SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Mercury (40 CFR part 61, subpart E) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NESHAP for Mercury (40 CFR part 61, subpart E) (Renewal)

	1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP),
for the regulations published at 40 CFR part 61, subpart E were proposed
on December 7, 1971, promulgated on April 6, 1973, and amended on
October 14, 1975, March 19, 1987 and October 17, 2000.  These standards
apply to the stationary sources which process mercury ore to recover
mercury, use mercury chlor-alkali cells to produce chlorine gas and
alkali metal hydroxide, and incinerate or dry wastewater treatment plant
sludge.

	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 (SSM)
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.  Semiannual summary reports are
also required.

	Any owner/operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
two 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).

	There are 107 respondents (one hundred wastewater treatment plant
sludge incineration and drying plants and seven cell chlor-alkali
plants), that will be subject to the regulation over the period covered
by this ICR, and it is estimated that no additional respondents will
become subject to the regulation in the next three years.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (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, HAP emissions from facilities in
semiconductor manufacturing cause or contribute to air pollution that
may reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP were promulgated for the source category at 40 CFR
part 61, subpart E.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard 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 standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	The notifications required in the standard 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, that leaks are being detected and
repaired, and that the 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.  Nonduplication, Consultations, and Other Collection Criteria

	The requested recordkeeping and reporting are required under 40 CFR
part 61, subpart E.

	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 (70 FR 55368) on September 20,
2005.  No comments were received on the burden published in the Federal
Register.

	3(c)  Consultations

	We were unable to get in contact with the Trade Associations.  After
repeated calls to the associations they did not return any of our calls.

	We also referenced the most recent ICR, consulted with the preparer of
the active ICR, and used other resources to obtain the most recent data
available.  We reviewed information available from the United States
Census Bureau, the Air Facility System (AFS), which is the primary
source of information regarding the number of existing sources, and
websites covering mercury.  We also consulted with EPA's Office of Air
Quality Planning and Standards, Information Transfer and Program
Integration Division.

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 that 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.

	3(e)  General Guidelines

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

	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 (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 no
include sensitive questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
mercury facilities that process mercury ore to recover mercury, use
mercury chlor-alkali cells to produce chlorine gas and alkali metal
hydroxide, and incinerate or dry wastewater treatment plant sludge. The
United States Standard Industrial Classification (SIC) codes for the
respondents affected by the standard are 2819 and 4952, which
corresponds to the North American Industry Classification System (NAICS)
codes 325188 and 22132 for mercury.

	4(b)  Information Requested

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

		(i)  Data Items

In this ICR, all the data that is recorded is required by NESHAP for
Mercury (40 CFR part 61, subpart E).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Notification and application of construction or modification	61.06 and
61.07

Notification of anticipated date of initial startup	61.09(a)(1)

Notification of actual startup	61.09(a)(2)

Notification of physical or operational change which may increase the
emission rate	61.15

Notification of performance tests	61.13(f)and (c)

Notification of annual stack emission tests	61.53(a)(1), (a)(3), (b)(1),
(b)(3), (c)(1), (c)(2), (d)(1), (d)(2), (d)(4), 61.12, 61.55(b)(1), and
(b)(2)

Performance of sludge test and determine mercury emissions	61.54(a),
(c)-(e)

Certify monitoring device	61.55(b)(5)

Notification of stack emission test	61.53(a)(2). (b)(2), (c)(3), and
(d)(3)

Semiannual reports of parameter excursions	61.55(b)(7)-(8)

Optional submission of a plant-specific monitoring, recordkeeping, and
recording plan	61.55(c)

Notification of any parameter excursion that persists for 24 consecutive
hours or longer (administrator must be notified within 10 days) 
61.55(b)(6)(i-ii)

Sludge Sampling	61.54

Report of stack test, emission test results and sludge sampling data
61.53(a)(3-4), (b)(3-4), (d)(4-5), and 61.54(e-f)



	A source must make the following reports:

Recordkeeping for 40 CFR part 61, subpart E

Maintain record of emission test results and sludge sampling data for a
minimum of two years 	61.53(a)(5), (b)(5), (d)(6), and 61.54(g)

Maintain records of monitoring data, monitoring system calibration
checks, and the occurrence and duration of periods where the monitoring
system is malfunctioning or inoperative.  Records shall be retained for
at least two years.	61.14(f)

Maintain records for two years	61.55(d)(2)

Monitor and record appropriate process or control device parameters once
each hour	61.55(b)(4)

Maintain daily records of all leaks or spills of mercury	 61.55(d)(1)



Electronic Reporting

	At the present, respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

	Also, 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 responses are done
electronically.

		(ii)  Respondent Activities

Respondent Activities

Read instructions.

