SUPPORTING STATEMENT
NSPS for NONMETALLIC MINERAL PROCESSING (40 CFR, PART 60, SUBPART OOO) (FINAL RULE)
Part A of the Supporting Statement
1. Identification of the Information Collection
(a) Title and Number of the Information Collection.
This ICR is titled NSPS for Nonmetallic Mineral Processing (40 CFR part 60, subpart OOO). OMB has previously approved the information collection requirements for the existing rule under assigned OMB control number 2060-0050. This ICR has been assigned EPA ICR number 1084.10. This is a revision to the ICR based on the final rule for New Source Performance Standards Review for Nonmetallic Mineral Processing Plants.
(b) Short Characterization.
The New Source Performance Standards (NSPS) for the regulations published at 40 CFR Part 60, subpart OOO were proposed on August 31, 1983, and promulgated on August 1, 1985. These regulations apply to the following affected facilities in fixed or portable nonmetallic mineral processing plants: each crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, and enclosed truck or railcar loading station, which commenced construction, modification or reconstruction after August 31, 1983. Also, crushers and grinding mills at hot mix asphalt facilities that reduce the size of nonmetallic minerals embedded in recycled asphalt pavement and subsequent affected facilities up to, but not including, the first storage silo or bin are subject to the provisions of the subpart. The provisions of subpart OOO do not apply to the following operations: facilities located in underground mines; wet material processing operations; and plants without crushers or grinding mills. An affected facility that is subject to the provisions of subparts F or I or that follows in the process any facility subject to the provisions of subparts F or I of this part is not subject to the provisions of this part. In addition, the following plants are not subject to subpart OOO: fixed sand and gravel plants and crushed stone plants with capacities of 23 megagrams per hour (25 tons per hour) or less; portable sand and gravel plants and crushed stone plants with capacities of 136 megagrams per hour (150 tons per hour) or less; common clay plants and pumice plants with capacities of 9 megagrams per hour (10 tons per hour) or less. This information is being collected to assure compliance with 40 CFR part 60, subpart OOO.
In general, all 40 CFR Part 60 NSPS standards require initial notifications, performance tests, monitoring, and periodic reports. Owners or operators 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 sources subject to NSPS.
Any owner or operator subject to the provisions of 40 CFR Part 60 shall maintain a file of these measurements, and retain the file for at least two 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 (EPA) regional office.
This ICR amends the existing approved information collection based on the amendments to the Standards of Performance for Nonmetallic Mineral Processing Plant(s) (NMPP). These final amendments include revisions to the emission limits for NMPP affected facilities which commence construction, modification, or reconstruction on or after April 22, 2008. These final amendments for NMPP also include: additional testing and monitoring requirements for affected facilities that commence construction, modification, or reconstruction on or after April 22, 2008; exemption of affected facilities that process wet material from this final rule; changes to simplify the notification requirements for all affected facilities; and changes to definitions and various clarifications.
Approximately 4,365 nonmetallic mineral processing plants (NMPP) are currently subject to the regulation, and it is estimated that an additional 199 newly constructed NMPP will become subject to the regulation in the next three years.
2. Need for and Use of the Collection
(a) Need/Authority for the Collection.
The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:
. . . application of the best system of emission reduction which (taking into account the cost of achieving such reduction and any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).
The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every eight years.
In addition, section 114(a) states that the Administrator may require any owner or 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, particulate emissions from NMPP cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart OOO.
(b) Use/Users of the Data.
The control of emissions of particulates from NMPP requires not only the installation of properly designed equipment, but also the operation and maintenance of that equipment. Emissions of particulates from NMPP are the result of operation of the affected facilities. The subject standards are achieved by the capture of pollutant emissions using fabric filters or wet scrubbers or prevention of pollutant emissions through wet suppression. The notifications required in the applicable regulations 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 and the regulations are being met. Performance test reports are needed as these are the Agency's record of a source's capability to comply with the emission standards, and serve as a record of the operating conditions under which compliance was achieved. The information generated by the monitoring, recordkeeping and reporting requirements described in this ICR is used by the Agency to ensure that facilities affected by the NSPS continue to operate the control equipment and achieve compliance with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable regulations, as required by the Clean Air Act. The information collected from recordkeeping and reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court.
