SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal), 

EPA ICR Number 2383.03, OMB Control Number 2060-0659. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Gold 

Mine Ore Processing were proposed on April 28, 2010 (75 FR 22470) and promulgated on

February 17, 2011 (76 FR 13514). These regulations apply to existing and new gold mine ore 

processing and production facilities that use ore pretreatment, carbon processes with mercury

retorts, carbon processes without mercury retorts, and non-carbon concentrate processes. The 

regulation sets mercury emission limits for each of the affected processes at new and existing 

facilities. New facilities include those that commenced construction or reconstruction after the 

date of proposal. This information is being collected to assure compliance with 40 CFR part 63, 

subpart EEEEEEE.

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 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 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 U. S.

Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 21 respondents per year will be subject to these

standards. We expect all existing respondents have already complied with initial requirements, 

and that no new respondents per year will become subject to these same standards. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”

The “Affected Public” are owners and operators of gold ore processing and production 

facilities, which extract gold from mined ore. The “burden” to the Affected Public may be found 

below in Table 1: Annual Respondent Burden and Cost – NESHAP for Gold Mine Ore 
2

Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal). The “burden” to the Federal 

Government is attributed entirely to work performed by either Federal employees or government 

contractors and may be found below in Table 2: Average Annual EPA Burden and Cost –

NESHAP for Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (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. 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, mercury emissions from gold ore processing and 

production facilities either cause or contribute to air pollution that may reasonably be anticipated 

to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this 

source category at 40 CFR part 63, subpart EEEEEEE.

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. 
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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, leaks are being detected and repaired, and the standard is 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. Non-duplication, Consultations, and Other Collection Criteria

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

EEEEEEE.

3(a) Non-duplication

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, duplication does not exist.

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 (78 FR 35023) on June 11, 2013. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS 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 these standards as it was being developed and the 

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the Nevada Mining Association, 

at john.barber@goldcorp.com, 303-674-9400; and 2) the Counsel for Barrick Gold Corporation,
4

at mbarbanell@barrick.com, 416-307-3502.

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 first Federal Register notice. 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 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

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.
5

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and 

operators of gold ore processing and production facilities. The United States Standard Industrial 

Classification (SIC) code for the respondents affected by the standards is SIC 1041, which 

corresponds to the North American Industry Classification System (NAICS) code 212221 for 

Gold Ore Mining.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Gold 

Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE). 

A source must make the following reports:

Notifications

Notification of applicability 63.9(b)(2), 63.11648(a)

Notification of construction/reconstruction 63.9(b)(5)

Notification of special compliance requirements 63.9(d)

Notification of performance test 63.9(c)

Notification of opacity observations 63.9(f)

Additional CMS notifications 63.9(g)

Notification of compliance status 63.9(h)(1)

Notification of changes in information 63.9(j)

Reports

Malfunction reports 63.11648(d)

Performance test plan 63.7(c)(2)

CMS quality control plan 63.8(d)

CMS performance evaluation test plan/report 63.8(e)

Compliance report if deviation occurs 63.11648(c), 63.10(e)(3)

Annual performance test for mercury emissions 63.11646(a-b), 63.7

A source must keep the following records:
6

Recordkeeping

Records to support notifications 63.11648(e)(1),63.10(b)(2)

Records of monitoring data 63.11648(e)(2)

Records of monthly ore and concentrate throughput, operating 

hour for each process unit

63.11648(e)(3)

Electronic Reporting

Some of the respondents 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 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 continuous monitoring device for mercury. 

Perform initial performance test, Reference Method 29 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.
7

Respondent Activities

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 system). Although personnel 

at the source 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

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 Online Tracking Information System (OTIS). 

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 properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to 

comply with the emission standards (note the operating conditions under which compliance was 

achieved). 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 OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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.
8

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. A small 

entity for this industry is defined as: (1) a small business whose parent company meets the Small 

Business Administration size standards for small businesses found at 13 CFR 121.201 (less than 

500 employees for gold mine ore processing facilities); (2) a small, governmental jurisdiction 

that is a government of a city, county, town, school district, or special district with a population 

of less than 50,000; and (3) a small organization that is any not-for-profit enterprise that is 

independently owned and operated and is not dominant in its field. 

