1062ss14

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (Renewal), EPA ICR Number 1062.14, OMB Control Number 2060-0122.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Coal Preparation and Processing Plants were proposed on October 24, 1974, promulgated on January 15, 1976, and amended on October 8, 2009. These regulations apply to existing and new facilities that perform coal preparation and processing activities. 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 60, Subpart Y.

In general, all NSPS standards require initial notification reports, 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 NSPS.

Any owner/operator subject to the provisions of this part 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 U.S. Environmental Protection Agency (EPA) regional office.

The “Affected Public” is owners or operators of coal preparation and processing plants. All of the coal preparation and processing plants are owned and operated by the coal preparation and processing industry. None of the facilities in the United States are owned by either state, local, tribal, or the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond. The “burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (Renewal). The Federal Government’s burden is attributed entirely to work performed by either Federal employees or government contractors. The “burden” to the Federal Government may be found below in Table 2: Average Annual EPA Burden and Cost – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (Renewal).

Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 1,037 respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards.

The active (previous) ICR had the following Terms of Clearance (TOC):

Before this ICR is renewed, the agency should check the burden universe and hours estimates.

The EPA has addressed the TOC by consulting with the Office of Air Quality Planning and Standards (OAQPS) rule lead. We believe the number of affected facilities may have decreased since the last ICR renewal due to reports of coal plants being shut down or converted to natural gas, and expect a net zero growth in this industry sector over the next three years. All burden estimates were thoroughly reviewed and updated accordingly.

2. Need for and Use of the Collection

2(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 technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or 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 four years.

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, PM, SO₂, NOx, and CO emissions from coal preparation and processing plants 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 Y.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard 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. Continuous emission monitors are used to ensure compliance with the standards 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 required in these standards 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 standards 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 60, Subpart Y.

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, 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 June 5, 2015. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry 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.

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 and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted: 1) the American Public Power Association (APPA), at (202) 467-2900; and 2) the National Mining Association (NMA), at (202) 463-2600.

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 these 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.

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 these standards 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 owners and operators of coal preparation and processing plants. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards and the corresponding North American Industry Classification System (NAICS) codes are listed below for this source category.

Standard (40 CFR Part 60, Subpart Y)	SIC Codes	NAICS Codes
Bituminous Coal and Lignite Surface Mining	1221	212111
Bituminous Coal Underground Mining	1222	212112
Fossil Fuel Electric Power Generation	4911, 4931, 4939	221112
American Indian and Alaska Native Tribal Governments	8641	921150
Anthracite Mining	1231	212113
Support Activities for Coal Mining	1241	213113
Paper (except Newsprint) Mills	2611, 2621	322121
Petrochemical Manufacturing	2865, 2869	325110
All Other Petroleum and Coal Products Manufacturing	2999, 3312	324199
Cement Manufacturing	3241	327310
Iron and Steel Mills	3312	331110

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y).

A source must make the following reports:

Notifications
Notification and application of construction or modification.	60.7(a)(1)
Notification of anticipated date of initial startup.	60.7(a)
Notification of actual startup.	60.7(a)(3)
Notification of physical or operational change which may increase the emission rate.	60.7(a)(4)
Notification of performance test.	60.8

Reports
Initial performance test results	60.258(c)
Repeat performance test results	60.258(d)
Semiannual excess emission reports	60.7(c), 60.258(b)

A source must keep the following records:

Recordkeeping
Startups, shutdowns, malfunctions, periods where the continuous monitoring system is inoperative	60.7(b)
Maintain a written or electronic logbook	60.258(a)
Records are required to be retained for two (2) years	60.7(f)
Records of ongoing monitoring	60.7(f)
Fugitive Coal Dust Emissions Control Plan	60.254(c)
Bag Leak Detection System Site-Specific Plan	60.256(c)

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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Perform initial performance test using EPA Method 5, 9, and 22, 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 Enforcement and Compliance History Online (ECHO) and ICIS.

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 reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS 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 two years.

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses) affected by this regulation. However, it is not clear if any future facilities subject to the NSPS would be owned by small entities. 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 – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (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 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.

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 42,300 hours (Total Labor Hours from Table 1 below). 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.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 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 such as photocopying and postage.

