SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Mercury Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII ) (Renew al)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Mercury Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (Renewal)

, EPA ICR Number 2046.08 , OMB Control Number 2060

- 0542

.

1(b) Short Characterization/Abstract

The National Emission Standards for Ha zardous Air Pollutants (NESHAP) for Mercury

Cell Chlor

- Alkali Plants ( 40 CFR Part 63, Subpart IIIII ) were proposed on July 3, 2002

, promulgated on December 19, 2003

, and amended on April 20, 2006

. These regulations apply to existing facilities and new facilities that are part of a major sour ce of hazardous air pollutant (HAP) emissions or part of an area source of HAP emissions

. A major source of HAP is one that has the potential to emit 10 tons or more of any HAP or 25 tons or more of total HAP per year; an area source is one with a potentia l to emit less than this. New facilities include those that commenced construction, modification or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63

, Subpart IIIII

.

In genera l, all NES HAP standards require initial notification report s, 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 malfuncti on 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

documents , and retain the file for at least five years following the generation date of such 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.

The “Affected Public” are owners and operators of mercury cell chlor

- alk ali plants.

The “ burden ” to the Affected Public may be found below in Table 1: Annual Respondent Burden

and Cost

– NESHAP for Mercury Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (Renewal). The “ burden ” to the Federal Government is attribu ted entirely to work performed by either Federal employees or government contractors

, and can be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Mercury Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (Renewal).

Based on our consultations with industry representatives, there is an average of one affected facilit y at each plant site and that each plant site has only one respondent (i.e., the2

owner/operator of the plant site).

The chlorine production source category is divi ded into two subcategories: (1) mercury

cell chlor

- alkali plants ; and (2) chlorine production plants that do not rely upon mercury cells for chlorine production (e.g., diaphragm cell chlor

- alkali plants, membrane cell chlor

- alkali plants).

This Informatio n Collection Request (ICR) only addresses the mercury cell chlor

- alkali subcategory.

Over the next three years, approximately two respondents 1 per year will be subject to

the se standard s , and no additional respondents per year will become subject to the se same standard s

. This estimate is based on the Agency’s November 2010 regulatory impact analysis (RIA) and consultation with industry experts.

The Office of Management and Budget ( OMB ) approved the currently active ICR without any “ Terms of Clearance ”

.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximu m 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

accorda nce 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 dir ect 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 e missions f rom mercury cell chlor

- alkali plants

either cause or contribute to air pollution that may reasonably be anticipated to endanger public

1 According to the Chlorine Institute, the two facilities are the ASHTA Chemicals facility in Ashtabula, O H, and the

PPG Industries facility in Martinsville, WV.3

health and/ or welfare. Theref ore, the NESHAP were promulgated for this source category at 40

CFR Part 63, Subpart IIIII

.

2(b) Practical Utility/Users of the Data

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

The notifications requi red 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

instal led and operated and/or leaks are being detected and repaired and the standard are being

met. The performance test may also be observed.

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

determinations.

3. Non

- duplication, Consultations, and Other Collection Criteria

The requested recor dkeeping an d reporting are required under 40 CFR Part 63

, Subpart

IIIII

.

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 th e 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 ( 80 FR 32116 ) on date. No comments were received on the burden published in the Federal Register

.4

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 years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts.

I ndustry trade associations and other interested parties were provided an opportunity to

comment on the burden associated with the se standard s as they were being developed and the se

same standard s ha ve been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, w e contacted 1) the Chlorine Institute

, at (703)

894

- 4140 ; and 2) the American Chemistry Council

, at ( 202 ) 249

- 7000.

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 Federal 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

coll ected less

- frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to

the standards. EPA believes that the five

- year records retention requirement is consistent with the Part 70 permit program and the five

- year statute of limitations on which the permit program is

based. T he retention of records for five years allow s EPA to esta blish 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 prev ented from pursuing the violators due to the destruction or

nonexistence of essential records

.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, C hapter 1, P art 2,

S ubpart 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

T he reporting or recordkeeping requirements in the standard do not include sensitive questions

.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are mercury cell chlor

alkali plants

. The United States Standard Industrial Classification ( SIC ) code for the respondents affected by the standards is SIC 2812, “Alkalis and Chlorine,” which corresponds to the North American Industry Classification System (NAICS ) code 32518 0 , “ Other Basic Inorganic Chemical Manufacturing ” for mercury cell chlor

- alkal i plants.

