P.1 

OAR Box 1110 

Prepped by Ryan Dugan 

Document Number: 

8) IV-H-3 

Docket Number: 

A-82-39 

Printed 4/14/2008 1:23:55 PM Sheet 8 of 156 
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J ft^n-vi 

» **A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY / V^ If ^J 

I HMR^ | Office of Air Quality Planning and Standards 

\<4tilu£/ Research Triangle Park, North Carolina 27711 

%. m<r *(. PRO* 0 

2 0 JUN 1988 

MEMORANDUM 

SUBJECT: Request for OMB Clearance of Reporting and Recordkeeping 

Requirements Associated With New Source Performance Standards 

(NSPS) for Calciners and Dryers in Mineral Industries 

I: / Gerald A. Emi son, Di recto r c4^^vA-^^^<^^-^i>< * 

/^Offic e of Air Quality Planning and Standards (MD-10) 

FROM: 

TO: Thomas E. Kelly, Director 

Office of Standards and Regulations (PM-223) 

THRU: Deborah Thompson 

Office of Air and Radiation (ANR-443) 

Attached are the Standard Form SF-83 and supporting statement 

(four copies each) for requesting clearance of the reporting and 

recordkeeping requirements associated with the NSPS for calciners and 

dryers in mineral industries. 

Please review this request and forward it to the Office of 

Management and Budget. If you have any questions concerning this 

submittal, please contact Doug Bell at FTS 629-5568. 

2 Attachments 

cc: Doug Bell (MD-13) 

Kenneth Durkee (MD-13) 

Bob Kolbinsky (MD-13) 

Harvey Nozick (ANR-443) (w/o attachment) ^ 

Shirley Tabler (MD-13) ^^ ^ 

<$> <•'•> ' 
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SUPPORTING STATEMENT FOR STANDARD FORM 83 

REPORTING AND RECORDKEEPING REOUIREMENTS FOR THE 

NEW SOURCE PERFORMANCE STANDARDS FOR 

CALCINERS AND DRYERS IN 

MINERAL INDUSTRIES 

A. JUSTIFICATION 

1. Need for the Information Collection. The U. S. Environmental 

Protection Agency (EPA) is charged under Section 111 of the Clean Air 

Act, as amended, to establish standards of performance for new stationary 

sources that reflect: 

. . . application of the best technological system of continuous 

emission reduction which (taking into consideration the cost of 

achieving such emission reduction and any nonair quality health 

and environmental impact and energy requirements) the Administrator 

determines has been adequately demonstrated [Section 111(a)(1)], 

Section 111(e) further states: 

After the effective date of standards of performance promulgated 

under this Section, it shall be unlawful for any owner or operator 

of any new source to operate such source in violation of any 

standard of performance applicable to such source. 

In the Administrator's judgment, particulate matter emissions 

from calciners and dryers in mineral industries cause, or contribute 

significantly to, air pollution that may reasonably be anticipated to 

endanger public health or welfare. Consequently, new source performance 

standards (NSPS) have been developed for this source category and are 

currently being processed for proposal in the Federal Register. 

Certain records and reports are necessary to enable the 

Administrator to: (1) identify new, modified, or reconstructed sources 

subject to the standards and (2) ensure that standards based on best 

demonstrated technology (BDT) are being achieved. 
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2. Description and Practical Utility of the Information Collection 

Activity. 

a. Description of Information Collection Activity for Calciners 

and Dryers in Mineral Industries. 

Reports of start of construction, anticipated and actual startup 

dates, and physical or operational changes to existing facilities are 

required to identify affected sources. Reports of initial performance 

tests are necessary to determine that BDT is being used. Records of 

startups, shutdowns, or malfunctions in the operation of affected 

facilities and associated control equipment, records of opacity and 

control device monitoring parameters, and other information required by 

the standards are necessary to determine proper operation and maintenance. 

Failure to collect this information would allow circumvention of the 

standards. 

b. EPA Use of Data Collected. The information will be used by 

Agency enforcement personnel: (1) to identify new, modified, and reconstructed sources subject to the standards; (2) to ensure that BDT is being 

properly operated and maintained on a continuous basis. 

