SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Mercury Cell Chlor-Alkali Plants 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR part 63, subpart
IIIII) (Renewal)

1(b)  Short Characterization/Abstract

	The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Mercury Emissions from Mercury Cell Chlor-Alkali plants were
promulgated on December 19, 2003.  These standards apply to existing
facilities and new facilities that are part of major source of hazardous
air pollutant (HAP) emissions or a part of an area source of HAP
emissions.  This 

information is being collected to assure compliance with 40 CFR part 63,
subpart IIIII.

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.

Any owner/operator subject to the provisions of this part shall maintain
a file of these measurements, and retain the file for at least five
years following the date of such measurements, maintenance reports and
records.  All reports are sent to the delegated state or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) regional office.

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

The chlorine production source category is divided into two
subcategories: (1) mercury cell chlor-alkali plants and (2) chlorine
production plants that do not rely upon mercury cells for chlorine
production (e.g., diaphragm cell chlor-alkali plants, membrane cell
chlor-alkali plants).  This ICR only addresses the mercury cell
chlor-alkali subcategory.  The affected facilities were required to be
in compliance with the standard within three years of the effective date
(promulgation date).

This ICR is based on nine existing mercury cell chlor-alkali plants in
the United States which were considered to be a part of the mercury cell
chlor-alkali plant source category for regulatory development.  It is
believed that no new mercury cell chlor-alkali plants will be
constructed over the next three years, an assertion which is based on
the fact that no new plants have been constructed in the United States
in over the last 30 years.  Future demand for chlor-alkali production is
anticipated to be met using other types of chlor-alkali cells that do
not result in any mercury emissions and, therefore, are not covered by
this standard.  Therefore, no new or reconstructed plants are
anticipated.

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, emissions from mercury cell
chlor-alkali plants cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP was promulgated for this source category at 40 CFR
part 63, subpart IIIII.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where 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
requirements.  Continuous emission monitors are used to ensure
compliance at all times.

The notifications required in the standards are used to inform the
Agency or delegated authority when a source becomes subject to the
requirements of the standard.  The reviewing authority may then inspect
the source to check if the pollution control devices are properly
installed and operated and the standard are being met.  The performance
test may also be observed.

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

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart IIIII.

3(a)  Nonduplication

 If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register at 71 FR 35652 on June 21, 2006. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

	The primary source of information as reported by industry, in
compliance with the recordkeeping and reporting provisions in the
standard, is the AFS (AIRS Facility Subsystem) which is operated and
maintained by EPA's Office of Compliance.  AFS is EPA’s database for
the collection, maintenance, and retrieval of all compliance data. 
Approximately nine respondents are currently subject to the regulation,
and our consultations with Agency industry experts regarding the growth
rate for the industry indicated that no additional respondents will
become subject to the regulation over the next three years.

	Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

	It is our policy to review any comments received since the last ICR
renewal including those submitted in response to the first federal
register notice and respond appropriately.  In this case, no comments
were received.

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards were collected less frequently, the proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

	These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five year records retention requirement is consistent
with the Part 70 permit program and the five year statute of limitations
on which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

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 the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
source category description.  The United States Standard Industrial
Classification (SIC) code for the respondents affected by the standards
is SIC 2812 which corresponds to the North American Industry
Classification System (NAICS) 325181 for source category description.

Standard	SIC Code	NAICS Code

40 CFR part 63, subpart IIIII	2812	325181



4(b)  Information Requested 

(i)  Data Items

In this ICR, all the data that is recorded or reported is required by 40
CR part 63, subpart IIIII.

