2303ss03

12

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

National Emission Standards for Hazardous Air Pollutants for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal), EPA ICR Number 2303.03, OMB Control Number 2060-0625.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) were proposed on September 15, 2008 (73 FR 53163), and promulgated on December 23, 2008 (73 FR 78637). These regulations apply to existing and new ferroalloys production facilities. This information is being collected to assure compliance with 40 CFR part 63, subpart YYYYYY.

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 subject to NESHAP.

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 (EPA) regional office.

Over the next three years, an average of 10 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.

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

All 10 ferroalloys production facilities in the United States are owned and operated by the ferroalloys production industry (the “Affected Public”). All of these facilities are privately-owned, for profit businesses; none of them are owned by state, local, tribal or the Federal government. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed by federal employees or government contractors; this burden may be found below in Table 2: Annual Agency Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal).

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 maximum 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 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, HAP emissions from ferroalloys production area sources cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 63 subpart YYYYYY.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where 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. Continuous emission monitors are used to ensure compliance with the standard at all times.

The notifications required 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 installed 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 recordkeeping and reporting are required under (40 CFR part 63, subpart YYYYYY).

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 the report required by the Federal standards. Therefore, no duplication exists.

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 (76 FR 26900) on May 9, 2011. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data sources and projections of industry growth over the next three years have been considered.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this ICR, we contacted the Globe Metallurgical Incorporated at (740) 984-2361, the Langeloth Metallurgical Company at (724) 947-2201, and the Metallurg Vanadium at (740) 432-6534. No comments were received on this ICR.

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 first Federal Register notice. 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 collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These 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 the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish 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 prevented from pursuing the violators due to the destruction or nonexistence of essential records.

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, 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).

3(g) Sensitive Questions

The 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 Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) for the respondents affected by the standards are listed in the table below.

Standard (40 CFR Part 63, Subpart YYYYYY)	SIC Codes	NAICS Codes
Primary Smelting and Refining of Nonferrous Metal (except Copper and Aluminum)	3339	331419
Electrometallurgical Ferroalloy Product Manufacturing	3313	331112
All Other Basic Inorganic Chemical Manufacturing	2819 and 2869	325188

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY).

A source must make the following reports:

Notifications
Notification of applicability	63.9(b)(2)
Notification of construction/reconstruction	63.9(b)(5)
Notification of special compliance requirements	63.9(d)
Notification of performance test	63.9(e)
Notification of opacity/VE observations	63.9(f)
Additional CMS notifications	63.9(g)
Notification of compliance status	63.9(h)
Notification of changes in information	63.9(j)

Reports
Reports of exceedences	N/A
Semiannual monitoring reports	N/A
Initial/repeat performance tests	N/A
Quality assurance test plan	N/A
CMS performance evaluation/report	63.8(e)(5)
SSM reports	63.6(e)(3)
Excess emissions reports	63.10(e)(3)
Annual compliance certifications	N/A

A source must keep the following records:

Recordkeeping
Records of notifications	63.10
Records that demonstrate continuous compliance	63.10
Monitoring information	63.10

Electronic Reporting

Some of the respondents 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.

Also, regulatory agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically. However, electronic reporting systems are still not widely used. At this time, it is estimated that approximately 20 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply pressure for control device.

Perform initial performance test, Reference Method 22/ 9(c) test, 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

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 Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

Following 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 comply with the emission standard. 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 maintenance, and for compliance determinations.

Information contained in the reports is entered into the OTIS which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 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/operator for five years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. 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 requirements 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 specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (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 each 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. Wherever 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.

6(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 345 ( Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP 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 $121.42 ($57.82 + 110%)

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, “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 only costs to the regulated industry resulting from information collection activities required by the subject standard are labor costs. There are no capital/startup or operation and maintenance costs.

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

The only type of industry costs associated with the information collection activity in the regulations is labor costs. There are no capital/startup or operation and maintenance 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 includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $1,757.

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2011 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: Annual Agency Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (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 10 existing respondents will be subject to the standard. It is estimated that no additional respondents per year will become subject. The overall average number of respondents, as shown in the table below is 10 per year.

The number of respondents is calculated using the following 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	10	0	0	10
2	0	10	0	0	10
3	0	10	0	0	10
Average	0	10	0	0	10

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

.

Column 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 10.

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

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
One-time initial notification	10	1	0	10
One-time notifications of compliance status	10	1	0	10
Annual compliance certifications	10	1	0	10
Annual reports of exceedances	2	1	0	2
TOTAL				32

The number of Total Annual Responses is 32.

The total annual labor costs are $33,035. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal).

There are no capital/startup or operation and maintenance costs.

The average annual Agency burden and cost over the next three years is estimated to be 39 labor hours at a cost of $1,757. See below Table 2: Annual Agency Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (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 in Tables 1 and 2 (below), respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 345. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 11 hours per response.

There are no capital/startup or operation and maintenance costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 39 labor hours at a cost of $1,757. See below Table 2: Annual Agency Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal).