In addition, records and reports are necessary to enable EPA to identify 

plants that may not be in compliance with the standard. Based on reported 

information, EPA can decide which plants should be inspected and what records 

or processes should be inspected at the plant. The records that plants would 

maintain would indicate whether plants are properly operating and maintaining 

control equipment. 

3. Minimizing Burden. The Agency does not ask the respondents to reduce 

the data, only to submit the recorded logs semiannually for those periods of 

normal operation during which the 10-percent opacity limit for dry control 

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devices is exceeded or, for wet scrubbers, the pressure drop varies by 

more than 10 percent or the liquid flow rate varies by more than 20 percent. Thus, the burden will be minimized for those respondents who properly 

operate and maintain their system to comply with the standards. Ball clay 

rotary dryers, diatomite rotary dryers, feldspar fluid bed dryers, fuller's 

earth rotary dryers, gypsum rotary dryers, gypsum flash calciners, gypsum 

kettle calciners, industrial sand rotary dryers, kaolin rotary dryers, 

kaolin multiple hearth furnaces, perlite expansion furnaces, talc flash 

dryers, talc rotary dryers, titanium dioxide direct or indirect rotary 

dryers, and vermiculite expansion furnaces controlled by dry control devices 

are exempt from the semiannual reporting and recordkeeping requirements 

associated with opacity monitoring because neither continuous opacity 

monitoring systems (COM's) nor Method 9 procedures were determined to be 

reasonable after considering the costs and potential benefits associated 

with these requirements. 

4. Nonduplication. A computer search of the Federal Information 

Locator System indicated that there are no similar information requests 

being carried out by the Federal Govenment. A similar search of EPA's 

ongoing Information Collection Requests (ICR's) revealed no duplication of 

information gathering efforts. However, certain reports required by State 

or local agency can be provided to the Adminstrator in lieu of the reports 

required by the recommended standards. 

5. Consideration of Alternatives. There are no practical alternatives 

for gathering this information other than the alternative noted in paragraph 4. 

6. Minimizing of Burden for Small Business. Some small organizations 

may be affected by the NSPS. However, the information collection requirements 

are the minimum necessary to demonstrate compliance. The EPA has critically 

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reviewed the reporting and recordkeeping requirements associated with the 

recommended standards for calciners and dryers in mineral industries and 

has reduced reporting and recordkeeping requirements to data that are 

essential to both the respondent and EPA to ensure proper operation and 

maintanance of control equipment. 

Ball clay rotary dryers, diatomite rotary dryers, feldspar fluid 

bed dryers, fuller's earth rotary dryers, gypsum rotary dryers, gypsum 

flash calciners, gypsum kettle calciners, industrial sand rotary dryers, 

kaolin rotary dryers, kaolin multiple hearth furnaces, perlite expansion 

furnaces, talc flash dryers, talc rotary dryers, titanium dioxide direct 

or indirect rotary dryers, and vermiculite expansion furnaces controlled 

by dry control devices have been exempted from the semiannual reporting 

requirements because it was determined to be unreasonable to require the 

owners or operators of these facilities to monitor the opacity of dry 

control devices with either a COM or a certified visible emissions observer 

considering the costs and potential benefits. 

7. Consideration of Collection. Most of the information collection 

requirements for calciners and dryers in mineral industries are one-timeonly notifications or reports and cannot be performed on a less frequent 

basis. These requirements include the notification of construction or 

reconstruction, notification of anticipated startup, notification of actual 

startup, notification of the inital performance test, and the initial 

performance test report. 

Semiannual reporting of exceedances of the opacity limit for dry control 

devices, exceedances of operating parameter limits for wet scrubbers, and 

corrective maintenence required as a result of annual calibrations of COM 

or operating parameter monitoring devices is required to ensure compliance 

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with the standards on a continuous basis. The frequency of these reports 

was chosen by the Agency as the least frequent period that still provides 

an adequate margin of assurance that facilities subject to the standards 

will not operate for extended periods in violation of the standards. Les?; 

frequent information collection could allow longer periods of time before 

poor pollution control operating and maintenance conditions and violation 

of the standards would be identified. This delay would result in higher 

emissions and a decrease in air quality. 