Although these standards will not affect any small entities, EPA nonetheless has tried to 

reduce the impact of this final rule on all of the affected sources. The standards include 

parametric monitoring requirements for mercury emission control devices that are common 

throughout the industry and in many cases are already required by State operating permits. 

The standards also require only the essential monitoring, recordkeeping, and reporting needed 

to verify compliance. 

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Gold Mine Ore 

Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal). 

6. Estimating the Burden and Cost of the Collection

Table 1 below 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. Wherever 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 2,358 hours (Total Labor Hours from Table 1

below). 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.
9

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2013, “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 type of industry costs associated with the information collection activities in the 

subject standard 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 monitor(s) and 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)

Monitoring 

equipment 1

$9,085 0 $0 $0 $0 $0

Method 29 Hg 

stack sampling 2

NA NA NA $9,420 17 $160,140

Material and 

supply 3

NA NA NA $3,190 21 $66,990

Total $0 $227,130

1 Annualized installed capital cost is $190,790 per year based on a capital recovery factor of 0.1424 (10 year life at 7%), and a 

total installed capital cost of $1.34 million for monitoring equipment. We assume no new sources will become subject over the 

three-year period of this ICR. 

2 Annualized cost for Method 29 stack sampling for mercury on 17 process units outside of Nevada. 

3 O&M costs are for materials and supplies (e.g., sorbent trap tubes, calibration standards) estimated as 5% of the installed capital 

cost ($1.34 million). 
10

The total capital/startup costs for this ICR are zero. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $227,130. This is 

the total of column G. 

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 $227,130. These are the

recordkeeping 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 

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 

$2,146. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Gold 

Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal). 

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

21 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 21 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR: 
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Number of Respondents

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 21 0 0 21

2 0 21 0 0 21

3 0 21 0 0 21

Average 0 21 0 0 21

1 New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard existing 

respondents submit initial notifications.

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 21. 

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

Initial notification of applicability 0 1 0 0

Initial notification of compliance status 0 1 0 0

Notification of performance test 0 1 0 0

Test plan 0 1 0 0

QA plan for CEMS 0 1 0 0

Startup, shutdown, and malfunction (SSM) plan 0 1 0 0

Annual performance test for Hg emissions 117 1 0 17

Semiannual reports of excess emissions 24.2 2 0 8.4

Total 25.4

1 Method 29 stack sampling for mercury on 17 process units outside of Nevada. Facilities in Nevada already perform annual 

sampling and analysis for mercury; consequently, those facilities will not incur any additional stack testing burden under this 

rule. 

2 We assume 20% of the 21 facilities will have excess emissions reports. 
12

The number of Total Annual Responses is 25 (rounded). 

The total annual labor costs are $217,994. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Gold Mine Ore 

Processing (40 CFR Part 63, Subpart EEEEEEE) (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 below in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 2,358 hours at a cost of $217,994. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost –

NESHAP for Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection 

of information is estimated to average 94 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $227,130. 

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 48

labor hours at a cost of $2,146. See below Table 2: Average Annual EPA Burden and Cost –

NESHAP for Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent burden and a decrease in Agency

burden. In addition, there is a decrease in total capital and O&M costs. This is not due to any

program changes. The changes in the burden and cost estimates occurred because the standards

have been in effect for more than three years and the requirements are different during the initial 

compliance period for new facilities, as compared to the on-going compliance period for existing 

facilities. The previous ICR reflected those burdens and costs associated with the initial 

activities for subject facilities. This includes purchasing monitoring equipment, preparing initial 

notification reports, and establishing recordkeeping systems. 

This ICR, by in large, reflects the on-going burden and costs for existing facilities. 