3. Nonduplication, Consultations, and Other Collection Criteria
(a) Nonduplication.
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 their 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, no duplication exists.
(b) Public Notice Required Prior to ICR Submission to OMB.
This section is not applicable because this is a rule related ICR.
(c) Consultations.
During development of the amendments, EPA held meetings and conference calls with representatives of nonmetallic mineral trade associations, individual companies, and State agencies. Consultations were made with the following trade associations: National Stone, Sand, and Gravel Association (NSSGA), Industrial Minerals Association-North America (IMA-NA), Utility Air Regulatory Group (UARG), Georgia Mining Association (GMA), and China Clay Producers Association (CCPA). More information is available in the docket for this rulemaking. In addition, public comments were requested through the proposed rulemaking notice.
(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 likelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease.
(e) General Guidelines.
None of these reporting or recordkeeping requirements violate any of the regulations established by the Office of Management and Budget (OMB) at 5 CFR 1320.5.
(f) Confidentiality.
The required information has been determined not to be confidential. However, 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).
(g) Sensitive Questions.
None of the reporting or recordkeeping requirements contain sensitive questions.
4. The Respondents and the Information Requested
(a) Respondents/NAICS Codes.
The North American Industry Classification System (NAICS) codes for respondents affected by the standards are listed in the following table.
Regulation |
NAICS Codes |
40 CFR part 60, subpart OOO |
212311 |
212312 |
|
212313 |
|
212319 |
|
212321 |
|
212322 |
|
212324 |
|
212325 |
|
212391 |
|
212393 |
|
212399 |
|
221112 |
|
324121 |
|
327121 |
|
327122 |
|
327123 |
|
327124 |
|
327310 |
|
327410 |
|
327420 |
|
327992 |
|
331111 |
(b) Information Requested.
(i) Data Items, Including Recordkeeping Requirements. All data in this ICR that is recorded and/or reported is required by NSPS for Nonmetallic Mineral Processing (40 CFR part 60, subpart OOO).
A source must make the following reports:
Reports for 40 CFR part 60, subpart OOO |
|
Notification of actual startup. |
60.7(a)(3), 60.676(i) |
Initial performance test results. |
60.8(a), 60.676(f) |
Initial performance test. |
60.8(d), 60.672 |
Physical or operational change. |
60.7(a)(4) |
Repeat performance test results. |
60.8(a), 60.11, 60.675 |
A source must maintain the following records:
Recordkeeping for 40 CFR part 60, subpart OOO |
|
Startups, shutdowns, malfunctions, periods where the continuous monitoring system is inoperative. |
60.7(b) |
Records are required to be retained for two (2) years. |
60.7(f) |
Records of ongoing monitoring. |
60.7(f), 60.674(b), 60.674(c) |
Records of replacement activities |
60.670(d), 60.676 |
(ii) Respondent Activities. The respondent activities required by subpart OOO are listed in the following tables.
Respondent Activities |
Read instructions. |
Perform initial performance test using appropriate Reference Method, 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. |
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. |
Transmit, or otherwise disclose the information. |
5. The Information Collected: Agency Activities, Collection Methodology, and Information Management
(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 AIRS Facility Subsystem (AFS) database. |
(b) Collection Methodology and Management.
Following notification of startup, the reviewing authority might 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 standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
Information contained in the reports is entered into the AIRS Facility Subsystem (AFS) which is operated and maintained by EPA's Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of compliance and annual emission inventory data for over 100,000 industrial and government-owned facilities. EPA uses the AFS 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 or operator for two years.
(c) Small Entity Flexibility.
A majority of the new affected facilities are estimated to be small entities. The impact on small entities (i.e., small businesses) was taken into consideration during the development of the revised regulation by exempting wet material processing operations, simplifying certain notification requirements, and selecting relatively low-cost repeat testing and monitoring provisions. In addition, certain plants operating at small capacities were exempted from subpart OOO due to economic considerations when the standards were originally developed. 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 requirements the minimum needed to ensure compliance and, therefore, cannot reduce them further for small entities.