8. Paperwork Reduction Act Guidelines. None of the guidelines in 

5 CFR 1320.6 are being exceeded. 

9. Consultations. Representatives of the mineral processing industries 

and members of the Expanded Shale, Clay, and Slate Institute; Gypsum Association; Industrial Gas Cleaning Institute; National Industrial Sand Association; 

Perlite Institute; The Refractories Institute; Lightweight Aggregate Industry; 

and State air pollution control agencies were consulted during the development 

of the standards. No major problems were encountered on which agreement could 

not be reached. Furthermore, Section 111(b) of the Clean Air Act requires that 

EPA review NSPS 4 years from the date of promulgation. This review will include 

an assessment of such factors as the need for integration with other programs, 

the existence of alternative methods, enforceability, improvements in emission 

control technology, and reporting requirements. For this reason, special 

consultation with respondents on a 3-year basis should not be necessary. 

10. Confidentiality. Any information submitted to the Agency for which a 

claim of confidentiality is made will be safeguarded according to the Agency's 

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, 1978; 44 FR 17674, 
P.8 

March 23, 1979). Furthermore, the type of information that is being collected 

by EPA is not expected to be considered confidential in most cases. 

11. Sensitive Questions. This section is not applicable because this 

ICR does not involve matters of a sensitive nature. 

12. Cost to the Government and to the Respondents. 

a. Cost to the Federal Government. The Federal Government will not 

incur any development costs because the information collection requirements 

were developed as an incidental part of developing the standards. Furthermore, 

the Federal Government will not incur any operation costs because reporting and 

recordkeeping requirements on the part of the respondents are required under 

Section 114 of the Clean Air Act. No Federal costs can be directly attributed 

to the ICR because publication and distribution of the information are part of 

the Compliance Data System as discussed in Section 15. Also, there will be no 

additional costs associated with examination of the records to be maintained 

by the respondents because the examination is already a part of EPA's periodic 

inspection of sources, which is part of EPA's overall compliance and enforcement program. The only costs that the Federal Government will incur are 

user costs associated with the analysis of the reported information. 

The average annual Federal cost during the first 3 years of the ICR is 

estimated to be $85,720.00. This cost is based on an average wage of $15.00 

per hour and a 110 percent overhead rate. Details upon which this estimate 

is based are presented in Tables 1 and 2 for affected facilities controlled 

by dry control devices and wet scrubbers, respectively. A breakdown of costs 

by cost category is presented below for the total of the two types of devices: 

Direct Personnel costs -- $83,538.00 

(including overhead) 

Other Direct Costs — 2,182.00 

(travel) 

Total — $85,720.00 
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b. Cost to the Respondents. Respondents are owners or operators 

of mineral calciner and dryer facilities for which construction, modification, or reconstruction will commence after the date of proposal of the 

standards. The cost to industry for a representative respondent for the 

first year is presented in Table 3. A representative respondent was 

assumed to be a respondent that would be required to fulfill all one-timeonly reporting and recordkeeping requirements and all semiannual and recurrent 

reporting and recordkeeping requirements associated with maintaining a COM 

for a dry control device or operating parameter monitoring devices for a wet 

scrubber. The total number of hours for all burden items would be 541 hours 

for a dry control device and 443 hours for a wet scrubber. The total number 

of hours for semiannual and recurrent burden items would be 102 hours per 

year for both a dry control device and a wet scrubber. -The total cost of 

ill burden items in the first year would be $17,040.00 for a dry control 

device and $13,955.00 for a wet scrubber. 

The total annual burden of reporting and recordkeeping requirements of 

affected facilities controlled by dry control devices or wet scrubbers in 

the first 3 years after proposal is presented in Tables 4 and 5, respectively. 

It is estimated that there will be approximately 43 respondents per year for 

the first 3 years after proposal. Of the 43 respondents, it is expected that 

34 will be using dry control devices and 9 will be using wet scrubbers. 

