SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Portland Cement Plants (40 CFR part 63, subpart LLL)

April 2009

Part A of the Supporting Statement

1.	Identification of the Information Collection

(a)	Title and Number of the Information Collection

“Recordkeeping and Reporting Requirements for Portland Cement Plants
(40 CFR Part 63, Subpart LLL).” The OMB has previously approved the
information collection requirements for the existing rule. This is a
revision to the existing approved information collection request (ICR).
The Office of Management and Budget (OMB) has previously approved the
information collection requirements in the existing rule (40 CFR part
63, subpart LLL) under the provisions of the Paperwork Reduction Act, 44
U.S.C. 3501 et seq. OMB control number is 2060-0416 and the EPA ICR
tracking number 1801.07 for this revision.

(b)	Short Characterization

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the regulations published at 40 CFR part 63, subpart LLL were
initially proposed on March 24, 1998, promulgated on June 14, 1999, and
subsequently revised on December 20, 2006. These regulations apply to
the following affected sources at each new and existing portland cement
plant that is a major or area source: each kiln, in-line kiln/raw mill
and raw material dryer at these facilities, except for kilns and in-line
kiln/raw mills that burn hazardous waste and are subject to 40 CFR 63,
subpart EEE. In addition, the rule applies to each new and existing
clinker cooler; raw mill; finish mill; raw material, clinker or finished
product storage bin; conveying system transfer point; and bagging system
and bulk loading and unloading system at facilities that are major or
area sources. This information is being collected to assure compliance
with 40 CFR part 63, subpart LLL.

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports. These notifications, reports,
and records are essential in determining compliance, and are required of
all sources subject to the NESHAP.

Any owner or 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.

Potential respondents are owners or operators of portland cement
manufacturing plants, except for kilns and in-line kiln/raw mills that
burn hazardous waste and are subject to 40 CFR part 63, subpart EEE. The
proposed amendments would establish or revise emission limits for total
hydrocarbons (THC), mercury (Hg), hydrogen chloride (HCl), and
particulate matter (PM). To demonstrate compliance with these emission
limits, owners or operators of new, existing or reconstructed kilns
would be required to continuously monitor THC, Hg, and HCl emissions and
monitor baghouse performance for PM removal. Respondents would be
required to maintain additional records to demonstrate compliance with
THC, Hg, HCl, and PM limits and notify EPA of performance tests. These
requirements are listed in Exhibit 1.

Exhibit 1.	Source Data and Information Requirements

Requirement	Regulation Citation	General Provision Citation	Record
Retention

Notifications



	Anticipated startup	63.1353(b)(1)	63.9(b)(3)	5 years

Actual startup	63.1353(b)(1)	63.9(b)(4)	5 years

Performance test	63.1353(b)(2)	63.7 and 63.9(e)	5 years

CEM performance evaluation	63.1353(b)(4)	63.8(e)	5 years

Compliance status	63.1353(b)(5)	63.9(h)	5 years

Reports



	Performance test	63.1354(b)(1)	63.10(d)	5 years

Monitoring exceedance	63.1354(b)(8)-(10)	63.10(e)(5)	5 years

Recordkeeping



	Record retention	63.1355(a)	63.10(b)(1)	5 years

General NESHAP records	63.1355(b)(1)-(3)	63.10(b)(2)-(3)	5 years

CMS performance records	63.1355(c)	63.10(c)	5 years

Approximately 93 facilities with 152 non-hazardous sources are currently
subject to the regulation, and it is estimated that 20 new sources will
be built over the next five years or 12 additional sources will become
subject to the regulation over the next three years.

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

2.	Need for and Use of the Collection

(a)	Need/Authority for the Collection

Section 112 of the CAA requires that EPA establish MACT standards for
new or existing major or area sources according to the requirements in
section 112(d). Certain records and reports are necessary for the
Administrator to: (1) confirm the compliance status of major sources,
identify any non-major sources not subject to the standards, and
identify new or reconstructed sources subject to the standards; and (2)
ensure that the MACT standards are being achieved on a continuous basis.
These recordkeeping and reporting requirements are specifically
authorized by section 114 of the Clean Air Act (42 U.S.C. 7414) and set
out in the General Provisions for national emission standards for
hazardous air pollutants (NESHAP) in 40 CFR part 63, subpart A.

(b)	Use/Users of the Data

The additional information will be used by Agency enforcement personnel
to ensure that the emission limitations are being achieved. Based on
review of the recorded information at the site and the reported
information, EPA can identify facilities that may not be in compliance
and decide which plants, records, or processes should be inspected.