A source must make the following reports:

Notifications

Initial startup or conversion of minor source to major source	63.9(b)

Application of construction or reconstruction	63.9(b)

Request for extension of compliance	63.9(c)

Subject to special compliance requirements 	63.9(d) 

Opacity and visible emissions observations 	63.9(f)

Performance tests	63.7(b), (c), 63.9(e)

Performance evaluation of continuous monitoring systems 	63.8(e), (f)

Continuous monitoring systems dates of operation	63.9(g)

Initial compliance	63.8252(e)

Compliance status	63.9(h)



Reports

Report of performance evaluations	63.7(e)

Immediate startup, shutdown and malfunction 	63.8254(c)

Semiannual reports 	63.8254(a), (b)



A source must keep the following records:

Recordkeeping

Notifications 	63.8256(a)

Maintain records of monitoring data, monitoring system calibration
checks, occurrence and duration of periods where the monitoring system
is malfunctioning or inoperative and system operations	63.8256(a),
63.8254(b)

Work practice standards	63.8254(c)

Periodic monitoring option	63.8254(d)



Electronic Reporting

In addition, regulatory agencies in cooperation with the respondents
continue to create reporting systems to transmit data electronically. 
However, electronic reporting systems are still not widely used.  At
this time, it is estimated that approximately 10 percent of the
respondents use electronic reporting.

(ii)  Respondent Activities	

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate opacity and/or parameter
monitors

Perform initial performance test 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

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 AIRS Facility Subsystem (AFS).



5(b)  Collection Methodology and Management

Following the notification of startup, the reviewing authority may
inspect the affect facility to determine whether the pollution control
devices are properly installed and operated.  Performance test reports
are used by the Agency to discern a source’s initial capability to
comply with the emission standard.  Data and records maintained by the
respondents are tabulated and published for use in compliance and
enforcement programs.  Immediate startup, shutdown and malfunction
notifications and reports alert the Agency to atypical operations
conditions which result in violations of the emission limitations. 
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 entered into the Air Facility
Subsystem (AFS) which is operated and maintained by EPA's Office of
Compliance.  AFS is EPA(s database for the collection, maintenance, and
retrieval of compliance data for approximately 125,000 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 records required by this regulation must be retained by the
owner/operator for five years.

5(c)  Small Entity Flexibility

	There are no small entities (i.e., small businesses) affected by this
regulation.  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
standard and only major sources of pollution were subsequently
regulated.

5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Respondent Burden Cost, NESHAP
for Mercury Cell Chlor-Alkali Plants (40 CFR part 63, subpart IIIII)

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 respondents. 
The individual burdens are expressed under standardized headings
believed to be consistent with the concept of burden under the Paperwork
Reduction Act.  Where appropriate, specific tasks and major assumptions
have been identified.  Responses to this information collection are
mandatory.

The Agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 14,558
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the 
regulation, Agency knowledge and experience with the NESHAP program, the
previously approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

This ICR uses the following labor rates: 

Managerial	$100.99 ($48.09 + 110%)

Technical	$87.97   ($41.89 + 110%)

Clerical	$43.81   ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2005, 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.

(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 regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitors and
include other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

Mercury Concentration CMS	$17,000	0	$0	$7,300	9	$65,700

Cell Room Mercury Monitoring System	$56,000	0	$0	$900	9	$8,100









$73,800



There are no total capital/startup costs associated with this ICR.  The
total operation and maintenance (O&M) costs for this ICR are $73,800.

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 $74,000 (rounded).

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
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 $35,455.

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

	

	Managerial	$57.20  (GS-13, Step 5, $35.75 x 1.6)

	Technical	$42.45  (GS-12, Step 1, $26.53 x 1.6)

	Clerical	$22.96  (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) 2006
General Schedule which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Annual Agency Burden and
Cost: NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR part 63,
subpart IIIII), below.

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 nine (9) existing respondents will be subject to
the standard.  It is estimated that no additional respondents will
become subject over the three period covered by this ICR.

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	9	0	0	9

2	0	9	0	0	9

3	0	9	0	0	9

Average	0	9

	9

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 nine (9).

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

Notifications 	0	0	0	0

Startup, Shutdown and Malfunction	9	0	0	0

Compliance Report (Semiannual)	9	2	0	18



	Total	18



The number of Total Annual Responses is eighteen (18).