Respondents are required by law to submit one-time-only reports, which 

include all of the "notification" reports listed under Item 3E of Tables 3 

and 4. In addition, the respondents who are subject to monitoring requirements 

would be required to submit semiannual reports containing information on those 

periods of normal operation during which the 10 percent opacity limit for dry 

control devices is exceeded or, for wet scrubbers, the pressure drop varies by 

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more than 20 percent. These respondents also would be required to submit 

semiannual reports that document corrective maintenance required as a result 

of annual calibrations of monitoring devices. The total average annual cost 

to the respondents during the first 3 years of the ICR is estimated to be 

$680,482.00. This cost is based on a total average annual burden of 21,603 

person-hours for 43 respondents and an average wage of $15.00 per hour plus 

a 110 percent overhead rate. 

However, recurrent costs of the required reporting and recordkeeping to 

a representative respondent should be only a small fraction, of the first-year 

costs because 439 hours of the estimated 541 hours for dry control devices and 

341 hours of the estimated 443 hours for wet scrubbers are associated with the 

initial performance tests and notification requirements, which are required only 

once. In addition, of the 43 affected facilities estimated to come on line 

annually, 23 facilities are expected to be exempt from any monitoring requirements 

and will have to comply with only the initial notifications and performance tests. 

Costs of recurrent burden items to a representative respondent should be about 

$3,200.00 per year for both dry control devices and wet scrubbers. 

13. Estimation of Respondent Burden. Information collection requirements 

include the following one-time-only reports: 

-- Notification of construction, modification, or reconstruction no 

later than 30 days after commencement of such action; 

-- Notification of anticipated date of initial startup no more than 

60 days nor less than 30 days prior to such date; 

-- Notification of the date of initial startup within 15 days after 

such date; 

-- Notification of the date of an initial emission test within 30 

days of the effective date of the NSPS; and 
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-- Notification of the result of the initial performance test. It 

was assumed that 20 percent of the initial performance tests will 

fail to show compliance with the standards. Therefore, 20 percent 

of the tests will be repeated, and the reports will be submitted 

again. 

Information collection requirements also include the following semiannual 

and recurrent reports: 

-- Reports of exceedances of the opacity limit for dry control devices 

or exceedances of the operating parameter limits for wet scrubbers. 

— Reports of corrective maintenance required as a result of semiannual 

calibration of the COM for dry control devices or of operating 

parameter monitoring devices for wet scrubbers. 

It was assumed that each respondent would report one exceedance per year 

regardless of the type of control device used. 

One-time-only information requirements will affect 171 facilities controlled 

by dry control devices in the first 5 years after proposal or about 34 facilities 

per year and will affect 47 facilities controlled by wet scrubbers in the first 

5 years after proposal or about 9 facilities per year. Semiannual reports of 

exceedances of the opacity limit for dry control devices will affect about 7 

facilities in the first 3 years after proposal. Seventy facilities will not be 

required to submit reports of exceedance of the opacity limit because opacity 

monitoring requirements were determined not to be cost effective. Semiannual 

reports of exceedances of operating parameter limits for wet scrubbers will 

affect about 6 facilities in the first 3 years after proposal. Semiannual 

reports of corrective maintenance required as a result of semiannual calibrations 

of a COM for dry control devices or.operating parameter monitoring devices (OPMD) 

for wet scrubbers will affect 32 and 28 facilities, respectively, in the 

first 3 years after proposal. 

14. Reason for Change in Burden. This section is not applicable. 
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15. Scheduling. Information contained in the one-time-only reports will 

be entered into the Compliance Data System operated and maintained by EPA's 

Stationary Source Compliance Division. Data obtained during periodic 

visits by Agency personnel from records maintained by the respondents will 

be tabulated and published for internal Agency use in compliance and enforcement programs. A time schedule for the collection of information and 

publication of data is not applicable because reports and recordkeeping 

are triggered by action of the respondents. 

16. Standard Industrial Classifications (SIC). The SIC codes for the 

respondents affected by these proposed standards are 1051, 1446, 1452, 1453, 

1454, 1455, 1459, 1492, 1496, 1499, 2816, and 3295. 

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS 

This section is not applicable because statistical methods are not used 

in the data collection associated with this regulation. 