3.	Nonduplication, Consultations, and Other Collection Criteria

(a)	Nonduplication

No other regulation currently requires the same information requested
under this ICR from owners or operators of portland cement plants. In
the event that certain reports required by State or local agencies may
duplicate information required by the proposed amendments, a copy of the
report submitted to the State or local agency can be provided to the
Administrator in lieu of the information that would be required in the
semi-annual compliance report. 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

We did not specifically consult with stakeholders on the ICR
requirements of these proposed amendments. However, all the basic
requirements in the proposed amendments exist in the current rule.
Participants in the development process for the current rule included
the Portland Cement Association (PCA) and Earth Justice on behalf of the
Sierra Club. Several meetings and conference calls with industry and
environmental representatives were held in the period leading to
proposal.

(d)	Effects of Less Frequent Collection

If the relevant information were collected less frequently, EPA would
not be reasonably assured that a plant is in compliance with the
standards.

(e)	General Guidelines

None of the guidelines in 5 CFR 1320.5 are being exceeded.

(f)	Confidentiality

All 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 (see 40 CFR 2; 41 FR 36902,
September 01, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR
42251, September 28, 1978; 44 FR 17674, March 23, 1979).

(g)	Sensitive Questions

This section is not applicable because this ICR does not involve matters
of a sensitive nature.

4.	The Respondents and the Information Requested

(a)	Respondents/NAICS Codes

In the proposed amendments, respondents are 93 owners or operators of
existing portland cement manufacturing plants and any new portland
cement plants. It is estimated that 20 new kilns located at an existing
plants will be built over 5 years (or 4 new kilns per year) after
promulgation of the amendments. All respondents will be subject to the
monitoring, recordkeeping, and reporting requirements. The NAICS code
for this industry is 327310, Cement Manufacturing.

(b) Information Requested

(i) Data Items, Including Recordkeeping Requirements. 

Exhibit 1 (Source Data and Information Requirements) summarizes the
final recordkeeping and reporting requirements.

(ii) Respondent Activities. 

The respondent activities required by the final amendments are
introduced in section 6(a).

(iii) Electronic Reporting. 

EPA is proposing that portland cement plants have the option of
submitting to an EPA electronic database an electronic copy of their
required stack test. This electronic database should become available as
of December 31, 2011. Currently, sources are using monitoring equipment
that provides automated parameter data (e.g., continuous opacity
monitoring). Although personnel at the affected facility must evaluate
these data, this type of monitoring equipment has significantly reduced
the burden associated with monitoring and recordkeeping. In addition,
some regulatory agencies are setting up electronic reporting systems to
allow sources to report such data electronically which also reduces the
reporting burden. It is estimated that approximately 10 percent of the
respondents currently use electronic reporting.

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 plant 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.
The semi-annual 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 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
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 or
operator for five years.

(c)	Small Entity Flexibility

There is a distribution of business sizes for the business that operate
portland cement plants. A majority of the affected plants are large
entities (e.g., large businesses). However, the impact on potential
small entities (i.e., small business) was taken into consideration
during the development of the regulation. One consideration in the
development of the proposed rule was that the size of the business does
not necessarily correlate with emissions potential. Even a small entity
can and do operate cement kilns that emit large quantities of HAP. Due
to technical considerations involving the process operation and the
types of control equipment employed, the recordkeeping and reporting
requirements are the same for both small and large entities. The agency
considerers these requirements the minimum needed to ensure compliance
and, therefore, cannot reduce them further for small entities. To the
extent that larger business can use economies of scale to reduce their
burden, the overall burden will be reduced. 

(d)	Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Tables 1a-c and Exhibit 2: Respondent Burden of
Reporting and Recordkeeping Requirements, NESHAP for Portland Cement
Plants (40 CFR Part 63, Subpart LLL).

6.	Estimating the Burden and Cost of the Collection

Tables 1a, 1b, and 1c document the computation of individual burdens for
the recordkeeping and reporting requirements applicable to the industry
for the subpart included in this ICR for each of the first 3 years.
Exhibit 2 contains a summary of the respondent burden hours and costs
detailed in Tables 1a, 1b, and 1c.

Exhibit 2.	Summary of Respondent Burden

Year	Total Annual Labor Burden (hours)	Total Annual Labor Costs ($)

1	93,953	8,781,789

2	19,647	1,836,380

3	20,369	1,903,773

Total	133,969	12,521,941

3-Year Average	44,656	4,173,980

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 44,656
hours per year (Total Labor Hours from Tables 1a, 1b, and 1c). 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.

(b)	Estimating Respondent Costs

Respondent costs are divided into four categories. These categories
include labor costs, capital costs (includes startup costs), operations
and maintenance costs, and annualized capital costs. The total
respondent costs per kiln ($583,502) have been calculated as the sum of
the capital costs (including startup) ($488,316) and the annual
operation and maintenance costs ($95,186).