(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 Respondents1	(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)
Bag leak detection systems 2	$48,180	0	$0	NA	NA	NA
Method 5 test 3	$7,000	0	$0	NA	NA	NA
Method 9 test 3	$1,300	0	$0	NA	NA	NA
Purchase supplies 4	NA	NA	NA	$2,735	24	$65,640
TOTAL5			$0			$65,600

¹ EPA assumes that all new coal preparation and process plants consist of coal processing and conveying equipment, coal storage systems, coal transfer and loading systems, and open storage piles. The estimates are based on conservative control implementation assumption that all affected respondents will choose to use enclosures vented to fabric filters to comply with the rule. In actuality many respondents are expected to choose alternative controls allowed under the rule, such as fogging systems, wet suppression, and passive enclosure containment system (PECS) that do not require Method 5 performance testing.

² The capital cost associated with procurement and installation of bag leak detection systems for the fabric filters was annualized assuming a 7 percent interest rate and 10-year life (i.e., capital recovery factor of 0.1424).

³ Both Method 5 and Method 9 testing are usually conducted by a contractor.

⁴ The annual costs associated with the purchase of monitoring, recordkeeping, and reporting supplies is estimated to be $2,735 per facility. These costs are assumed to only apply to facilities subject to the final rule amendment (i.e. facilities constructed, reconstructed, or modified after April 28, 2008).

⁵ 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 of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $65,600. 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 $65,600. These are record-keeping 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 $438,000.

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%)

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (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. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (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 1,037 existing respondents will be subject to these standards. 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 1,037 per year. The estimated growth rate is based on our consultation with OAQPS.

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	1,037	0	0	1,037
2	0	1,037	0	0	1,037
3	0	1,037	0	0	1,037
Average	0	1,037	0	0	1,037

¹ New respondents 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 1,037.

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
Notification of construction/ reconstruction commencement	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of initial performance tests except coal dump trucks	0	8	0	0
Notification of initial performance test for coal truck dumps	0	1	0	0
Notification of repeat performance test except coal truck dumps	0	0.5	0	0
Notification of repeat performance test for coal truck dumps	0	3	0	0
Notification of physical or operational change	0	1	0	0
Performance test reports except coal truck dumps	0	8.5	0	0
Performance test reports for coal truck dumps	0	4	0	0
Semiannual Excess Emissions Report	1,037	2	0	2,074
			Total	2,074

The number of Total Annual Responses is 2,074 (rounded).

The total annual labor costs are $4,250,000 (rounded). Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (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 42,300 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (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 20 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $65,600. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 9,600 labor hours at a cost of $438,000. See (below) Table 2: Average Annual EPA Burden and Cost – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (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.

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent labor hours 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.

In addition, there is a decrease in cost and number of responses due to a reduction in the estimated number of sources subject to the regulation. The previous ICR estimated that five new sources per year will be constructed such that they will become subject to the regulations. In consultation with OAQPS for the renewal of this ICR, we believe there will not be any net growth over the next three years. As such, no sources will incur burden associated with initial notifications and performance testing. This results in a decrease in capital cost and number of responses.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 20 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-2012-0498. 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), 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 (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-2012-0498 and OMB Control Number 2060-0122 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 – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (Renewal)