6(f) Reasons for Change in Burden

There is a decrease in respondent labor and cost from the most recently approved ICR. The decrease is due to a reduction in initial compliance costs as existing respondents are already expected to be in compliance with the regulations. However, there is an increase in Agency costs due to an adjustment in labor rates. The labor rates have increased over the past three years and the cost calculations in this ICR have been updated to reflect the most recent labor rates.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 11 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 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–OECA–2011–0236. 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 available 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 and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA 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 (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. 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 Officer for EPA. Please include the EPA Docket ID Number EPA–HQ–OECA–2011–0236 and OMB Control Number 2060–0625 in any correspondence.

Part B of the Supporting Statement

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

Table 1. Annual Respondent Burden and Cost - NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal)
REPORTING/RECORDKEEPING REQUIREMENT	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (A) x (B)	(D) Respondents per year	(E) Technical person-hour per year (C) x (D)	(F) Management person-hour per year (E) x 0.05		(G) Clerical person-hour per year (E) x 0.10	(H) Cost, $ (a)
1. Applications	N/A
2. Survey and Studies	N/A
3. Acquisition, Installation, & Utilization of Tech. & Systems	40	1	40	0	0	0		0	$0
4. Reporting Requirements
A. Read instructions (b)	4	1	4	0	0	0		0	$0
B. Required Activities
One-time activity, Initial control device Method 22 Planning	N/A
One-time activity, Initial control device Method 22 Test	N/A
Periodic control device Method 22	2	2	4	19	76	3.8		7.6	$8,374.60
Retest control device	2	1	2	1	2	0.1		0.2	$220.38
Weekly VE check (19 control devices)	0.1	52	5.2	19	98.8	4.94		9.88	$10,886.96
One-time activity, initial building opacity Method 9 (c)	N/A
Periodic (semi-annual) building VE Method 22	2	2	4	10	40	2		4	$4,407.68
Retest building opacity Method 9				10	0	0		0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write Report	See 4B
Initial Notification	2	1	2	0	0	0		0	$0
Notification of Compliance Status	4	1	4	0	0	0		0	$0
Annual Compliance Certification (d)	4	1	4	10	40	2		4	$4,407.68
Report of Exceedencess (e)	2	1	2	2	4	0.2		0.4	$440.76
Reporting Subtotal					299.92
5. Recordkeeping Requirements
A. Read instructions	See 4A
B. Plan activities	See 5E
C. Implement activities	See 5E
D. Develop record system	See 5E
E. Time to enter information
Records of all info. required by standards (f)	0.3	12	3.6	10	36	1.8		3.6	$3,966.92
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply w/ prev. appl. req.	N/A
H. Time to transmit or disclose information (g)	0.3	1	0.3	10	3	0.15		0.3	$330.57
I. Time for audits	N/A
Recordkeeping Subtotal					44.85
GRAND TOTAL (rounded)					344.77 345 (rounded)				$33,035
Assumptions: (a) Costs are based on the following hourly rates: technical at $99.14, management at $121.42, and clerical at $49.81.
(b) One-time activity. There are an estimated 10 existing ferroalloys production facilities and no new facilities are expected.
(c)One-time activity. Assume the facilities hire a contractor.
(d) The 10 existing plants would be required to submit and Annual Compliance Certification at the end of Year 1 of the ICR and each year thereafter.
(e) Assumes that 2 facilities per year would have to submit a report of exceedence.
(f) Recordkeeping requirements begin in Year 1 of ICR clearance period for all existing plants.
(g) Transmittals would include Annual Compliance Certifications for 10 plants.
(h) The total annual number of response is calculated by summing the product of columns B and D for each of the reports listed in 4B.
N/A = Not Applicable.

Table 2: Annual Agency Burden and Cost -NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal)
REPORTING/RECORDKEEPING REQUIREMENT	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent	Respondents per year	Technical person-hours	Managerial person-hours	Clerical person-hours	Cost, $ (a)
			(A) x (B)		(C) x (D)	(E) x 0.05	(E) x 0.10
Report Review:
Initial Notification of applicability (b)	1	1	1	3.3	3.3	0.17	0.33	$171.32
Notification of Compliance Status (c)	2	1	2	3.3	6.6	0.33	0.66	$342.05
Annual Compliance Certification (d)	2	1	2	10	20	1	2	$1,036.49
Annual Report of Deviations (e)	2	1	2	2	4	0.2	0.4	$207.29
SUBTOTAL ANNUAL BURDEN					33.9	1.7	3.39	$1,757
GRAND TOTAL (rounded)					39
(a) Costs are based on the following hourly rates: technical at $46.21, management at $62.27, and clerical at $25.01. Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
(b) All 10 plants will submit the initial notification, leading to an average annual burden of 3 plants/yr.
(c) All 10 plants will submit the notification of compliance status, leading to an average annual burden of 3 plants/yr.
(d) All 10 plants will submit an annual compliance certification each year.
(e)  Assumes that 2 facilities per year would have to submit an exceedance report per year.
N/A = Not applicable