10 
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TABLE 1. ANNUAL ESTIMATE OF DIRECT PERSONNEL COSTS TO THE FEDERAL 

GOVERNMENT FOR FACILITIES CONTROLLED BY DRY CONTROL DEVICES 

BURDEN ITEM 

Hours 

per 

occurrence 

(A) 

Occurrences per 

facility 

per year 

(B) 

Hours per 

facility 

per year 

(C=AxB) 

Facilities Hours 

per year3 per year 

(D) (E=CxD) 

Dollars 

per year 

1. Initial Performance Test 120 120 2.7° 324 

2. Repeat Performance Test 

- Retesting Preparation 16 

- Retesting 120 

3. Litigation 

4. Excess Emissions 

2,080 

Enforcement Activities 120 

5. Report Review 

- Notification of 2 

construction/reconstruction 

- Notification of 2 

anticipated startup 

- Notification of 2 

actual startup 

- Notification of initial 2 

performance test 

- Review emission 8 

test report 

- Notification of 2 

demonstration of COM 

- Review COM or Method 9 16 

demonstration 

- Review excess emissions 8 

reports 

- Review no excess 2 

emissions reports 

TOTAL ANNUAL HOURS 

6. Travel Expenses for Tests Attended1* 

(1 person x 3.1 facilities/yr x 1 day/test 

x $50 per diem) + ($400/round trip x 3.1 

round trips/yr) 

7. Salary1 

(1 person x 1855.6 hours/yr x $31.50/h) 

TOTAL ANNUAL COSTS 

(travel expense + salary) 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

2 

2 

16 

120 

2,080 

120 

2 

2 

2 

2 

8 

2 

16 

16 

4 

3.4C 

0.3d 

0.3e 

0.1' 

34.2a 

34.2 

34.2 

34.2 

. 34.2 

7.89 

10.8n 

2.21 

8.6J 

54.4 

36 

624 

12 

68.4 

68.4 

68.4 

68.4 

273.6 

15.6 

172.8 

35.2 

34.4 

1,855.6 

1,395.00 

58,451.40 

59,846.40 

a Assume 34.2 affected facilities/yr. use dry control devices. 

° Assume enforcement personnel attend 8 percent of initial tests and 34.2 

affected facilities tested. 

c Assume 20 percent repeat performance test due to failure and 50 percent of 

failures cannot retest immediately. 

d Assume enforcement personnel attend 10 percent of retests. 

e Assume one facility in 100 will be involved in litigation. 

Assume 10.8 facilities are required to monitor opacity and 10 percent will 

have to retest as a result of excess emissions reports. 

9 Only 7.8 of the 34.2 affected facilities will be required to demonstrate a 

continuous opacity monitoring system (COM). 

n Assume 7.8 of the 34.2 affected facilities will be required to install a COM 

. and three facilities will have to perform daily visible emissions observations 

1 Assume 20 percent of 10.8 affected facilities with monitoring requirements have 

. excess emissions to report semiannually. 

J Assume 80 percent of 10.8 affected facilities with monitoring requirements have 

no excess emissions to report semiannually. 

k Tests attended = 2.7 initial tests + 0.3 repeat tests + 0.1 enforcement tests 

= 3.1. 

1 Direct personnel = $15.00/h plus 110 percent overhead = $31.50/h. 
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TABLE 2. ANNUAL ESTIMATE OF DIRECT PERSONNEL COSTS TO THE FEnERAL 

GOVERNMENT FOR FACILITIES CONTROLLED BY WET SCRUBBERS 

BURDEN ITEM 

Hours 

per 

occurrence 

(A) 

Occurrences per 

facility 

per year 

(B) 

Hours per 

facility Facilities 

per year 

(C=AxB) 

per yearc 

(0) 

Hours 

per year Hollars 

(E=CxD) per year 

1. Initial Performance Test 

2. Repeat Performance Test 

120 120 0.8h 96 

3. 

4. 

5. 