Perform initial performance test, using Method 101 Appendix B for
mercury ore processing facilities, Method 102 for mercury chlor-alkali
plants with hydrogen streams, Method 101 Appendix B for mercury
chlor-alkali plants with cell room ventilation systems and Method 101A
in Appendix B for sludge incineration and drying plants, or the
alternative test Method 105 of Appendix B, 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.



	Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources still need
to evaluate the data, this type of monitoring equipment has
significantly reduced the burden associated with monitoring and
recordkeeping.

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

Observe initial performance tests and repeat performance tests if
necessary.

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 Air Facility System (AFS).



	5(b)  Collection Methodology and Management

	Following notification of startup, the reviewing authority might
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 standard.  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 entered into the 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 two 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
regulation.  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 requirements the minimum
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 in Table 1: Annual Industry Burden for NESHAP for
Mercury (40 CFR part 61,

subpart E).

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 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 20,490
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
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, March 19, 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 percent
to account for the benefit packages available to those employed by
private industry.

		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	The only type of industry costs associated with the information
collection activity in the regulations is labor costs.  There are no
capital/startup or operation and maintenance 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 activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $29,706.  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 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: Average Annual EPA
Burden, NESHAP for Mercury (40 CFR part 61, subpart E).

	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 107 existing respondents will be subject to the
standard.  It is estimated that no additional respondent per year will
become subject.  The overall average number of respondents, as shown in
the table below is 107 per year.

	The number of respondents is calculated using the following table which
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	(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	107	0	0	107

2	0	107	0	0	107

3	0	107	0	0	107

Average	0	107	0	0	107



	To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 107.  This number appears on the OMB 83-I form in block
13(a), Number of respondents.

 

	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 construction/reconstruction	0	1	0	0

Notification of initial startup	0	1	0	0

Notification of actual startup	0	1	0	0

Notification of initial performance test	0	1	0	0

Report of annual emission test	100	1	0	100

Submit semiannual report	7	2	0	14

Notification of parameter excursions	7	2	0	14



	Total	128



	The number of Total Annual Responses is 128.  This number is shown on
the OMB 83-I form in block 13(b), Total annual responses.

	6(e)  Bottom Line Burden Hours Burden 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 Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor costs are $ 1,735,420.55.  The annual labor costs
are not shown on the OMB 83-I form.  Details regarding these estimates
may be found in Table 1. Annual Respondent Burden and Cost, NESHAP for
Mercury (40 CFR part 61, subpart E).  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 160 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $0.  This number is shown on the OMB 83-I form in block 14(c), Total
annualized cost requested.  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 the next three years is
estimated to be 718 labor hours at a cost of $29,706.  See Table 2.
Annual Agency Burden and Cost, NESHAP for Mercury (40 CFR part 61,
subpart E).

	6(f)  Reasons for Change in Burden

	The increase in burden from the most recently approved ICR is due to an
adjustment.  The reason for the change in burden is related to the fact
that we are presently accounting for technical, managerial and clerical
burdens in this renewal package.  The previous version of the ICR
omitted the managerial and clerical burdens and used only technical.
There was also a change in the labor rate which contributed to the
increase in cost.

	There are no changes in the capital/startup and operations and
maintenance (O&M) costs from the previous ICR.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 160 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-2005-0071, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the Enforcement and Compliance Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301
Constitution Avenue, N.W., Washington, D.C.  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 Enforcement and
Compliance Docket and Information Center is (202) 566-1972.  An
electronic version of the public docket is at
http://www.regulations.gov.  This site can be used to submit or view
public comments, access the index listing of the contents of the public
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 above.  Also, you can send
comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, N.W., Washington, D.C. 20503,
Attention: Desk Officer for EPA.  Please include the EPA Docket ID
Number EPA-HQ-OECA-2005-0071 and OMB Control Number 2060-0097 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 (40
CFR Part 61, Subpart E) 

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $  b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting Requirements









    New Sources









   A. Read instructions c	1	1	1	0	0	0	0	$0

   B. Required activities 









          Initial performance test d	24	1	24	0	0	0	0	$0

          Repeat performance test e	24	0.20	4.8	0	0	0	0	$0

   C. Create information	Included in 3B







	   D. Gather existing information	Included in 3B







	   E. Write reports









   New Sources









         Notification of construction/                         
reconstruction f	2	1	2	0	0	0	0	$0

         Notification of initial startup g	2	1	2	0	0	0	0	$0

         Notification of actual startup g	2	1	2	0	0	0	0	$0

         Report of initial performance test	Included in 3B







	         Notification of initial performance test	2	1	2	0	0	0	0	$0

   Existing Sources









         Report of annual emission test h	12	1	12	100	1,200	60	120
$116,880.60

         Submit semiannual report i	8	2	16	7	112	5.6	11.2	$10,908.85

         Notification of parameter excursions j	4	2	8	7	56	2.8	5.6
$5,454.43

4.  Recordkeeping requirements









   A. Read instructions 	Included in 3A







	   B. Plan activities	Included in 3B







	   C. Implement activities 	Included in 3B







	   D. Develop Record System







 