(d) Collection Schedule.
The specific frequency for each information collection activity within this request is shown in Table 2: Annual Burden of Reporting and Recordkeeping Requirements, NSPS for Nonmetallic Mineral Processing (40 CFR part 60, subpart OOO).
6. Estimating the Burden and Cost of the Collection
Table 2 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. Where 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.
(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 11,330 hours per year (Total Labor Hours from Table 2: Annual Burden of Reporting and Recordkeeping Requirements, NSPS for Nonmetallic Mineral Processing (40 CFR part 60, subpart OOO). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously approved ICR, and any comments received.
(b) Estimating Respondent Costs.
(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for private industry workers were taken from the United States Department of Labor, Bureau of Labor Statistics, March 2008, “Table 2. Civilian Workers, by occupational and industry group”. The most recent version is available at www.bls.gov/news.release/ecec.t02.htm but previous editions are available at http://www.bls.gov/schedule/archives/all_nr.htm and the docket for this rulemaking. Wages for occupational groups are used as the basis for the labor rates with a total compensation of $44.92 per hour for technical, $53.04 per hour for managerial, and $22.41 per hour for clerical. These rates represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully-burdened hourly wage rates used to represent respondent labor costs are: technical at $94.33, management at $111.38, and clerical at $47.06.
(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. The capital costs associated with the information collection requirements will include the costs to conduct performance tests and purchase file cabinets for keeping records. The rule will require an initial performance test for each new NMPP. There are no O&M costs for this rulemaking.
Performance tests using Method 5 and Method 9 are usually conducted by a contractor such that the cost of the emissions testing is a capital cost. A testing cost of $7,000 for Method 5 tests and $216.67 for a 30-minute Method 9 tests was used. The total costs for performance testing were calculated for each industry sector covered by subpart OOO. Growth in each of the NMPP sectors was estimated using model plants and recent (e.g., 2005/2006) production data available from the U.S. Geological Survey (USGS) and model plant parameters used in development of the original promulgated NSPS. The anticipated number of new sources in each sector combined with the number of tests required for each type of model plant resulted in a total capital cost of $1.0 million for Method 5 testing and $872,000 for Method 9 testing over the next three years. The costs for each industry sector are shown in Table 1.
Table 1. Performance Testing Costs by Industry Sector Over 3 Year Period
Industry Sector |
Number of new NMPP over 3 year period |
Number of emission points per NMPP |
Method 5 costs |
Method 9 costs |
Total costs |
Crushed / broken stone, Sand / Gravel |
183 |
22 |
NA |
$872,300 |
$872,300 |
Other sectors |
16 |
9 |
$1,008,000 |
NA |
$1,008,000 |
|
|
|
|
|
|
TOTALS |
199 |
|
$1,008,000 |
$872,300 |
$1,880,300 |
(iii) Annualizing Capital Costs. The annualized capital costs include the costs for performance tests and file cabinets. The capital cost associated with testing was annualized assuming a 7 percent interest rate and 5-year life (i.e., capital recovery factor [CRF] of 0.244). To calculate annualized costs, the CFR was multiplied by the capital cost of testing. The annualized capital cost for file cabinets was calculated using a 7 percent interest rate and a 15-year life (i.e., CRF of 0.1098). The total annualized capital costs total $154,577.
(c) Estimating Agency Burden and Cost.
The only costs to the Agency are those costs associated with analysis of the reported information. Publication and distribution of the information are part of the AFS program. Examination of records to be maintained by the respondents will occur as part of the periodic inspection of sources, which is part of EPA's overall compliance and enforcement program.
The Agency labor rates are from the Office of Personnel Management (OPM) 2008 General Schedule which excludes locality rates of pay. These rates can be obtained from Salary Table 2008-GS, available on the OPM website at www.opm.gov/oca/08tables/html/gs_h.asp. The government employee labor rates are $14.96 per hour for clerical (GS-6, Step 3), $27.65 for technical (GS-12, Step 1), and $37.27 for managerial (GS-13, Step 5). These rates were increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates used to represent Agency labor costs are: clerical at $23.94, technical at $44.24, and managerial at $59.63.