The total annual labor costs are $1,277,382.  Details regarding these
estimates may be found in Table 1: Annual Respondent Burden and Cost,
NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR part 63, subpart
IIIII).

The total annual capital/startup and O&M costs to the regulated entities
are $74,000.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

The average annual Agency burden and cost over next three years is
estimated to be 801 labor hours at a cost of $35,455.  See Table 2:
Annual Agency Burden and Cost, NESHAP for Mercury Cell Chlor-Alkali
Plants (40 CFR part 63, subpart IIIII).

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

(i) Respondent Tally

The total annual labor costs are $1,277,382.  Details regarding these
estimates may be found in Table 1.  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 809 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $74,000 (rounded).  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 801 labor hours at a cost of $35,455.  See Table 2:
Annual Agency Burden and Cost, NESHAP for Mercury Cell Chlor-Alkali
Plants (40 CFR part 63, subpart IIIII).

6(f)  Reasons for Change in Burden

	The number of respondents has not changed and there are no program
changes.  However, there are adjustments for an increase in labor hours
and a decrease in costs as compared to the currently “active” ICR.

	The adjustments result from the transition by the respondents from
initial compliance with the standard to continuing compliance with the
standard.  The respondents achieved compliance over the past three years
by conducting performance tests and purchasing pollution monitors which
resulted in a smaller number of labor hours, but relatively high
capital/startup costs.  After achieving compliance, performance tests
are not required and capital/startup costs are lower because pollution
monitors are a one-time, initial expense.  However, the cost to maintain
the monitors increased.  The overall labor costs are higher because the
pollution levels must be recorded and compliance reports sent to the
appropriate regulatory authority.

	It should be noted that labor rates have increased over the past three
years which increases the labor hour dollar-cost.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 809 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA’s 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-2006-0421.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1752.  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-2006-0421 and OMB Control Number 2060-0542 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 Mercury Cell Chlor-Alkali Plants

(40 CFR Part 63, Subpart iiiii)



















A	 	 	B	C	D	E	 	 	F

	Labor Rates





INFORMATION COLLECTION ACTIVITY	RESPONDENT LABOR HOURS PER ACTIVITY PER
LABOR CATEGORY	 	 	RESPONDENT ACTIVITIES PER RESPONDENT PER YEAR
NUMBER OF RESPONDENTS	RESPONDENT HOURS PER YEAR	RESPONDENT LABOR COSTS
PER LABOR CATEGORY PER YEAR (AXBXC X RATE)	 	 	RESPONDENT LABOR COSTS
PER YEAR

48.09	41.89	14





 	Mgmt	Technical	Clerical	 	 	 	Mgmt @$100.99	Technical @$87.97
Clerical @$43.81	 









1. REQUIRED MONITORING, INSPECTIONS, AND RECORDKEEPING	 	 	 	 	 	 
 	 	 	 









 a. Read rule and instructions (a)	16	24	0	1	0	0	$0	$0	$0	$0









 b. Prepare Startup/Shutdown/Malfunction Plan (a)	8	32	4	1	0	0	$0	$0	$0
$0









 c. Prepare Washdown Plan (a)	4	16	4	1	0	0	$0	$0	$0	$0









 d. Prepare site-specific monitoring plan (a)	4	32	4	1	0	0	$0	$0	$0	$0









 e. Record date/time of washdowns	0	0.1	0	365	9	329	$0	$28,898	$0
$28,898









 f. Measure cell room mercury vapor level and record data	0	0.5	0	365	9
1,643	$0	$144,489	$0	$144,489









 g. Monitor vent mercury concentration and record CMS data, daily
averages, and deviations	0	0.5	0	365	9	1,643	$0	$144,489	$0	$144,489









 h. Perform vent mercury concentration CMS inspections and calibration
checks and record results	0	8	0	2	9	144	$0	$12,668	$0	$12,668

