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)