(d) Estimating the Respondent Universe and Total Burden and Costs.
Approximately 4,365 NMPP are currently subject to the regulation. Growth in each of the NMPP sectors was estimated using model plants and the most recent production data available from the USGS and model plant parameters used in development of the original promulgated NSPS. Using this information, 332 new plants are projected over the 5-year NSPS review period. Thus, it is estimated that an additional 66.4 NMPP per year will become subject to the regulation over the three year ICR period (332/5 = 66.4). Of these 66.4 NMPP, all are estimated to be newly constructed (either as new greenfield plants or as capacity additions to existing plants). In the second and third year, these sources increase the average number of existing sources by 66.4 per year. Subpart OOO contains a “like-for-like” replacement provision which allows individual existing affected facilities within a NMPP to be replaced with new affected facilities of equal or smaller size without triggering subpart OOO. Therefore, no modifications or reconstructions are projected in addition to the 66.4 projected new/expanded plants.
The total annual number of responses for the monitoring, recordkeeping, and reporting requirements in subpart OOO is 4,853. This number is calculated by summing the product of columns B and D for each of the activities listed in 4B and 4E of Table 2.
The total annual labor costs are $1,030,642. Details upon which this estimate is based appear in Table 2.
(e) Bottom Line Burden Hours Burden Hours and Cost Tables.
(i) Respondent Tally. The bottom line respondent burden hours and costs, presented in Table 2 are calculated by adding person-hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column.
The average annual burden for the monitoring, recordkeeping, and reporting requirements in subpart OOO is 11,330 hours, with annual labor costs of $1,030,642; and annualized capital costs of $154,577.
(ii) The Agency Tally. The average annual Federal Government cost is $1,075,683 for 24,317 hours for subpart OOO. The bottom line Agency burden hours and costs presented in Table 3 are calculated by adding person-hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column.
(iii) Variations in the Annual Bottom Line. This section does not apply since no significant variation is anticipated.
(f) Reasons for Change in Burden.
The change in burden cost from the most recently approved ICR is due to seven reasons. First, the number of NMPP projected to become subject to subpart OOO in the next 3 years is smaller than the previously approved ICR. Second, the 60.7(a)(1) notification of construction/reconstruction commencement is being eliminated for subpart OOO facilities. Third, new standards in subpart OOO require additional monitoring requirements. Fourth, a greater number of existing NMPP are now subject to subpart OOO. Fifth, the revised analysis for this ICR includes time for management and clerical workers as well as technical staff. Sixth, the hourly labor rate increased from $57.12 per hour to $90.96 per hour. Seventh, performance testing was calculated as a capital cost because it is likely to be conducted by a contractor.
Overall, these changes result in a decrease in hourly burden and an increase in capital costs from the previously approved ICR.
(g) Burden Statement.
The annual public reporting and recordkeeping burden for this collection of information is estimated to average 2.3 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’s 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-OAR-2007-1018. An electronic version of the public docket is available at 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 Docket ID Number EPA-HQ-OAR-2007-1018. The documents are also available for public viewing at the EPA Docket Center, EPA West, Room 3334, 1301 Constitution Avenue, 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) 566-1742. Send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attn: Desk Officer for EPA, 725 17th St., NW, Washington, DC 20503. Please include the EPA Docket ID Number OAR-2007-0018 and OMB Control Number 2060-0050 in any correspondence.
Part B of the Supporting Statement
This part is not applicable because statistical methods are not used in data collection associated with the final rule.