0.04383562	hr for 365 d/yr	4.297	tot vent+fug labor	3.7534	just fug
labor

 i. Perform twice daily inspections (for vessels and process equipment
problems, hydrogen and/or mercury vapor leaks at decomposers and
hydrogen piping up to the hydrogen header) and record information	0	0.75
0	730	9	4,928	$0	$433,467	$0	$433,467

1.5	hr for 365 d/yr



	 j. Inspect cell room floors for cracks, spalling, or other
deficiencies and record information	0	2	0	12	9	216	$0	$19,001	$0	$19,001

0.06575342	hr for 365 d/yr



	 k. Inspect pillars and beams for cracks, spalling, and other
deficiencies and record information	0	8	0	2	9	144	$0	$12,668	$0	$12,668

0.04383562	hr for 365 d/yr



	 l. Perform daily cell room inspections (for caustic leaks in caustic
system equipment and piping, liquid mercury spills or accumulations on
floors and surfaces, for liquid mercury leaks from vessels, piping, and
equipment in liquid mercury service) and record information	0	1.25	0	365
9	4,106	$0	$361,223	$0	$361,223









 m. Inspect equipment and piping in the hydrogen system from the header
to the last control device for hydrogen and/or mercury vapor leaks and
record information on these leaks	0	4	0	4	9	144	$0	$12,668	$0	$12,668

0.04383562	hr for 365 d/yr



	 n. Record information on handling and storage of mercury-containing
waste	0	0.25	0	365	9	821	$0	$72,245	$0	$72,245

	1241814.389





	 o. Record the mass of virgin mercury added to cells.	0	0.25	0	4	9	9	$0
$792	$0	$792









2. REQUIRED REPORTING	 	 	 	 	 	0	$0	$0	$0	 









 a. Read rule and instructions (a)	4	8	0	1	0	0	$0	$0	$0	$0









 b. Initial Notifications (a)	4	0	2	1	0	0	$0	$0	$0	$0









 c. Notification of Intent to conduct a performance test	2	0	1	2.58	0	0
$0	$0	$0	$0









 d. Notification of Compliance Status (a)	8	16	4	1	0	0	$0	$0	$0	$0









 e. Startup, Shutdown and Malfunction	8	16	4	0	0	0	$0	$0	$0	$0









 f. Compliance Reports	4	16	4	2	9	432	$7,271	$25,335	$2,170	$34,776









TOTAL	 	 	 	 	 	14,558	 	 	 	$1,277,382





























Note:



















(a) A one-time activity for each plant.











































Table 2: Annual Agency Burden and Cost, NESHAP for Mercury Cell
Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII)

 	A	 	 	B	C	D	E	 	 	F

 ACTIVITY	AGENCY LABOR HOURS PER ACTIVITY PER LABOR CATEGORY	 	 
AGENCY ACTIVITIES PER RESPONDENT PER YEAR	NUMBER OF RESPONDENTS	AGENCY
HOURS PER YEAR	AGENCY LABOR COSTS PER LABOR CATEGORY PER YEAR (AXBXC X
RATE)	 	 	AGENCY COSTS PER YEAR

 	Mgmt	Technical	Clerical	 	 	 	Mgmt @$57.20	Technical @$42.45
Clerical @$22.96	 

 a. Review Initial Notification	1	4	0	1	0	0	$0	$0	$0	$0

 b. Review Notification of Intent to conduct a performance test	1	4	0	3
0	0	$0	$0	$0	$0

 c. Observe performance tests	0	16	0	3	0	0	$0	$0	$0	$0

 d.  Review Notification of Compliance Status (including site-specific
monitoring plans and operation & maintenance plans) (a)	4	32	0	1	9	324
$2,174	$12,225	$0	$14,399

 e. Review performance test reports	1	8	0	3	9	243	$1,631	$9,169	$0
$10,800

 f. Review compliance reports	1	12	0	2	9	234	$1,087	$9,169	$0	$10,256

TOTAL	 	 	 	 	 	801	 	 	 	$35,455













Note:











(a) A one-time activity for each plant.













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