- Retesting Preparation 

- Retesting 

Litigation 

Excess Emissions 

- Enforcement Activities 

Report Review 

- Notification of 

16 

120 

2,080 

120 

2 

const ruction/reconstruct ion 

- Notification of 

anticipated startup 

- Notification of 

actual startup 

- Notification of initial 

performance test 

- Review emission 

test report 

- Notification of 

demonstration of OPMD 

- Review OPMD 

demonstration 

- Review excess emissions 

reports 

- Review no excess 

emissions reports 

2 

2 

2 

8 

2 

16 

8 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

2 

2 

16 

120 

2,080 

120 

2 

2 

2 

2 

8 

2 

16 

16 

4 

TOTAL ANNUAL HOURS 

6. Travel Expenses for Tests Attended1' 

(1 person x 1.75 facilities/yr x 1 day/test 

x $50 per diem) + ($400/round trip x 1.75 

round trips/yr) 

7. SalaryJ 

(1 person x 796.4 hours/yr x $31.50/h) 

TOTAL ANNUAL COSTS 

(travel expense + salary) 

0.9C 

0.09^ 

0.09e 

0.9f 

9.4a 

9.4 

9.4 

9.4 

9.4 

9.4 

9.4 

1.99 

7.5h 

14.4 

10.8 

187.2 

108 

18.8 

18.8 

18.8 

18.8 

75.2 

18.8 

150.4 

30.4 

30.0 

796.4 

787.50 

25,086.60 

25,874.10 

a Assume 9.4 affected facilities/yr. use wet scrubbers. 

b Assume enforcement personnel attend 8 percent of initial tests and 9.4 

affected facilities tested. c Assume 20 percent repeat performance test due to failure and 50 percent of 

failures cannot retest immediately. 

d Assume enforcement personnel attend 10 percent of retests. 

e Assume one facility in 100 will be involved in litigation, 

f Assume 10 percent will have to retest as a result of excess emissions reports. 

9 Assume 20 percent of the 9.4 affected facilities have excess emissions to report 

semiannually. n Assume 80 percent of 9.4 affected facilities have no excess emissions to report 

semiannually. „ n . . . 

1 Tests attended = 0.8 initial tests + 0.09 repeat tests + 0.9 enforcement tests 

= 1.75. 

j Direct'personnel = $15.00/h plus 110 percent overhead = $31.50/h. 
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TABLE 3. COST TO INDUSTRY FOR A REPRESENTATIVE RESPONDENT FOR THE FIRST YEAR 

Person-hours 

Person-hours per 

per Number of Respondent 

BURDEN ITEM occurrence occurences per year 

1. Reporting Requirements 

A. Read Instructions 1 1 1 

B. Required Activitie s 

- Initia l performance test 330 1 330 

- Demonstration of continuous 100,2a»

D

 l,i a 100,2a 

monitoring system (CMS) or 

operating parameter 

monitoring devices (OPMD) 

- Recalibration of CMS or 4 2 8 

OPMD (semiannual) 

C. Write Report 

- Notification of construction 2 1 2 

and reconstruction 

- Notification of anticipated 2 1 2 

startup 

- Notification of actual startup 2 1 2 

- Notification of initial per- 2 1 2' 

formance test 

- Reports of excess emissions 16 1 16-

(Recurrent) 

2. Recordkeeping Requirements 

A. Time to Enter Information 

- Records of startup, shutdown, 1.5 4 6' 

malfunction, etc. (recurrent) 

- Records of all measurements and 1.5 48 72-

information required by the 

standard (recurrent) 

TOTAL ANNUAL HOURS 541,443a 

TOTAL ANNUAL COSTSC $17,041.50a 

(Total annual hours x $31.50/h) $13,954.50a 

Approximately 54 percent of affected facilities will have no monitoring requirements. 

The numbers in the table are for those facilities that will have monitoring requirements, 

The first number corresponds to a typical facility controlled by a dry control device 

and the second number corresponds to a typical facility controlled by a wet scrubber. 

Assume it will take 1 hour each to demonstrate pressure loss and liquid flow rate 

monitoring devices. 

Personnel costs = $15.00/h + 110 percent overhead = $31.50/h. 
TABLE 4. ANNUAL RESPONDENT BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE PROMULGATED STANDARD 

(DRY CONTROL DEVICES) 

BURDEN ITEM 

Occurrences per Hours per Respondents 

Hours per respondent respondent per Hours per 

occurrence per year per year year3 year 

(A) (B) (C = AxB) (D) (E = CxD) 

Dollars 

per year^ 

(F) 

1. Applications 

2. Surveys A Studies 

3. Reporting Requirements 

A. Read Instructions 

B. Required Activities 

- Initial performance test 

- Repeat performance test 

N/AC 

N/A 

C. 