(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 2009, “Table 2. Civilian
Workers, by occupational and industry group,” available at   HYPERLINK
"http://www.bls.gov/news.release/ecec.t02.htm" 
www.bls.gov/news.release/ecec.t02.htm . Wages for occupational groups
are used as the basis for the labor rates with a total compensation of
$46.18 per hour for technical, $54.64 per hour for managerial, and
$22.74 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 $96.98, management at $114.74, and clerical at $47.75.

(ii)	Estimating Capital Costs

The capital costs associated with the information collection
requirements will include the costs to conduct performance tests,
startup costs for CEMS, and startup costs for bag leak detectors. The
rule will require an initial performance test for each portland cement
plant. 

The annual total capital (including startup) costs for CEMS that will be
used to monitor THC, Hg, and HCl and bag leak detectors is $488,316 per
kiln (costs derived from EPA’s CEM.xls spreadsheet and Hg costs from
69FR4694). The costs will be incurred for each year of the three-year
period.

The average annual cost for capital (including startup) costs to
industry each year over the next three years of the ICR are estimated to
be $486,316. The continuous monitoring costs that are included in this
section consist only of those capital costs that a source incurs as a
result of the standard. Some continuous monitoring costs may not be
included in this section. For instance, if a particular industry
typically utilizes a control device that must have a continuous monitor
(e.g., temperature, pressure drop, etc.) to function properly, and the
recordation of additional measurements beyond the minimum are required
by the standard, then there is no capital cost; but, there is a labor
cost to record the additional readings. Such a cost would not appear in
this section, but in the industry burden Section 6(d) below.

All portland cement plants are assumed to consist of kiln, clinker
cooler, raw mill system, finish mill system, raw mill dryer, raw
material storage, clinker storage, finished product storage, convey
transfer points, and bagging and bulk loading and unloading systems. In
the future, the Agency assumes that no new COMS/Method 9 testing will be
used. Fabric filter performance tests at Portland cement plants include
an initial Method 5 test. Method 5 testing is 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 was used. It is
anticipated that new kilns will use continuous emission monitoring
systems (CEMS) for compliance with the proposed new or revised THC, Hg,
HCl, and PM emission limits and bag leak detectors for baghouse
performance. Initial CEMS testing is usually conducted by an
installation contractor such that the cost of the emissions testing is a
capital cost. A testing cost of $81,308 per kiln for initial CEMS
testing was used. The total costs for performance testing were
calculated for this industry sector. Note that there are no testing
costs for BLDs. The anticipated number of new sources in this sector
combined with the number of tests required for each type of model plant
resulted in a total capital cost of approximately $13,195,390 for Method
5 and CEMS testing over the next three years as shown in Exhibit 3.

Exhibit 3.	Total Testing Costs by Year

Year	Method 5 ($)	CEMS and Flow Meters ($)

1	1,064,000	11,480,927

2	28,000	297,232

3	28,000	297,232

Total	1,120,000	12,075,390

Grand Total

13,195,390



(iii)	Estimating Operations and Maintenance (O&M) Costs

The annual operation and maintenance costs are the ongoing costs to
maintain the monitors and other costs such as photocopying and postage.
The total annual operations and maintenance costs for CEMS that will be
used to monitor THC, Hg, HCl and bag leak detectors is $95,186 per kiln
per year (costs derived from EPA’s CEM.xls spreadsheet and Hg costs
from 69FR4694).

The average annual cost for operation and maintenance costs to industry
each year over the next three years of the ICR are estimated to be
$95,186 per kiln. The continuous monitoring costs that are included in
this section consist only of those O&M costs that a source incurs as a
result of the standard. Some continuous monitoring costs may not be
included in this section. For instance, if a particular industry
typically utilizes a control device that must have a continuous monitor
(e.g., temperature, pressure drop, etc.) to function properly, and the
recordation of additional measurements beyond the minimum are required
by the standard, then there is O&M cost, but there is a labor cost to
record the additional readings. Such a cost would not appear in this
section, but in the industry burden Section 6(d) below.

(iv)	Annualizing Capital Costs

The annualized capital costs include the costs for Method 5 performance
tests, CEMS, BLD, and flow meters. The total annualized capital costs
total $53,698,306. A copy of the CEMS Monitoring Costs Spreadsheet can
be found in the docket (See Section 6(g) for docket information).