Activities for existing source include continuously monitoring of mercury and the submission of 

annual and semiannual reports. 
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6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 94 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 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-2013-0317. 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), WJC 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-2013-0317 and OMB Control Number 2060-0659 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Gold Mine Ore Processing (40 CFR Part 63, Subpart

 EEEEEEE) (Renewal)

Burden item

(A) (B) (C) (D) (E) (F) (G) (H)

Person 

hours per 

occurrence

No. of 

occurrences 

per 

respondent

Personhours per 

respondent 

per year

(C=A*B)

Respondents 

per year

Technical 

personhours per 

year 

(E=C*D)

Management 

personhours per 

year 

(E*0.05)

Clerical 

personhours 

per year 

(E*0.1)

Total Cost

per year a, $

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and Utilization of Technology 

and Systems 

N/A

4. Reporting Requirements

A. Read instructions b8 1 8 0 0 0 0 $0 

B. Required activities c N/A

Operating CEMS d0.25 365 91.25 4 365 18.25 36.5 $41,058.85

Weekly and monthly sampling 1 52 52 17 884 44.2 88.4 $99,441.17

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

Initial notification of applicability b2 1 2 0 0 0 0 $0 

Notification of compliance status b2 1 2 0 0 0 0 $0 

Request for compliance extension N/A

Site-specific test plan b4 1 4 0 0 0 0 $0 

Quality assurance plan for CEMS d8 1 8 0 0 0 0 $0 

Notification of performance test b2 1 2 0 0 0 0 $0 

Startup, shutdown, malfunction plan b4 1 4 0 0 0 0 $0 

Annual performance test for Hg emissions 8 1 8 17 136 6.8 13.6 $15.298.65

Semiannual report of excess emissions 8 2 16 4.2 67.2 3.36 6.72 $7,559.24
15

Subtotal for Reporting Requirements 1,670.03 $163,357.91

5. Recordkeeping Requirements 

A. Read instructions See 4A

B. Plan activities See 4A

C. Implement activities See 4A

D Develop record system 4 1 4 0 0 0 0 $0 

E. Time to enter information 0.5 52 26 21 546 27.3 54.6 $49,843.28 

F. Time to transmit or disclose information 0.25 2 0.5 21 10.5 0.53 1.05 $958.52 

G. Time to adjust existing ways 2 1 2 21 42 2.1 4.2 $3,834.10 

F. Time to train personnel 4 1 4 0 0 0 0 $0 

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 688.28 $54,635.90

TOTAL LABOR BURDEN AND COST (rounded) 2,358 $217,994

Assumptions:

a This ICR uses the following labor rates based on Department of Labor, Bureau of Labor Statistics (BLS) data “Table 2 Civilian Workers, by Occupational and Industry group. --

$102.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and $51.18 per hour for Clerical labor. The wages have been adjusted 

to account for an overhead rate of 110 percent.

b Assumes 21 existing facilities have already complied with initial rule requirements during the previous ICR period. 

c Rule will require operating CEMS, weekly sampling, and monthly sampling.

d Assumes 4 roaster stacks will be equipped with mercury CEMS, and that QA plan has already been developed during initial rule compliance. 
16

Table 2: Average Annual EPA Burden and Cost – NESHAP for Gold Mine Ore Processing (40 CFR Part 63, Subpart

 EEEEEEE) (Renewal)

Burden Item

(A) (B) (C) (D) (E) (F) (G) 

Person hours 

per 

occurrence

Occurrences 

per respondent

Plants per 

year 

Technical 

hours/year 

(D=A*B*C)

Management 

hours/year 

(E=0.05*D)

Clericalhours/year 

(F=0.1*D)

Total Cost

per year a, $

Observe performance test b16 1 1 16 0.8 1.6 $829.19 

Report Review:

 Initial notification of applicability c1 1 0 0 0 0 $0 

 Notification of compliance status c2 1 0 0 0 0 $0 

 Notification of performance test c2 1 0 0 0 0 $0 

Deviation reports N/A

 Startup, shutdown, malfunction plan c2 1 0 0 0 0 $0 

 Semiannual excess emissions report d 1 2 4.2 8.4 0.42 0.84 $435.33 

 Annual performance test report for 

 Hg emission

1 1 17 17 0.85 1.7 $881.02 

TOTAL ANNUAL BURDEN AND COST (rounded) 48 $2,146

Assumptions:

a These rates were be obtained from Salary Table 2013-GS available on the OPM website. 

b Assumes Agency staff will observe the performance test of one affected plant per year.

c Assumes 21 existing gold mine ore processing facilities have already complied with initial rule requirements.

d

 Assume 20% of existing facilities (21 x 20% = 4.2 facilities) will need to submit excess emissions reports.