The National Emission Standards for
Hazardous Air Pollutants (NESHAP): Mercury Emissions from Mercury
Cell Chlor-Alkali plants were promulgated on December 19, 2003.
These standards apply to existing facilities and new facilities
that are part of major source of hazardous air pollutant (HAP)
emissions or a part of an area source of HAP emissions. This
information is being collected to assure compliance with 40 CFR
part 63, subpart IIIII. 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. 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 United States Environmental Protection Agency regional office.
The chlorine production source category is divided 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 ICR only addresses the
mercury cell chlor-alkali subcategory.
The number of respondents has
not changed and there are no program changes. However, there are
adjustments for an increase in labor hours and a decrease in costs
as compared to the currently "active" ICR. The adjustments result
from the transition by the respondents from initial compliance with
the standard to continuing compliance with the standard. The
respondents achieved compliance over the past three years by
conducting performance tets and purchasing pollution monitors which
resulted in a small number of labor hours, but a relatively high
capital/startup cost. After achieving compliance, performance tests
are not required and capital/startup costs are low because
pollution monitors are a one-time, initial expense. However, the
cost to maintain the monitors is increased. The overall labaor
costs are higher because the pollution levels must be recorded and
compliance reports sent to the appropriate regulatory
authority.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
2046ss03-v2.doc
NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR part 63, subpart IIIII) (Renewal)