and clerical at
$48.38.

	(ii)	Estimating Capital and Operations and Maintenance (O&M) Costs. The
annual operations and maintenance costs associated with the information
collection requirements will include the costs to conduct performance
tests and purchase monitoring, recordkeeping, and reporting supplies.  A
third-party contractor testing cost of $7,000 for each Method 5
performance test and $1,300 for each Method 9 performance test was used.
 The estimated number of affected facilities times the number of total
number of tests required for each affected facility per year resulted in
a total capital cost of approximately $882,000 for Method 5 testing and
$231,400 for Method 9 testing over the next three years.  Installing bag
leak detection systems for the fabric filters is included as a capital
cost.  The annual operation and maintenance costs associated with the
purchase of monitoring, recordkeeping, and reporting supplies is $38,290
over the next three years.

	(iii)  Annualizing Capital Costs. The capital cost associated with
procurement and installation of bag leak detection systems for the
fabric filters was annualized assuming a 7 percent interest rate and
10-year life (i.e., capital recovery factor [CRF] of 0.1424).  The total
annualized capital costs total $674,528.



(c)	Estimating EPA Burden and Cost.

	Table 2a: Year 1 Burden and Cost to the EPA—NSPS for Coal preparation
and processing plants, Table 2b: Year 2 Burden and Cost to the
EPA—NSPS for Coal preparation and processing plants, and Table 2c:
and Year 3 Burden and Cost to the EPA—NSPS for Coal preparation and
processing plants document the costs of this NSPS revision to EPA.  The
only costs to EPA are those costs associated with analysis of the
reported information.  Publication and distribution of the information
are part of the AFS program.  Examination of records to be maintained by
the respondents will occur as part of the periodic inspection of
sources, which is part of EPA’s overall compliance and enforcement
program.  Table 2d contains a summary of EPA burden costs and hours
detailed in Tables 2a, 2b, and 2c.  The average annual EPA cost during
the three years of the ICR is estimated to be $57,436.

	The EPA labor rates are from the Office of Personnel Management (OPM)
2009 General Schedule which excludes locality rates of pay.  These rates
can be obtained from Salary Table 2009-GS, available on the OPM website
at   HYPERLINK "http://www.opm.gov/oca/09tables/html/gs_h.asp" 
www.opm.gov/oca/09tables/html/gs_h.asp .  The government employee labor
rates are $16.04 per hour for clerical (GS-07, Step 1), $33.84 for
technical (GS-13, Step 1), and $47.03 for managerial (GS-15, Step 1). 
These rates were increased by 60 percent to include fringe benefits and
overhead.  The fully-burdened wage rates used to represent EPA labor
costs are: clerical at $25.66, technical at $54.14, and managerial at
$75.25.

(d)	Estimating the Respondent Universe and Total Burden and Costs.

	It is estimated that an additional 14 new coal preparation and
processing plants will become subject to the rule amendments in the next
three years.  The total annual number of responses for the monitoring,
recordkeeping, and reporting requirements in rule amendments is 315. 
This number is calculated by the 22 responses for the 14 new facilities
that would be subject to additional reporting and recordkeeping
requirement under the rule amendments. 

	The total annual labor costs are $2,601,624.  Details upon which this
estimate is based appear in Tables 1a, 1b, and 1c. 

(e)	Bottom Line Burden Hours and Cost Tables.

	The bottom line burden hours and cost tables for both EPA and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 29
hours per response.

(f)	Reasons for Change in Burden.

	The change in burden cost is primarily due to the additional
performance testing, monitoring, recordkeeping, and reporting costs
attributable to the rule amendments.  It is also due to the use of more
current labor rates for calculating the industry and EPA burden.

(g)	Burden Statement.

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 29 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 the Federal EPA.  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.

	EPA 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’s regulations are listed at
40 CFR part 9 and 48 CFR chapter 15.