(c)	Estimating Agency Burden and Cost

Because the information collection requirements were developed as an
incidental part of standards development, no costs can be attributed to
the development of the information collection requirements. Because
reporting and recordkeeping requirements on the part of the respondents
are required under the NESHAP General Provisions, no operational costs
will be incurred by the Federal Government. Publication and distribution
of the information are part of the Compliance Data System, with the
result that no Federal costs can be directly attributed to the ICR.
Examination of records to be maintained by the respondents will occur
incidentally as part of the periodic inspection of sources that is part
of EPA's overall compliance and enforcement program, and, therefore, is
not attributable to the ICR. The only costs that the Federal government
will incur are user costs associated with the analysis of the reported
information, as presented in Tables 2a, 2b, and 2c. Exhibit 4 contains
a summary of the agency burden costs and houses detailed in Tables 2a,
2b, and 2c. The average annual Agency costs during the three years of
the ICR is estimated to be $120,679.

Exhibit 4.	Summary of the Agency Burden

Year	Total Annual Labor Burden (Hours)	Total Annual Costs ($)

1	2,958	162,692

2	1,713	94,380

3	1,906	104,966

Total	6,576	362,038

3-Year Average	2,192	120,679

The Agency labor rates are from the Office of Personnel Management (OPM)
2003 General Schedule which excludes locality rates of pay. These rates
can be obtained from Salary Table 2009-GS available on the OPM website (
 HYPERLINK "http://www.opm.gov/oca/09tables/html/gs_h.asp" 
www.opm.gov/oca/09tables/html/gs_h.asp ). The government employee labor
rates are $16.04/hour for clerical (GS-7, Step 1), $33.84 for technical
(GS-13, Step 1), and $47.03/hr for management (GS-15, Step 1). 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 wage rates used to represent Agency
labor costs are: clerical at $25.66; technical at $54.14, and management
at $75.25.

(d) Estimating the Respondent Universe and Total Burden and Costs.

Approximately 93 portland cement plants are currently subject to the
current regulation. Growth in this sector was estimated using data
compiled by the Portland Cement Association showing capacity expansion
estimates for the industry. Using this information it is estimated that
an additional 20 new portland cement kilns will become subject to the
regulation over the 5-year NESHAP review period. Thus, it is estimated
that an additional 12 portland cement kilns per year will become subject
to the regulation over the three year ICR period (20/5 x 3 = 12). All 20
new kilns are estimated to be newly constructed at existing portland
cement plants.

The total annual number of responses for the new monitoring,
recordkeeping, and reporting requirements in subpart LLL is 1,476 for
the existing 152 kilns that will follow the proposed amendments and the
additional 12 newly constructed portland cement kilns.

The total annual labor costs are $4,173,980. Details upon which this
estimate is based appear in Tables 1a, 1b, and 1c.

(e)	Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached. The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 2,828
hours per response. The increased average annual burden for the proposed
amendments is 22,971 person hours with an annual average cost of
$25,808,396 for technical, management, and clerical hours with
annualized capital/startup cost of $53,698,306 for a total cost of
$79,506,702. The total annual average burden for the rule, including the
final amendments will be 44,656 (21,685+22,971) person hours with a
total annualized capital/startup cost of $26,762,068
($953,672+$25,808,396).

(f)	Reasons for Change in Burden.

The increase in burden is primarily due to the additional performance
testing, monitoring, recordkeeping, and reporting costs attributable to
the proposed amendments. It is also due to the use of more current labor
rates for calculating the industry and Agency burden.

(g)	Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 2,828 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 currently
valid OMB control number. The OMB control numbers for EPA’s
regulations in 40 CFR part 63 are listed in 40 CFR part 9.

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-2002-0051, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air and Radiation
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room B102, 1301 Constitution Avenue, NW, Washington, D.C. 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
Air and Radiation Docket and Information Center is (202) 566-1742. An
electronic version of the public docket is available at
www.regulations.gov. This site can be used to submit or view public
comments, access the index listing of the contents of the public 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 above. Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA. Please include the EPA Docket ID Number
EPA-HQ-OAR-2002-0051 in any correspondence.

PART B

This section is not applicable because statistical methods are not used
in data collection associated with the final amendments.

Table 1a	Year 1 Respondent Burden of Reporting and Recordkeeping
Requirements, NESHAP for Portland Cement Plants (40 CFR part 63, subpart
LLL

Year 1 Activities	(A) Hours per Occurrence	(B) Occurrences/ Respondent/
Year	(C) Hours/ Respondent/ Year (A x B)	(D) Respondents/ Year	(E)
Technical Hours/Year (C x D)	(F) Managerial Hours/Year (E x 0.05)	(G)
Clerical Hours/Year (E x 0.10)	(H) Cost/ Year

1. APPLICATIONS (Not Applicable)









2. SURVEY AND STUDIES (Not Applicable)









3.  ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS
16	1	16	93	1,488.0	74.4	148.8	$159,946