         Record operating parameters k	0.25	365	91.25	107	9,763.75
488.19	976.37	$950,994.16

         Record mercury leaks l	0.25	365	91.25	7	638.75	31.94	63.87
$62,214.60

         Record monitored parameters l	0.5	365	182.5	7	1,277.5	63.87
127.75	$124,428.63

         Compile data for semiannual reports m 	8	2	16	7	112	5.6	11.2
$10,908.85

         Maintain data on mercury leaks n	0.5	52	26	7	182	9.1	18.2
$17,726.89

         Maintain data on monitored                           parameters
n	0.5	52	26	7	182	9.1	18.2	$17,726.89

   E. Time to enter information 









         Records of startup, shutdown, and                malfunction o
1.5	53.5	80.25	53.5	4,293.37	214.67	429.34	$418,176.65

   F. Audits	N/A







	Subtotals Labor Burden and cost  



	17,817.37	890.87	1,781.73	$1,735,420.55

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	20,490	$1,797,635



Assumptions:

a  We have assumed that the average number of respondent that will be
subject to the rule will be 107.  There will be no additional new source
that will become subject to the rule over the three-year period of this
ICR. 

b  This ICR uses the following labor rates: $100.99 per hour for
Executive, Administrative, and Managerial labor; $87.97 per hour for
Technical labor, and $43.81 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 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.

c  It will take each new respondent 1 hour to read instructions.

d We have assumed that it will take 24 hours for each new respondent to
complete the initial performance test.

e  We have assumed that 20 percent of new respondents will repeat the
performance test due to failure.

f  We have assumed that each new respondent will take two hours to write
notification report on construction/reconstruction.

g  We have assumed that it will take each new respondent two hours each
to write notification reports on initial startup and actual startup.

h  We have assumed that 100 of the existing respondents will take 12
hours to write report on the annual emission tests.

i  It is assumed that seven of the existing respondents will each have
to submit semiannual reports.

j  It is assumed that seven of the existing respondents will write
notification report on parameter excursions twice a year.

k  We have assumed that all respondents will record operating parameters
365 days per year.

l  We have assumed that seven respondents will each have to record
mercury leaks and monitored parameters.

m  We have assumed that seven respondents will each take eight hours to
compile data for semiannual reports.

n  We have assumed that each of the seven respondent will have to
maintain data on mercury leaks and monitored parameters 52 time
per-year.

o  We have assumed that 50 percent of the respondents will each take 1.5
hours to record information of startup, shutdown, and malfunctions.

Table 2:  Average Annual EPA Burden - NESHAP for Mercury (40 CFR Part
61, Subpart E) 

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

 per year	

(C)

EPA person

hours per

plant  per year

(C=AxB)	

(D)

Plants per year  a	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $ b

Required activities









   New Plants









        Initial performance tests c	24	1	24	0	0	0	0	$0

        Repeat performance tests c, d	24	0.2	4.8	0	0	0	0	$0

Report Review









   New Plants









        Notification of construction e	0.5	1	0.5	0	0	0	0	$0

        Notification of initial startup e	0.5	1	0.5	0	0	0	0	$0

        Notification of actual startup e	0.5	1	0.5	0	0	0	0	$0

        Notification of initial test e	0.5	1	0.5	0	0	0	0	$0

        Review test results f	8	1	8	0	0	0	0	$0

        Participate in performance test g	24	1	24	0	0	0	0	$0

   Existing Plants









        Annual emission test	4	1	4	100	400	20	40	$19,042.40

        Review semiannual reports h	8	2	16	7	112	5.6	11.2	$5,331.87

        Review notification on monitored               parameters i	8	2
16	7	112	5.6	11.2	$5,331.87

Subtotals Labor Burden and cost



	624	31.2	62.4	$29,706.14

 TOTAL ANNUAL BURDEN AND     COST (rounded)	

	

	

	

	718	$29,706



Assumptions:

    a  We have assumed that the average number of respondents that will
be subject to the rule will be 107.  There will be no additional new
source that will become subject to              the rule over the
three-year period of this ICR. 

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 $57.20 (GS-13, Step 5, $35.75 x 1.6),
Technical rate of $42.45 (GS-12, Step 1, $26.53 x 1.6), and Clerical
rate of $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.

c  We have assumed that it will take each respondent 24 hours to
participate in the performance tests.

    d  We have assumed that 20 percent of new respondent will have to
repeat performance tests due to failure.

    e  We have assumed that it will take each new respondent 0.5 hours
to review notification reports.

    f  It will take each respondent 8 hours to review test results.

   g  It will take 24 hours for each respondent to participate in the
performance test.

   h It is assumed that seven existing respondent will take eight hours
twice a year to review semiannual reports.

  i  We have assumed that seven respondent will take eight hour each to
review notification of monitored parameters.

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