	Send comments on the Agency’s need for this information, the accuracy
of the provided burden estimates, and any suggested methods for
minimizing a respondent burden, including the use of automated
collection techniques, to the Directory, Office of Environmental
Information, Collection Strategies Division (2822), U.S. Environmental
Protection Agency, 1200 Pennsylvania Avenue NW, Washington, DC 20460,
and to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street NW, Washington, DC 20503, marked
“Attention: Desk Officer for EPA.”  Include the EPA ICR tracking
number 1062.12 and OMB Control Number 2060-0122 for this ICR in any
correspondence.

Part B of the Supporting Statement

	This part is not applicable because statistical methods are not used in
data collection associated with the final rule.



Table 1a. Year 1 Respondent Burden and Cost-NSPS for Coal Preparation
and Processing Plants

See Table 1d for assumptions



Table 1b. Year 2 Respondent Burden and Cost-NSPS for Coal Preparation
and Processing Plants

See Table 1d for assumptions



Table 1c. Year 3 Respondent Burden and Cost-NSPS for Coal Preparation
and Processing Plants

See Table 1d for assumptions



Table 1d. Summary of Respondent Burden and Cost-NSPS for Coal
Preparation and Processing Plants

Respondent Burden

 (based on a total of 14 respondents)	Total Annual Labor Burden (Hours)
Total

Annual

Labor Costs	Total Annualized

Capital Costs	Total

Annual

O&M Costs	Total Annualized Costs

Year 1 (see Table 1a)	10,262	$968,103	$224,843	$428,790	$1,621,735

Year 2 (see Table 1b)	8,658	$816,761	$224,843	$361,450	$1,403,053

Year 3 (see Table 1c)	8,658	$816,761	$224,843	$361,450	$1,403,053

Nationwide 3-Year Total	27,578	$2,601,624	$674,528	$1,151,690	$4,427,842

Nationwide 3-Year Average	9,193	$867,208	$224,843	$383,897	$1,475,947

Average per Respondent	657	$61,943	$16,060	$27,421	$105,425



Respondent Assumptions for Burden and Cost Estimates

14	Total number of coal preparation plants constructed first 3 years
after rule applicability date

5	Average number of coal handling affected facilities except coal truck
dump per plant site subject to Subpart Y opacity limit 

3	Average number of coal handling affected facilities at plant site
using enclosure and mechanically vented to fabric filter

2	Average number of coal handling affected facilities using fabric
filter subject to BLD requirement

2	Number of plant sites with coal truck dumps subject to Subpart Y
opacity limit

10%	Percent of coal handling affected facilities subject to Subpart Y
opacity limit requiring 90-day repeat Method 9 performance test

50%	Percent of plant owners/operators electing to perform daily
walkthrough visual emission observations for compliance monitoring

50%	Percent of plant owners/operators electing to perform repeat Method
9 opacity testing for compliance monitoring





Table 2a. Year 1 Burden and Cost to the EPA—NSPS for Coal Preparation
and Processing Plants

Assumes 1 Method 5 and 2 Method 9 performance test site visits at $900
each for a total of 3 trips annually. The $900 includes the costs for
airline, car rental, hotel, and per diem for 3 days.

The Federal Employee Labor Rates are from salary table 2009-GS. The
loaded rates used are $33.84 for technical, 47.03 for manager, and 16.04
for clerical.



Table 2b. Year 2 Burden and Cost to the EPA—NSPS for Coal Preparation
and Processing Plants

Assumes 1 Method 5 and 2 Method 9 performance test site visits at $900
each for a total of 3 trips annually. The $900 includes the costs for
airline, car rental, hotel, and per diem for 3 days.

The Federal Employee Labor Rates are from salary table 2009-GS. The
loaded rates used are $33.84 for technical, 47.03 for manager, and 16.04
for clerical.



Table 2c. Year 3 Burden and Cost to the EPA—NSPS for Coal Preparation
and Processing Plants

Assumes 1 Method 5 and 2 Method 9 performance test site visits at $900
each for a total of 3 trips annually. The $900 includes the costs for
airline, car rental, hotel, and per diem for 3 days.

The Federal Employee Labor Rates are from salary table 2009-GS. The
loaded rates used are $33.84 for technical, 47.03 for manager, and 16.04
for clerical.



Table 2d. Summary of Burden and Cost to the EPA—NSPS for Coal
Preparation and Processing Plants

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