4. REPORT REQUIREMENTS









 	A. Read Instructions









 	 	Existing Sources	1	1	1	93	93.0	4.7	9.3	$9,997

 	 	New Sources	1	1	1	4	4.0	0.2	0.4	$430

 	B. Required Activities*









 	 	New Sources - Initial Performance Test	24	1	24	152	3,648.0	182.4
364.8	$392,126

 	 	New Sources - Reference Method 5 Test	8	1	8	152	1,216.0	60.8	121.6
$130,709

 	 	New Sources - Repeat Performance Test	24	1	24	152	3,648.0	182.4
364.8	$392,126

 	 	New Sources - Initial THC Performance Test	8	1	8	152	1,216.0	60.8
121.6	$130,709

 	 	New Sources - Repeat THC Performance Test	8	1	8	152	1,216.0	60.8
121.6	$130,709

 	 	New Sources - Initial Hg Performance Test**	40	1	40	156	6,240.0
312.0	624.0	$670,741

 	 	New Sources - Repeat Hg Performance Test**	0	0	0	156	0	0	0	$0

 	 	New Sources - Initial HCl Performance Test**	16	1	16	156	2,496.0
124.8	249.6	$268,297

 	 	New Sources - Repeat HCl Performance Test**	16	0.2	3.2	156	499.2
25.0	49.9	$53,659

 	 	New Sources - CEMS Monitoring	0.5	1	0.5	152	76.0	3.8	7.6	$8,169

 	 	New Sources - CEMS Quarterly Inspections	2	4	8	152	1,216.0	60.8
121.6	$130,709

 	 	New Sources - CEMS Daily Calibration Drift Tests	0.3	300	90	152
13,680.0	684.0	1,368.0	$1,470,471

 	 	New Sources - BLD Quarterly (Seasonal) Adjustments	2	4	8	152
1,216.0	60.8	121.6	$130,709

 	 	New Sources - Daily monitoring (CEMS and BLD)	0.3	300	90	152
13,680.0	684.0	1,368.0	$1,470,471

 	 	New Sources -- All CEMS must follow appropriate performance
specifications	0.3	300	90	152	13,680.0	684.0	1,368.0	$1,470,471

 	C. Create Information (Included in 4B)









 	D. Gather Existing Information (Included in 4E)









 	E. Write Report









 	 	New Sources - Notification of construction/reconstruction	2	1	2	4
8.0	0.4	0.8	$860

 	 	New Sources - Notification of actual startup	2	1	2	4	8.0	0.4	0.8
$860

 	 	New Sources - Physical or Operational Change	2	1	2	4	8.0	0.4	0.8
$860

 	 	New Sources - Notification of Demonstration of CEMS	2	1	2	4	8.0
0.4	0.8	$860

 	 	New Sources - Report of Performance Test (included in 4B)









 	 	New Sources - Notification of Initial Performance Test	2	1	2	4	8.0
0.4	0.8	$860

 	 	New Sources - Report of Performance Test	2	1	2	4	8.0	0.4	0.8	$860

 	 	New Sources - Report of Semi-Annual Reports	24	2	48	4	192.0	9.6
19.2	$20,638

 	 	New Sources - BLD - site-specific monitoring plan**	40	1	40	156
6,240.0	312.0	624.0	$670,741

5. RECORDKEEPING REQUIREMENTS









 	A. Read Instructions (Included in 4A)









 	B. Plan Activities (Included in 4B)









 	C. Implement Activities (Included in 4B)









 	D. Record Data ( Not Applicable)









 	E. Time to Transmit or Disclose Information









 	 	New Sources - Data Collection**	0.1	300	30	156	4,680.0	234.0	468.0
$503,056

 	 	New Sources - Records of Startups, Shutdowns, malfunctions, etc**
1.5	1	1.5	156	234.0	11.7	23.4	$25,153

 	F. Time to Train Personnel**	16	2	32	156	4,992.0	249.6	499.2	$536,593

 	G. Time for Audits (Not Applicable)









TOTAL ANNUAL LABOR BURDEN AND COST

1231.2

3,138	81,698	4,085	8,170	$8,781,789







93,953	Hours

	ANNUAL CAPITAL COSTS









 	Performance tests







$12,544,927

 	Other Capital Costs of Installation (ODC and Labor)







$63,778,759

 	Total annual capital







$76,323,685

ANNUALIZED CAPITAL COSTS







$152,647,371

 	Total annualized capital







$152,647,371

TOTAL ANNUAL COSTS (O&M)







$174,169

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)







$152,821,540

*Includes 152 existing sources that must comply with the new regulations

**Includes 152 existing sources that must comply with the new
regulations and 4 new anticipated sources.

Table 1b	Year 2 Respondent Burden of Reporting and Recordkeeping
Requirements, NESHAP for Portland Cement Plants (40 CFR part 63,
subpart LLL