4(b) Information Requested

(i) Data Items

I n this ICR , all the data that is recorded or reported is required by the NESHAP for Mercury Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII)

.

A source must make the following reports:

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

Application of construction or reconstruction 63.9(b)

Request for extension of compliance 63.9(c)

Subject to special compliance requirements 63.9(d)

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

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

Continuous monitoring systems dates of operation 63.9(g)6

Notification s
Initial compliance 63.8252(e)

Compliance status 63.9(h)

Reports

Report of performance evaluations 63.7(g ), 63.10(d)(2)

Immediate startup, shutdown and malfunction 63.8254(c)

Semiannual reports 63.8254(a), (b)

A source must keep the following records:

Recordkeeping

Notifications and reports 63.8256(a), 63.10(b)(2)(xiv)

Maintain records of monitoring data, monitoring system calibration checks, occurrence and duration of periods where the monitoring system is malfunctioning or inoperative and system operations 63.8256(a), 63.8256(b), 63.8258

Work practice standards 63.8256(c)

Periodic monitoring option 63.8256(d)

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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

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

Perform initial performance test and repeat performance tests if necessary.7

Respondent Activities

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 pro cessing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests, if necessary.

Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO)

and ICIS.

5(b) Collection Methodology and Management

Following the 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 c omply with the8

emission standard s

. 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 mai ntenance, and for compliance

determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is

EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five

years.

5(c) Small Entity Flexibility

Half of the respondents are small entities (i.e., small businesses)

. Information from both Agency consultation with industry experts and the November 2010 RIA indicate that the ASHTA Chemicals facility in Ashtabula, OH, qualifies as a small entity. The impact on small entities (i.e., small business es) was taken into consideration during the development of the regulation. In the final rulemaking notice, EPA prepared a regulatory flexibility analysis (FRFA) which examined the impact of the final rule on small entities (68 FR 70925, December 19, 2003).

Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requi rements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The sp ecific frequency for each information collection activity within this request is

shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Mercury Cell

Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (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 ICR. The individual burdens are expressed under standardized he adings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.9

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 reco rdkeeping and reporting requirement s is estimated to be 3,760 hours ( Total Labor Hours from Table 1

below ). T hese hours are based on Agency studies and background documen ts from the development of the regulation s , Agency knowledge and experience with the N ESHAP program, the previously

- approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 66 + 110%)

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

2014

, “ 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 su ch as photocopying and postage.10

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

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

(A)

Continuous Monitoring

Device (B) Capital/Startup

Cost for One Respondent (C)

Number of

New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M

Costs for One Respondent (F)

Number of Respondents

with O&M (G) Total O&M, (E X F)

Mercury

Concentration

CMS $17,000 0 $0 $7,300 2 $14,600

Cell Room Mercury Monitoring System $56,000 0 $0 $900 2 $1,800

Total $16,400

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $ 0

. This is the total o f column D in the

above table.

The total operation and maintenance ( O&M) costs for this ICR are $ 16,400

. 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 $ 16,400

. These are 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 i ncludes activities such as the

examination of records maint ained by the respondents, periodic inspection of sources of

em issions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $ 2,510

.

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

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )11

These rates are from the Office of Personnel Management (OPM)

, 20 1 4 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 Mercury

Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (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

two existing respondents will be subject to the se standard s

. It is estimated that no additional respondents per year will become subject to these same standards

. The overall average number of responden ts, as shown in the table below, is two per year.

The number of respondents is calculated using the fol lowing table that addresses the three years covered by this ICR :

Number of Respondents

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A)

Number of New Respondents 1 (B)

Number of Existing Respondents (C) Number of Existing Respondents that keep

records but do not submit reports (D)

Number of Existing Respondents That

Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 2 0 0 2

2 0 2 0 0 2

3 0 2 0 0 2

Average 0 2 0 0 2

1 New respondents include sources with constructed, reconstructed and modified affected facilities.

C olumn 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 2

.

