**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 
**NESHAP for Mercury**  **(40 CFR Part 6 1**  **, Subpart E**  **) (Renewal)**
**1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Mercury (40 CFR Part 6 1 , Subpart E ) (Renewal), EPA ICR Number 0113.11 , OMB Control Number 2060

- 0097 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Mercury (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 regulations apply to the new and existing facilities 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. New facilities include those that commenced construction, modification or reconstruction after the date of proposal. This information is being collect ed to assure compliance with 40 CFR part 61, subpart E

. 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 facilit y, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measure ments, 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 directl y to the U.S. Environmental Protection Agency (EPA) regional off

ice. 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). Over the next three ye ars, an average of 107 respondents (100 wastewater sludge incineration and drying plants and 7 cell chlor

- alkali plants) per ye ar will be subject to the standard , and no additional respondents per y ear will become subject to the stand ard. The Office of Management and Budget (OMB) approved the currentl y active I CR with following “Terms of Clearance ” (TOC) :2 When this I CR is renewed, EPA should review the respondent burden, universe, labor rates, and capital costs and ensure the se estimates have been updated.
EPA has addressed each item of concern in the TOC. All estimates and burden calculations for both the “Affected Public” and the Federal government have been reviewed and updated as necessary
. The “Affected Public” is p rivate sector businesses that are owned and operated by the mercury industry . The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)

. The burden to the “Federal Government” is attributed entirel y to work performed either by F ederal emplo ye es or government contractors; this burden is found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal).
**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 (HAP) . 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 equipme nt, 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 o n 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 Adminis trator may reasonabl y require. In the Administrator's judgment, HAP emissions from facilities that process mercury ore to recovery

mercury cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Ther efore, the NESHAP were promulgated for this source category at 40 CFR part 61, subpart E

.3

**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 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 t o 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 properl y installed and operated and leaks are being detected and repaired and the standard are being met. The performance test may also be observed. The required semiannual rep orts are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordke eping and reporting are required under 40 CFR part 61, subpart E

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Pub lic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (77 FR 47631) on August 9, 2012 . No comments were received on the burden published in the Fede ral Register

. **3(c) Consultations** The Agency

has consulted i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three y ears. The primary source4

of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information Sy stem (OTIS ) which is operated and maintained b y EPA's Office of Compliance. OTI S is EPA ’ s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts.
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. In developing this I CR, we contacted : the 1) Oli n Corporation , at ( 314 ) 480

- 1400 ; and 2) the Frankfort Wastewater Treatment Plant , at (317) 654

- 6133. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst F ederal Register n otice. 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 was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 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 (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, Septemb er 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard do not include sensitive questions.5

**4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are owners or operators of facilities that process mercury . The United States Standard Industrial Classification (SI C) codes for the respondents affected b y the standards, which corresponds t o the North American Industry Classification Sy stem (NAICS) codes, are listed below for this source category

. **Standard** ( **40 CFR P**  **art 61, S**  **ubpart E** ) **SIC Codes NAICS Codes**  All Other Basic Inorganic Chemical Manufacturing 2819 32518 0 Sewage Treatment Facilities 4952 2213 20 **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y NESHAP for Mercury (40 CFR P art 61, S ubpart E)

. A source must make the following reports:
**Notification s**  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 ph ys ical or operational change which may increase the emission rate. 61.15 Notification of performance tests. 61.13(c) and (f)

Perform annual stack emission test. 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), (b)(2) Performance of sludge test and determine mercury emissions. 61.54(a), (c), (d), (e) Notification of stack emission test. 61.53(a)(2), (b)(2), (c)(3), (d)(3) Certify monitoring device. 61.55(b)(5) Notification of an y parameter excursion that persists for 24 consecutive hours or l onger (Administrator must be notified within 10 day s). 61.55(b)(6)(i) and (ii) Sludge sampling 61.546 **Reports** Report of stack tests, emi ssion test results and sludge sampling data. 61.53(a)(3), (a)(4), (b)(3), (b)(4), (d)(4), (d)(5) and 61.54(e), (f) Optional submission of a plant

- specific monitoring, record keeping, and recording plan. 61.55(c) Sem i annual reports of parameter excursions. 61.55(b)(7), (b)(8) A source must keep the following records: **Recordkeeping** Maintain records of emission test results and sludge sampling data for a minimum of two y ears. 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 sy stem is malf unctioning 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 Some of the r espondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in coop eration with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 20 percent of the respondents use electronic reporting.

**(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 sy stems , Method 101A in Appendix B for sludge incineration and drying plants, or the alternative test Method 105 of7 **Respondent Activities** 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with an y previously applicable i nstructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this t ype of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping.
**5. The Inf**

**ormation Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following activities in connection with the acquisition, analy sis, 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to compl y 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 used8

for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered int o OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tr acking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for two y ears. **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 ty pes of control equipment employ ed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefo re, 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 collecti on activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paper work Reduction Act. Where ver 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 display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three y ears from these recordkeeping and reporting requirement s is estimated to be 20,490 ( Tota l Labor Hours from Table 1 below ).9

T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previousl y approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $121.44 ($57.83 + 110%) Technical $100.23 ($47.73 + 110%) Clerical $50.51 ($24.05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 201 2 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 p ercent to account for the benefit packages available to those employ ed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are no capital/startup or operation and maintenance costs.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only t ype of industry costs associated with the information collect ion activity in the regulations is labor cost. 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 anal ys is of the reported information. EPA's overall compliance and enforcement program i ncludes 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 y ears of the ICR is estimated to be $32,338. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% )10