D. 

E. 

- Demonstration of COM 

- Method 9 test 

- Repeat of Method 9 test 

- Recalibration of COM 

(semiannual) 

Create Information 

Gather Existing Information 

Write Report 

330 

330 

100 

18 

18 

4 

Included in 3B 

Included in 3E 

Notification of construction/ 

reconstruction 

Notification of physical/ 

operational changes. 

Notification of anticipated 

startup. 

Notification of actual startup 

Notification of initial performance test. 

Notification of demonstration 

of COM. 

Reports of excess emissions 

(recurrent). 

Report of performance test 

Report of COM demonstration 

N/A 

2 

2 

16 

Included 

Included 

in 

in 

3B 

3B 

330 

330 

100 

18 

18 

8 

34.2 

34.2 

34.2 

68.4 

1,077.30 

34.2 

6.8^ 

7.8e 

26.4f 

5.39 

7.8e 

11,286.0 

2,244.0 

780.0 

475.2 

95.4 

62.4 

355,509.00 

70,686.00 

24,570.00 

14,968.00 

3,005.10 

1,965.60 

2,154.60 

2 

2 

2 

2 

32 

34.2 

34.2 

34.2 

7.8e 

10.8h 

68.4 

68.4 

68.4 

15.6 

345.6 

2,154.60 

2,154.60 

2,154.60 

491.40 

10,886.40 
TABLE 4 (CONTINUED) 

BURDEN ITEM 

Hours per 

occurrence 

(A) 

Occurrences per 

respondent 

per year 

(B) 

Hours per 

respondent 

per year 

(C=AxB) 

Respondents Hours 

per year3 per year 

(D) (E=CxD) 

Dollars 

per year 

4. Recordkeeping Requirements 

A. Read Instructions 

B. 

C. 

D. 

E. 

Plan Activities 

Implement Activities 

Develop Record System 

Time to Enter Information 

Records of startup, 

shutdown, malfunction, 

etc. (recurrent). 

- Records of all measurements, and information 

required by the standards 

(recurrent). 

- Records of excess emissions 

(recurrent). 

F. Train Personnel 

G. Audits 

TOTAL ANNUAL HOURS 

TOTAL ANNUAL COSTS 

Included in 

Included in 

Included in 

1.5 

1.5 

3A 

3B 

3B 

4

1" 

48J 

Included in 3E 

32 

N/A 

N/A 

6 

72 

32 

34.2 

10.8n 

3.0k 

205.2 

777.6 

96.0 

16,690.80 

6,463.80 

24,494.40 

3,024.00 

525,760.20 
a Assume one affected facility per respondent and 34.2 affected facilities per year that use dry control devices, 

b Hourly wage of $15.00 plus 110 percent overhead costs equals $31.50. This amount was multiplied by the hours per 

year in Column E. 

c N/A = not applicable 

d Assume 20 percent of initial performance tests must be repeated because the initial test failed. 

e Only 7.8 of the 34.2 affected facilities will be required to demonstrate a continuous opacity monitoring system 

(COM). 

F Assume 26.4 of the 34.2 affected facilities will not use COM's and will have to perform a Method 9 test. 

9 Assume 20 percent of Method 9 tests must be repeated because of failure. 

n Assume 7.8 of the 34.2 affected facilities will be required to install a COM and three facilities will have to 

perform daily visible emissions observations. 

} Assume respondent will shutdown twice per year for maintenance and twice per year for process malfunctions. 

J Assume 48 weeks per year of operation, 

k Assume three facilities have to have personnel certified for Method 9 testing. 

00 
TABLE 5. ANNUAL RESPONDENT BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE PROMULGATED STANDARD 

(WET SCRUBBERS) 

BURDEN ITEM 

Hours per 

occurrence 

(A) 

Occurrences per 

respondent 

per year 

(B) 

Hours per 

respondent 

per year 

(C = AxB) 

Respondents 

per 

year3 

(D) 

Hours per 

year 

(E = CxD) 

Dollars 

per year 

(F) 

h 

1. Applications 

2. Surveys & Studies 

3. Reporting Requirements 

A. Read Instructions 

B. Required Activities 

- Initial performance test 

- Repeat performance test 

- Demonstration of wet scrubber 

operating parameter monitoring 

devices (OPMD). 