The total number of annual responses per year is calculated using the following table:12

Total Annual Responses

(A)

Information Collection Activity (B)

Number of Respondents (C)

Number of Responses (D) Number of Existing Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Responses E=(BxC)+D

Notifications 0 0 0 0

Startup, shutdown, and

malfunction 0 0 0 0

Compliance report (semiannual) 2 2 0 4

Total 4

The number of Total Annual Responses is 4.

The total annual labor costs are $378,000 (rounded)

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

– NESHAP for Mercury

Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (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 below , respectively, and summarized below.

(i) Respondent Tally

The total annual l abor hours are 3,760 hours

. Details regarding these estimates may be

found below in Table 1. Annual Respondent Burden and Cost

– NESHAP for Mercury Cell

Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (Renewal)

.

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 940 hours per response

.

The total annual capital/startup and O& M costs to the regulated entity are $16,400

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.13

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 55 labor hours at a cost of $ 2,510

. See below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Mercury Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) ( Renew al).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is a small adjustment increase in the respondent labor hours as currently identified

in the OMB Inventory of Approved Burdens . The increase is due to a change in assumption. In this ICR, we assume all existing sources will take some time each year to re

- familiarize themselves with the regulatory requirements.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 940 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide info rmation 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 inform ation, 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 Contro l

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 th e use of automated collection techniques, EPA has established a public docket for this ICR under

Docket ID Number EPA

- HQ

- OECA

- 2012

- 0691

. 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 avai lable 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 and14

Compliance Docket and Information Center in the EPA Docket C enter (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 (2 02) 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 Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Off icer for EPA. Please include the EPA Docket ID

Number EPA

- HQ

- OECA

- 2012

- 0691 and OMB Control Number 2060

- 0542 in any correspondence.

Part B of the Supporting Statement

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

information.15

Table 1: Annual Respondent Burden and Cost

– NESHAP for Mercury Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (Renewal)

Burden Item (A)

Technical

person

hours per

occurrence (B)

No. of

occurrences

per respondent

per year (C)

Technical

person

hours per respondent

per year (C=AxB) (D) Respondents

per year a (E)

Technical hours per

year (E=CxD) (F) Management

hours per

year (F=Ex0.05) (G)

Clerical hours per

year (G=Ex0.10) (H)

Total cost per year ($) b

1. Reporting requirements

a. Familiarize with regulatory requirements c 32 1 32 2 64 3.2 6.4 $7,401 .31

b. Prepare startup/shutdown/ malfunction plan d 32 1 32 0 0 0 0 $0

c. Prepare washdown plan d 16 1 16 0 0 0 0 $0

d. Prepare site

- specific monitoring plan d 32 1 32 0 0 0 0 $0

e. Record date/time of washdowns e 0.1 365 36.5 2 73 3.65 7.3 $8,442.12

f. Measure cell room mercury vapor level

and record data e 0.5 365 182.5 2 365 18.25 36.5 $42,210.61

g. Monitor vent mercury concentration and record CMS data, daily averages, and

deviations e 0.5 365 182.5 2 365 18.25 36.5 $42,210.61

h. Perform vent mercury concentration CMS inspections and calibration checks and

record results 8 2 16 2 32 1.6 3.2 $3,700.6616

i. Perform twice daily inspections (for vessels and process equipment problems, hydrogen and/or mercury vapor leaks at decomposers and hydrogen piping up to the hydrogen header) and record information f 0.75 730 547.5 2 1,095 54.75 109.5 $126,631.82

j. Inspect cell room floors for cracks, spalling, or other deficiencies and record

information g 2 12 24 2 48 2.4 4.8 $5,550.98

k. Inspect pillars and beams for cracks, spalling, and other deficiencies and record