Table 2. Annual Respondent Burden and Cost—NSPS for Nonmetallic Mineral Processing Plants
|
(A) Hours per Occurrence |
(B) Occurrences per Respondent |
(C) Hours per Respondent (A x B) |
(D) Respondents per year |
(E) Technical Hours per year (C x D) |
(F) Managerial hours per year (E x 0.05) |
(G) Clerical Hours per year (E x 0.10) |
(F) Cost per year |
|
1. APPLICATIONS (Not Applicable) |
|
|
|
|
|
|
|
|
|
2. SURVEY AND STUDIES (Not Applicable) |
|
|
|
|
|
|
|
|
|
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable) |
|
|
|
|
|
|
|
|
|
4. REPORT REQUIREMENTS |
|
|
|
|
|
|
|
|
|
A. Read Instructions |
1 |
1 |
1 |
66.4a |
66.40 |
3.32 |
6.64 |
$6,946 |
|
B. Required Activities |
|
|
|
|
|
|
|
|
|
Monitoring--wet suppressionb |
0.17 |
12 |
2 |
60.9 |
121.80 |
6.09 |
12.18 |
$12,741 |
|
Monitoring--M22 readingsc |
1 |
4 |
4 |
5.5 |
22 |
1.10 |
2.20 |
$2,301 |
|
C. Create Information (Included in 4B) |
|
|
|
|
|
|
|
|
|
D. Gather Existing Information (Included in 4E) |
|
|
|
|
|
|
|
|
|
E. Write Report |
|
|
|
|
|
|
|
|
|
Notification of construction/reconstruction commencement |
2 |
1 |
2 |
0 |
0.00 |
0 |
0 |
$0 |
|
Notification of actual startup |
2 |
1 |
2 |
66.4 |
132.80 |
6.64 |
13.28 |
$13,892 |
|
Notification of initial performance test |
2 |
1 |
2 |
66.4 |
132.80 |
6.64 |
13.28 |
$13,892 |
|
Report of performance test (Included in 5B) |
|
|
|
|
|
|
|
|
|
Notification of Physical or Operational Change |
2 |
1 |
2 |
66.4 |
132.80 |
6.64 |
13.28 |
$13,892 |
|
5. RECORDKEEPING |
|
|
|
|
|
|
|
|
|
A. Read Instructions (Included in 4A) |
|
|
|
|
|
|
|
|
|
B. Plan Activities (Included in 4B) |
|
|
|
|
|
|
|
|
|
Initial performance test (new sources) |
30d |
1 |
30 |
66.4 |
1,992.00 |
99.60 |
199.20 |
$208,378 |
|
Repeat performance test (new sources) |
30d |
1 |
30 |
16.6e |
498.00 |
24.90 |
49.80 |
$52,094 |
|
Performance test (existing sources) |
30d |
1 |
30 |
0f |
0.00 |
0.00 |
0.00 |
$0 |
|
C. Implement Activities (Included in 4B) |
|
|
|
|
|
|
|
|
|
D. Record Data |
|
|
|
|
|
|
|
|
|
Monitoring--wet suppressionb |
0.1 |
1 |
0.1 |
60.9 |
6.09 |
0.30 |
0.61 |
$637 |
|
Monitoring--M22 readingsc |
0.2 |
1 |
0.2 |
5.5 |
1.10 |
0.06 |
0.11 |
$115 |
|
E. Time to Transmit or Disclose Information |
|
|
|
|
|
|
|
|
|
Records of startups, shutdowns, malfunctions, etc. |
1.5 |
1 |
1.5 |
4,497.8g |
6,746.70 |
337.34 |
674.67 |
$705,754 |
|
F. Time to Train Personnel (Not Applicable) |
|
|
|
|
|
|
|
|
|
G. Time for Audits (Not Applicable) |
|
|
|
|
|
|
|
|
|
TOTAL ANNUAL LABOR BURDEN AND COST |
|
|
|
|
9,852.49 |
492.62 |
985.25 |
$1,030,642 |
|
4,853 total annual responses |
11,330 hours |
||||||||
ANNUAL CAPITAL COSTS |
|
||||||||
Performance tests |
|
$626,767 |
|||||||
File cabinets |
|
$15,604 |
|||||||
Total Annual capital |
|
$642,371 |
|||||||
ANNUALIZED CAPITAL COSTS |
|
||||||||
Performance tests (5 year life, 7% interest; CRF=0.2439) |
|
$152,868 |
|||||||
File cabinets (15 year life, 7% interest; CRF=0.1098) |
|
$1,709 |
|||||||
Total annualized capital |
|
$154,577 |
|||||||
TOTAL ANNUAL COSTS (O&M) |
|
$0 |
|||||||
TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) |
|
$154,577 |
a Estimating that there are approximately 332 NMPP which become subject over a 5-year period, the number of new sources per year equals 332/5 =66.4.