Burden Item	(A) Hours per Occurrence	(B) Occurrence per Respondent per Year	(C) Hours per Respondent per Year (C=AxB)	(D) Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, ($) b
1. Applications	N/A
2. Survey and studies	N/A
3. Report Requirements
A. Familiarize with Regulatory Requirements c	2	1	2	1,037	2,074	103.7	207.4	$239,848.77
B. Required Activities
a. Initial Performance Tests
Supervise Method 5 stack test performed by contractor service	8	1	8	0	0	0	0	$0
Supervise Method 9 opacity test performed by contractor service (except coal truck dumps)	2	1	2	0	0	0	0	$0
Supervise quarterly Method 9 opacity test performed by contractor service	4	1	4	0	0	0	0	$0
b. Repeat Performance Tests
Supervise Method 5 stack test performed by contractor service	8	0	0	0	0	0	0	$0
Supervise Method 9 opacity test performed by contractor service (except coal truck dumps)	2	0.5	1	0	0	0	0	$0
Supervise quarterly Method 9 opacity test performed by contractor service	4	3	12	0	0	0	0	$0
c. Compliance Monitoring and Inspection
Daily plant walkthrough visual observation of affected facilities for visible emissions	1	350	350	12	4,200	210	420	$485,711.10
Monthly visual inspection of control equipment used for affected facilities subject to opacity standards	1	36	36	12	432	21.6	43.2	$49,958.86
Coal handling affected facilities using fabric filter - inspect bag leak detectors (BLD) d	0.25	175	43.75	24	1,050	52.5	105	$121,427.78
d. Site-specific Emission Control Plans
Prepare "Fugitive Emission Control Plan"	40	1	40	0	0	0	0	$0
Prepare "BLD Monitoring Plan"	40	1	40	0	0	0	0	$0
e. Site-specific Emission Controls Operation Logbook
Prepare logbook	8	1	8	0	0	0	0	$0
Record required emission control equipment operating and maintenance data	0.5	350	175	0	0	0	0	$0
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write Report
a. Notifications
Notification of construction/reconstruction commencement	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of initial performance tests except coal dump trucks	2	8	16	0	0	0	0	$0
Notification of initial performance test for coal truck dumps	2	1	2	0	0	0	0	$0
Notification of repeat performance test except coal truck dumps	1	0.5	0.5	0	0	0	0	$0
Notification of repeat performance test for coal truck dumps	1	3	3	0	0	0	0	$0
Notification of physical or operational change	2	1	2	0	0	0	0	$0
b. Reports
Performance test reports except coal truck dumps (review and transmit report prepared by test contractor)	4	8.5	34	0	0	0	0	$0
Performance test reports for coal truck dumps (review and transmit report prepared by test contractor)	2	4	8	0	0	0	0	$0
Semiannual excess emissions report e	8	2	16	1,037	16,592	829.6	1,659.2	$1,918,790.14
Subtotal for Reporting Requirements					28,000			$2,815,737
4. RECORDKEEPING REQUIREMENTS
A. Familiarize with Regulatory Requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Record Data	See 3B
E. Time to Transmit or Disclose Information
Electronically transmit data f	1	12	12	1,037	12,444	622.2	1,244.4	$1,439,092.60
F. Time to Train Personnel
Plant personnel walkthrough observation procedure g	8	3	24	0	0	0	0	$0
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					14,311			$1,439,093
TOTAL Annual Labor Burden and Costs (rounded) h					42,300			$4,250,000
Capital and O&M Costs								$65,600
Grand TOTAL								$4,320,000

Assumptions:

^a We have assumed that the average number of sources that will be subject to the standard will be 1,37. There will be no additional new source per year that will become subject to the rule over the three-year period of this ICR

^b This ICR uses the following labor rates: $123.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. 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.

^c We assume all respondents will take 2 hours to familiarize with the regulatory requirements.

^d These requirements only apply to sources subject to the 2009 final rule amendment, i.e. sources constructed, reconstructed, or modified after April 28, 2008. EPA assumes that on average over the period covered under this ICR, there are 24 sources subject to the final rule amendment. EPA also assumes that 50 percent of sources elect to perform daily walkthrough visual emission observations for compliance monitoring, and 50 percent of sources elect to perform repeat Method 9 opacity testing for compliance monitoring.

^e All new and existing sources are subject to semiannual reporting.

^f We have assumed that each respondent will take one hour once per month to transmit electronic data.

^g We have assumed that each new respondent will take eight hours three time per year to observe procedures.

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

Table 2: Average Annual EPA Burden and Cost – NSPS for Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (Renewal)

Burden Item	(A) EPA Hours per Occurrence	(B) Occurrence per Plant per Year	(C) EPA Hours per Plant per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, ($) b
Notification Review
Construction/reconstruction commencement notifications	1	1	1	0	0	0	0	$0
Actual startup notifications	1	1	1	0	0	0	0	$0
Performance test notifications	1	9	9	0	0	0	0	$0
Physical or Operational Change	1	1	1	0	0	0	0	$0
Site-Specific Emission Control Plan Review
Review site-specific "Fugitive Emission Control Plan"	8	1	8	0	0	0	0	$0
Review site-specific "Bag Leak Detection Monitoring Plan"	8	1	8	0	0	0	0	$0
Compliance Demonstration Reports Review
Review performance test reports	4	9	36	0	0	0	0	$0
Review semi-annual excess emissions reports c	4	2	8	1,037	8,296	414.8	829.6	$434,212.64
Coal Preparation Plant Site Visits
Observe Method 5 Performance Test	24	1	24	1	24	1.2	2.4	$1,256.16
Observe Method 9 Performance Test	24	1	24	2	48	2.4	4.8	$2,512.32
Total Annual Labor Burden and Costs (rounded) d					9,600			$438,000

Assumptions:

^a We have assumed that the average number of sources that will be subject to the standard will be 1,037. There will be no additional new source per year that will become subject to the rule over the three-year period of this ICR.

^b This ICR uses the following labor rates: Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); Technical $46.67 (GS-12, Step 1, $29.17 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (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 have assumed that all sources are subject to semiannual excess emissions reporting.

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