information 8 2 16 2 32 1.6 3.2 $3,700.66

l. Perform daily cell room inspections (for caustic leaks in caustic system equipment and piping, liquid mercury spills or accumulations on floors and surfaces, for liquid mercury leaks from vessels, piping, and equipment in liquid mercury service)

and record information e 1.25 365 456.25 2 912.5 45.63 91.25 $105,526.52

m. Inspect equipment and piping in the hydrogen system from the header to the last control device for hydrogen and/or mercury vapor leaks and record information on these

leaks 4 4 16 2 32 1.6 3.2 $3,700.66

n. Record information on handling and storage of mercury

- containing waste e 0.25 365 91.25 2 182.5 9.13 18.25 $21,105.30

o. Record the mass of virgin mercury

added to cells i 0.25 2 0.5 2 1 0.05 0.1 $115.65

Subtotal for Reporting Requirements 3,682 $370,297

2. Recordkeeping requirements

a. Familiarize with regulatory requirements c See 1A

b. Initial notifications d 6 1 6 0 0 0 0 $017

c. Notification of intent to conduct a performance test d 3 1 3 0 0 0 0 $0

d. Notification of compliance status d 16 1 16 0 0 0 0 $0

e. Startup, shutdown, and malfunction 16 0 0 0 0 0 0 $0

f. Semiannual compliance reports i 16 2 32 2 64 3.2 6.4 $7,401.31

Subtotal for Recordkeeping Requirements 74 $7,401

TOTAL ANNUAL BURDEN AND COST (rounded) j 3,760 $378,000

TOTAL CAPITAL AND O&M COSTS (rounded) j $16,400

GRAND TOTAL (rounded) j $394,000

Assumptions:

a We have assumed that there are approximately 2 respondents subject to the rule, with no new sources expected over the next th ree

- years of this ICR.

b This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87 + 110%); and Clerical $51.79 ($24.66 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Tabl e 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. This ICR ass umes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.

c We assume all respondents will have to familiarize themselves with regulatory requirements each year

. d We assume that this is a one

- time only activity for new facilities.

e We have assume that information should be recorded 365 days per year.

f We have assumed that inspection should be performed two times per day for a total of 730 times per year.

g We have assumed that inspection should be done and recorded once per month.

h We have assumed that it will take 0.25 hours two times per year to record information.

i We have assumed that it will take each respondent 16 hours to two times per year to complete semiannual compliance reports.

j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.18

Table 2: Average Annual EPA Burden and Cost

– NESHAP for Mercury Cell Chlor

- Alkali Plants (40 CFR Part 63, Subpart IIIII) (Renewal)

Burden Item (A)

Technical

person

- hours

per

occurrence (B)

No. of

occurrences

per respondent

per year (C)

Technical

person

hours per respondent

per year (C=AxB) (D) Respondents

per year a (E)

Technical hours per

year (E=CxD) (F) Management

hours per

year (F=Ex0.05) (G)

Clerical hours per

year (G=Ex0.10) (H)

Total
cost per year ($) b

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

b. Review Notification of intent to conduct a performance test 4 3 12 0 0 0 0 $0

c. Observe performance tests 16 3 48 0 0 0 0 $0

d. Review Notification of Compliance Status (including site

- specific monitoring plans and operation & maintenance plans) c 32 1 32 0 0 0 0 $0

e. Review performance test reports c 8 1 8 0 0 0 0 $0

f. Review semiannual compliance

reports d 12 2 24 2 48 2.4 4.8 $2,512 .32

TOTAL ANNUAL BURDEN AND COST (rounded) e 55 $2,510

Assumptions:

a We have assumed that there are approximately 2 respondents subject to the rule, with no new sources expected over the next th ree

- years of this ICR. Facilities subject to the NESHAP rules are located in 13 States.

b This cost is based on the average hou rly labor rate as follows: Technical $46.67 (GS

- 12, Step 1, $29.17 + 60%); Managerial $62.90 (GS

- 13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS

- 6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Cler ical hours are 10 percent of Technical hours. These rates are from the OPM, 2014 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.

c We assume that this is a one

- time only cost.

d We assume that it will take 12 hours two times per year to review the semiannual compliance reports.19

e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.