- Repeat of demonstration of wet 

scrubber OPMD. 

- Recalibration of wet scrubber 

OPMD (semiannual). 

C. Create Information Included in 3B 

D. 

E. 

Gather Existing Information 

Write Report 

- Notification of construction/ 

reconstruction. 

- Notification of anticipated 

startup. 

- Notification of actual startup 

- Notification of initia l performance test . 

- Reports of excess emissions 

(recurrent). 

- Report of performance test 

- Report of wet scrubber OPMD 

demonstration 

Included 

2 

2 

2 

2 

16 

Included 

Included 

in 

in 

in 

3E 

3B 

3B 

1 

1 

1 

1 

2 

N/Ab 

N/A 

32 

9.4 9.4 

9.4 300.8 

296.10 

OO OO OO 00 

ro o o 

fD 

2 

4 

1 

1 

1 

1 

2 

330 

330 

2 

2 

8 

9.4 

1.9C 

9.4 

1.9d 

9.4 

3,102.0 

627.0 

18.8 

3.8 

75.2 

97,713.00 

19,750.50 

592.20 

119.70 

2,368.80 

2 

2 

ro ro 

9.4 

9.4 

9.4 

9.4 

18.8 

18.8 

18.8 

18.8 

592.20 

592.20 

592.20 

592.20 

9,475.20 
TABLE 5 (CONTINUED) 

BURDEN ITEM 

Hours per 

occurrence 

(A) 

Occurrences per 

respondent 

per year 

(B) 

Hours per 

respondent 

per year 

(C=AxB) 

Respondents 

per year3 

(D) 

Hours 

per year 

(E=CxD) 

Dollars 

per yearb 

4. Recordkeeping Requirements 

A. Read Instructions 

B. Plan Activities 

C. Implement Activities 

D. Develop Record System 

E. Time to Enter Information 

- Records of startup, 

shutdown, malfunction, 

etc. (recurrent). 

- Records of all measurements, and information 

required by the standards 

(recurrent). 

- Records of excess emissions 

(recurrent). 

F. Train Personnel 

Included in 3A 

Included in 3B 

Included in 3B 

1.5 

1.5 

4f 

489 

N/A 

6 

72 

9.4 

9.4 

56.4 

676.8 

1,776.60 

21,319.20 

Included in 3E 

G. Audits 

TOTAL ANNUAL HOURS 

TOTAL ANNUAL COSTS 

N/A 

N/A 

4,945.4 

155,780.10 

3 Assume 9.4 affected facilities per year use wet scrubbers, 

b N/A = not applicable 

c Assume 20 percent repeat performance test due to failure, 

d Assume 20 percent fail the initial demonstration of wet scrubber OPMD. 

e Assume it will take 1 hour each to demonstrate pressure loss and liquid flow rate monitoring devices, 

f Assume respondent will shutdown twice per year for maintenance and twice per year for process malfunctions. 

9 Assume 48 weeks per year of operation. 

n Hourly wage of $15.00 plus 110 percent overhead costs equals $31.50. This amount was multiplied by the hours 

per year in Column E. 

Tl 

ho 
P.21 

ATTACHMENT 

SOURCE DATA AND INFORMATION REQUIREMENTS 

General 

Regulation Provision 

Requi rement Reference Reference 

° Notification of construction, 60.7(a) 

reconstruction, modification, 

anticipated startup, actual 

startup, and demonstration of 

continuous monitoring system 

° Records of startup, shutdown, 60.7(b) 

or malfunction 

o 2 year retention of records 60.735(a) 60.7(d) 

° Report of performance test 60.8(a) 

data and results 

° Notification of performance 60.8(d) 

test 

° Records of opacity monitoring 60.735(a) 

results for dry control devices and 

and operating parameter monitoring 60.735(b) 

device (OPMD) results for wet 

scrubbers 

o Semiannual reports of monitoring 

results 60.735(c)