These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages avai lable to government employ ees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs**  Based on our research for this I CR, on average over the next three ye ars, approximately 107 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar 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 that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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 0 107 0 0 107 2 0 107 0 0 107 3 0 107 0 0 107 Average 0 107 0 0 107
C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 107

. The total number of annual responses per ye ar 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 0 011 **Total Annual Responses** 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

. The total annual labor costs are $1,984,018

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)

. **6( e) Bottom Line Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 20,490 at a cost of $1,984,018

. Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 160 hours per response

. There are no capital/startup or O&M costs

. **(ii) The Agency Tally** The average annual Agency burden and cost over next three y ears is estimated to be 718 labor hours at a cost of $32,338 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)

. **6(f) Reasons for Change in Burden** There is no change in the burden hours in this I CR compared to the p revious I CR. This is due to two considerations : 1) the regulations have not changed over the past three years and are not anticipated to change over the next three ye ars ; and 2) the growth rate for the industry is very low, negative or non

- existent, so th ere is no significant change in the overall burden. There is an increase in costs for both the respondents and the Agency from the most recentl y approved ICR. The increase in burden cost is due to an increase in labor rates. This ICR uses updated labor rates from the U.S. Bureau of Labor Statistics to calculate burden costs.12

**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 b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; devel op, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any pr eviously

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 display s a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency 's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for t his I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0529 . 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 sy stem , select “search,” then key in the docket ID number identified in this document. The documents are al so 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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

- 2012

- 0529 and OMB Control Number 2060

- 0097 in any correspondence.
**Par t B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.13

**Table 1: Annual Respondent Burden and Cost**

**– NESHAP for**  **Mercury (40 CFR Part**  **61 , Subpart**  **E ) (Renewal)** 

**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)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **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 0.2 4.8 0 0 0 0 $0 C. Create information See 3B D. Gather existing information See 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 See 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 $133,623.60 Submit semiannual report i 8 2 16 7 112 5.6 11.2 $12,471.54 Notification of parameter excursions j 4 2 8 7 56 2.8 5.6 $6,235.77 Subtotal for Reporting Requirements **1,573 $152,331**  4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities See 3B C. Implement activities See 3B D. Develop record system Record operating parameters k 0.25 365 91.25 107 9,763.75 488.19 976.38 $1,087,222.85 Record mercury leaks l 0.25 365 91.25 7 638.75 31.94 63.88 $71,126.7314

**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)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

Record monitored parameters l 0.5 365 182.5 7 1,27 7.5 63.88 127.75 $142,253.46 Compile data for semiannual reports m 8 2 16 7 112 5.6 11.2 $12,471.54 Maintain data on mercury leaks n 0.5 52 26 7 182 9.1 18.2 $20,266.25 Maintain data on monitored parameters n 0.5 52 26 7 182 9.1 18.2 $20,266.25 E. Time to enter information Records of startup, shutdown, and malfunction o 1.5 53.5 80.25 53.5 4,293.38 214.67 429.34 $478,080.19
F. Audits N/A Subtotal for Recordkeeping Requirements **18,917 $1,831,687**  **TOTAL LABOR BURDEN AND COST 20,490**  **$1,984,018**
**Assu mptions:**  a We have assumed that there are approximately 107 existing sources currently subject to this rule. There will be no additiona l 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: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 ”T able 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, ”Total compensation.” The rates have been increased by 110 p ercent to account for the benefit packages available to those employed by private industry. c We have assumed that it will take 1 hour for a new respondent to read instructions. d We have assumed that it will take each new respondent 24 hours to complete initial performance test. e We have assumed that 20 percent of new respondents will repeat the perf ormance test due to failure. f We have assumed that each new respondent will take two hours to write notification reports on construction/reconstruction. g We have assumed that it will take each new respondent two hours each to write notification report s on initial startup and actual startup. h We have assumed that 100 0f the existing respondents will take 12 hours to w rite reports on the annual emission tests. i We have assumed that seven of the existing respondents will each have to submit semiannual reports. j We have assumed that seven of the existing respondents will w rite notification reports on parameter excursions two times per 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 times per year.15

o We have assumed that 50 percent of the respondents will each take 1.5 hours to record information of startup, shutdown, and malfunctions.16

**Table 2: Average Annual EPA Burden and Cost**

**– NESHAP for**  **Mercury (40 CFR Part**  **61 , Subpart**  **E ) (Renewal)** 

**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)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

Required activities New Plants Initial performance test c 24 1 24 0 0 0 0 $0 Repeat performance test 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 $20,729.80 Review semiannual reports h 8 2 16 7 112 5.6 11.2 $5,804.34 Review notification on monitored parameters i 8 2 16 7 112 5.6 11.2 $5,804.34 **TOTAL ANNUAL BURDEN AND COST 718**  **$32,338**
**Assu mptions:**  a We have assumed that there are approximately 107 existing sources currently subject to this rule. There will be no additiona l new sources 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 w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.57 for Managerial (GS

- 13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS

- 12, Step 1, $28.88 x 1.6), and $25.01 Clerical (GS

- 6, Step 3, $1 5.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “ 2012 General Schedule” which excludes locality rates of pay. c We have assumed that each respondent will take 24 hours to participate in the performance tests. d We have assume d that 20 percent of new respondents will have to repeat the performance tests due to failure. e We have assumed that it will take each new respondent 0.5 hours to review notification reports. f We have assumed that each respondent will take 8 hours to review test results.17

g We have assumed that each respondent will take 24 hours to participate in the performance test. h We have assumed that seven existing respondents will take eight hours two times per year to review semiannual reports. i We have ass umed that seven respondents will take eight hours each to revie w notification of monitored parameters.