Year 2 Activities	(A) Hours per Occurrence	(B) Occurrences/
Respondent/Year	(C) Hours/ Respondent/ Year (A x B)	(D) Respondents/
Year	(E) Technical Hours/Year (C x D)	(F) Managerial Hours/Year (E x
0.05)	(G) Clerical Hours/Year (E x 0.10)	(H) Cost/ Year

1. APPLICATIONS (Not Applicable)









2. SURVEY AND STUDIES (Not Applicable)









3.  ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS
-- New Sources	16	1	16	4	64.0	3.2	6.4	$6,879

4. REPORT REQUIREMENTS







 

 	A. Read Instructions







 

 	 	New Sources	1	1	1	4	4.0	0.2	0.4	$430

 	B. Required Activities









 	 	Existing Sources - Initial Performance Test*	24	1	24	9	216.0	10.8
21.6	$23,218

 	 	Existing Sources - Reference Method 5 Test*	8	1	8	9	72.0	3.6	7.2
$7,739

 	 	Existing Sources - Repeat Performance Test*	24	1	24	9	216.0	10.8
21.6	$23,218

 	 	Existing Sources - Initial THC Performance Test*	8	1	8	9	72.0	3.6
7.2	$7,739

 	 	Existing Sources - Repeat THC Performance Test*	8	1	8	9	72.0	3.6
7.2	$7,739

 	 	Existing Sources - Initial Hg Performance Test*	40	1	40	9	360.0
18.0	36.0	$38,697

 	 	Existing Sources - Repeat Hg Performance Test*	0	0	0	9	0	0	0	$0

 	 	Existing Sources - Initial HCl Performance Test*	16	1	16	9	144.0
7.2	14.4	$15,479

 	 	Existing Sources - Repeat HCl Performance Test*	16	0.2	3.2	9	28.8
1.4	2.9	$3,096

 	 	Existing Sources - CEMS Monitoring*	0.5	1	0.5	9	4.5	0.2	0.5	$484

 	 	Existing Sources - CEMS Quarterly Inspections*	2	4	8	9	72.0	3.6
7.2	$7,739

 	 	Existing Sources - CEMS Daily Calibration Drift Tests*	0.3	300	90
9	810.0	40.5	81.0	$87,067

 	 	Existing Sources - BLD Quarterly (Seasonal) Adjustments*	2	4	8	9
72.0	3.6	7.2	$7,739

 	 	Existing Sources - Daily monitoring (CEMS and BLD)*	0.3	300	90	9
810.0	40.5	81.0	$87,067

 	 	Existing Sources -- All CEMS must follow appropriate performance
specifications*	0.3	300	90	9	810.0	40.5	81.0	$87,067

 	 	New Sources - Initial Performance Test	24	1	24	4	96.0	4.8	9.6
$10,319

 	 	New Sources - Reference Method 5 Test	8	1	8	4	32.0	1.6	3.2	$3,440

 	 	New Sources - Repeat Performance Test	24	1	24	4	96.0	4.8	9.6
$10,319

 	 	New Sources - Initial THC Performance Test	8	1	8	4	32.0	1.6	3.2
$3,440

 	 	New Sources - Repeat THC Performance Test	8	1	8	4	32.0	1.6	3.2
$3,440

 	 	New Sources - Initial Hg Performance Test	40	1	40	4	160.0	8.0	16.0
$17,198

 	 	New Sources - Repeat Hg Performance Test	0	0	0	4	0	0	0	$0

 	 	New Sources - Initial HCl Performance Test	16	1	16	4	64.0	3.2	6.4
$6,879

 	 	New Sources - Repeat HCl Performance Test 	16	0.2	3.2	4	12.8	0.6
1.3	$1,376

 	 	New Sources - CEMS Monitoring	0.5	1	0.5	4	2.0	0.1	0.2	$215

 	 	New Sources - CEMS Quarterly Inspections	2	4	8	4	32.0	1.6	3.2
$3,440

 	 	New Sources - CEMS Daily Calibration Drift Tests	0.3	300	90	4
360.0	18.0	36.0	$38,697

 	 	New Sources - BLD Quarterly (Seasonal) Adjustments	2	4	8	4	32.0
1.6	3.2	$3,440

 	 	New Sources - Daily monitoring (CEMS and BLD)	0.3	300	90	4	360.0
18.0	36.0	$38,697

 	 	New Sources -- All CEMS must follow appropriate performance
specifications	0.3	300	90	4	360.0	18.0	36.0	$38,697

 	C. Create Information (Included in 4B)









 	D. Gather Existing Information (Included in 4E)









 	E. Write Report









 	 	Existing Sources - Notification of construction/reconstruction*	2
1	2	9	18.0	0.9	1.8	$1,935