b Monitoring for wet suppression involves checking that water is actually flowing. This is estimated to take 10 minutes per check and to occur on a monthly basis. Wet suppression is
expected to be used in the following sectors: crushed/broken stone, and sand/gravel. The number of new sources per year from these sectors over the next three years is expected to be
60.9.
c Baghouse Method 22 readings are estimated to take 1 hour. All industry sectors except for crushed/broken stone and sand/gravel are expected to use baghouses and
will employ baghouse Method 22 readings to comply with the periodic monitoring requirements. The number of new sources per year from these sectors over the next three
years is expected to be 5.5.
d Performance tests include 8 hours to develop and review a performance test report and 22 hours to plan for the performance tests. The time required to conduct Method 5 and Method 9
tests are included in capital costs because a contractor is typically hired to perform the tests.
fe Assume 25% of initial performance tests must be repeated due to failure.
f Performance testing for existing sources will not occur until 5 years after the initial performance testing, which is the 6th year of the ICR. Beginning in the 6th year of the ICR, 60.9
sources per year would conduct 5-year repeat fugitive Method 9 performance tests. These tests are only required for crushed/broken stone and sand/gravel facilities that do not have
water sprays.
g Assume the average number of affected facilities over the next three years is represented by the number of sources in year 2 (66.4 new in first and second years and 4,365 existing
sources in the first year).
Table 3. Annual Burden and Cost to the Agency—NSPS for Nonmetallic Mineral Processing Plants
Activity |
(A) EPA Hours/ Occurrence |
(B) Occurrences/ Plant/Year |
(C) EPA Hours/ Plant/Yeara |
(D) Plants/ Year |
(E) EPA Technical Hours/ Yearb |
(F) EPA Managerial Hours/ Year |
(G) EPA Clerical Hours/ Year |
(H) Cost, $ |
Initial Performance Tests (New Plants) |
24 |
1 |
24 |
66.4 |
1,594 |
79.68 |
159.36 |
$79,067 |
Repeat Performance Tests (New Plants) |
24 |
1 |
24 |
16.6c |
398.4 |
19.92 |
39.84 |
$19,767 |
Performance test (existing sources)d |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
Report Review (New Plants) |
|
|
|
|
|
|
|
|
Notification of construction/reconstruction commencement |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
Notification of actual startup |
0.5 |
1 |
0.5 |
66.4 |
33.2 |
1.66 |
3.32 |
$1,647 |
Notification of initial test |
0.5 |
1 |
0.5 |
66.4 |
33.2 |
1.66 |
3.32 |
$1,647 |
Notification of Physical or Operational Change |
0.5 |
1 |
0.5 |
66.4 |
33.2 |
1.66 |
3.32 |
$1,647 |
Review test results |
8 |
1 |
8 |
66.4 |
531.2 |
26.56 |
53.12 |
$26,356 |
Emission Reports |
4 |
2 |
8 |
66.4 |
531.2 |
26.56 |
53.12 |
$26,356 |
Report Review (Existing Plants) |
4 |
1 |
4 |
4,497.8e |
17,991 |
899.56 |
1,799.1 |
$892,637 |
Annual Totals |
|
|
|
|
21,145.0 |
1,057.26 |
2,114.52 |
$1,049,123 |
Travel Expenses |
|
|
|
|
|
|
|
$26,560 |
Totals |
|
|
|
|
24,317 hours |
$1,075,683 |
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|
|
|
|
|
|
|
|
|
a C = A x B |
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b E = C x D |
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c Assume 25% of initial performance tests must be repeated due to failure. |
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d Performance testing for existing sources is not required in this rulemaking. |
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e Assume that average number of affected facilities over the next three years is estimated by the number of affected facilities in the second year (66.4 new in first year and 66.4 new in the second year and 4,365 existing in the first year). |
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Travel Expenses = (1 person x 66.4 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 66.4 plants/year) = $26,560/year. |
File Type | application/msword |
File Title | SF -83 SUPPORTING STATEMENT |
Last Modified By | Courtney Kerwin |
File Modified | 2009-04-29 |
File Created | 2009-04-13 |