 	 	Existing Sources - Notification of actual startup*	2	1	2	9	18.0
0.9	1.8	$1,935

 	 	Existing Sources - Physical or Operational Change*	2	1	2	9	18.0
0.9	1.8	$1,935

 	 	Existing Sources - Notification of Demonstration of CEMS*	2	1	2	9
18.0	0.9	1.8	$1,935

 	 	Existing Sources - Report of Performance Test (included in 4B)









 	 	Existing Sources - Notification of Initial Performance Test*	2	1	2
9	18.0	0.9	1.8	$1,935

 	 	Existing Sources - Report of Performance Test*	2	1	2	9	18.0	0.9
1.8	$1,935

 	 	Existing Sources - Report of Semi-Annual Reports*	24	2	48	9	432.0
21.6	43.2	$46,436

 	 	Existing Sources - BLD - site-specific monitoring plan*	40	1	40	9
360.0	18.0	36.0	$38,697

 	 	New Sources - Notification of construction/reconstruction	2	1	2	4
8.0	0.4	0.8	$860

 	 	New Sources - Notification of actual startup	2	1	2	4	8.0	0.4	0.8
$860

 	 	New Sources - Physical or Operational Change	2	1	2	4	8.0	0.4	0.8
$860

 	 	New Sources - Notification of Demonstration of CEMS	2	1	2	4	8.0
0.4	0.8	$860

 	 	New Sources - Report of Performance Test (included in 4B)









 	 	New Sources - Notification of Initial Performance Test	2	1	2	4	8.0
0.4	0.8	$860

 	 	New Sources - Report of Performance Test	2	1	2	4	8.0	0.4	0.8	$860

 	 	New Sources - Report of Semi-Annual Reports	24	2	48	4	192.0	9.6
19.2	$20,638

 	 	New Sources - BLD - site-specific monitoring plan	40	1	40	4	160.0
8.0	16.0	$17,198

5. RECORDKEEPING REQUIREMENTS









 	A. Read Instructions (Included in 4A)









 	B. Plan Activities (Included in 4B)









 	C. Implement Activities (Included in 4B)









 	D. Record Data ( Not Applicable)









 	E. Time to Transmit or Disclose Information









 	 	Existing Sources - Data Collection	0.1	300	30	160	4,800.0	240.0
480.0	$515,955

 	 	Existing Sources - Records of Startups, Shutdowns, malfunctions,
etc	1.5	1	1.5	160	240.0	12.0	24.0	$25,798

 	 	New Sources - Data Collection	0.1	300	30	4	120.0	6.0	12.0	$12,899

 	 	New Sources - Records of Startups, Shutdowns, malfunctions, etc
1.5	1	1.5	4	6.0	0.3	0.6	$645

 	F. Time to Train Personnel	16	2	32	160	5,120.0	256.0	512.0	$550,352

 	G. Time for Audits (Not Applicable)









TOTAL ANNUAL LABOR BURDEN AND COST

2456.4

795	17,084	854	1,708	$1,836,380







19,647	Hours

	ANNUAL CAPITAL COSTS









 	Performance tests







$325,232

 	Other Capital Costs of Installation (ODC and Labor)







$1,656,028

 	Total annual capital







$1,981,260

ANNUALIZED CAPITAL COSTS







$3,962,519

 	Total annualized capital







$3,962,519

TOTAL ANNUAL COSTS (O&M)







$174,169

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)







$4,136,688

*Assumes that 10% of the 93 facilities (9 facilities) will have new
construction/reconstruction and will be required to complete performance
tests and new/revised reports.

Table 1c	Year 3 Respondent Burden of Reporting and Recordkeeping
Requirements, NESHAP for Portland Cement Plants (40 CFR part 63, subpart
LLL)]

Year 3 Activities	(A) Hours per Occurrence	(B) Occurrences/ Respondent/
Year	(C) Hours/ Respondent/ Year (A x B)	(D) Respondents/ Year	(E)
Technical Hours/Year (C x D)	(F) Managerial Hours/Year (E x 0.05)	(G)
Clerical Hours/Year (E x 0.10)	(H) Cost/ Year

1. APPLICATIONS (Not Applicable)









2. SURVEY AND STUDIES (Not Applicable)









3.  ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS
-- New Sources	16	1	16	4	64.0	3.2	6.4	$6,879

4. REPORT REQUIREMENTS









 	A. Read Instructions









 	 	New Sources	1	1	1	4	4.0	0.2	0.4	$430

 	B. Required Activities









 	 	Existing Sources - Initial Performance Test*	24	1	24	9	216.0	10.8
21.6	$23,217

 	 	Existing Sources - Reference Method 5 Test*	8	1	8	9	72.0	3.6	7.2
$7,739

 	 	Existing Sources - Repeat Performance Test*	24	1	24	9	216.0	10.8
21.6	$23,217

 	 	Existing Sources - Initial THC Performance Test*	8	1	8	9	72.0	3.6
7.2	$7,739

 	 	Existing Sources - Repeat THC Performance Test*	8	1	8	9	72.0	3.6
7.2	$7,739

 	 	Existing Sources - Initial Hg Performance Test*	40	1	40	9	360.0
18.0	36.0	$38,694

 	 	Existing Sources - Repeat Hg Performance Test*	0	0	0	9	0	0	0	$0

 	 	Existing Sources - Initial HCl Performance Test*	16	1	16	9	144.0
7.2	14.4	$15,478

 	 	Existing Sources - Repeat HCl Performance Test*	16	0.2	3.2	9	28.8
1.4	2.9	$3,096

 	 	Existing Sources - CEMS Monitoring*	0.5	1	0.5	9	4.5	0.2	0.5	$484

 	 	Existing Sources - CEMS Quarterly Inspections*	2	4	8	9	72.0	3.6
7.2	$7,739

 	 	Existing Sources - CEMS Daily Calibration Drift Tests*	0.3	300	90
9	810.0	40.5	81.0	$87,062

 	 	Existing Sources - BLD Quarterly (Seasonal) Adjustments*	2	4	8	9
72.0	3.6	7.2	$7,739

 	 	Existing Sources - Daily monitoring (CEMS and BLD)*	0.3	300	90	9
810.0	40.5	81.0	$87,062

 	 	Existing Sources -- All CEMS must follow appropriate performance
specifications*	0.3	300	90	9	810.0	40.5	81.0	$87,062

 	 	New Sources - Initial Performance Test	24	1	24	4	96.0	4.8	9.6
$10,318

 	 	New Sources - Reference Method 5 Test	8	1	8	4	32.0	1.6	3.2	$3,439

 	 	New Sources - Repeat Performance Test	24	1	24	4	96.0	4.8	9.6
$10,318

 	 	New Sources - Initial THC Performance Test	8	1	8	4	32.0	1.6	3.2
$3,439

 	 	New Sources - Repeat THC Performance Test	8	1	8	4	32.0	1.6	3.2
$3,439

 	 	New Sources - Initial Hg Performance Test	40	1	40	4	160.0	8.0	16.0
$17,197

 	 	New Sources - Repeat Hg Performance Test	0	0	0	4	0	0	0	$0

 	 	New Sources - Initial HCl Performance Test	16	1	16	4	64.0	3.2	6.4
$6,879

 	 	New Sources - Repeat HCl Performance Test 	16	0.2	3.2	4	12.8	0.6
1.3	$1,376

 	 	New Sources - CEMS Monitoring	0.5	1	0.5	4	2.0	0.1	0.2	$215

 	 	New Sources - CEMS Quarterly Inspections	2	4	8	4	32.0	1.6	3.2
$3,439

 	 	New Sources - CEMS Daily Calibration Drift Tests	0.3	300	90	4
360.0	18.0	36.0	$38,694

 	 	New Sources - BLD Quarterly (Seasonal) Adjustments	2	4	8	4	32.0
1.6	3.2	$3,439

 	 	New Sources - Daily monitoring (CEMS and BLD)	0.3	300	90	4	360.0
18.0	36.0	$38,694

 	 	New Sources -- All CEMS must follow appropriate performance
specifications	0.3	300	90	4	360.0	18.0	36.0	$38,694

 	C. Create Information (Included in 4B)









 	D. Gather Existing Information (Included in 4E)









 	E. Write Report









 	 	Existing Sources - Notification of construction/reconstruction*	2
1	2	9	18.0	0.9	1.8	$1,935

 	 	Existing Sources - Notification of actual startup*	2	1	2	9	18.0
0.9	1.8	$1,935

 	 	Existing Sources - Physical or Operational Change*	2	1	2	9	18.0
0.9	1.8	$1,935

 	 	Existing Sources - Notification of Demonstration of CEMS*	2	1	2	9
18.0	0.9	1.8	$1,935

 	 	Existing Sources - Report of Performance Test (included in 4B)*









 	 	Existing Sources - Notification of Initial Performance Test*	2	1	2
9	18.0	0.9	1.8	$1,935

 	 	Existing Sources - Report of Performance Test*	2	1	2	9	18.0	0.9
1.8	$1,935

 	 	Existing Sources - Report of Semi-Annual Reports*	24	2	48	9	432.0
21.6	43.2	$46,433

 	 	Existing Sources - BLD - site-specific monitoring plan*	40	1	40	9
360.0	18.0	36.0	$38,694

 	 	New Sources - Notification of construction/reconstruction	2	1	2	9
18.0	0.9	1.8	$1,935

 	 	New Sources - Notification of actual startup	2	1	2	9	18.0	0.9	1.8
$1,935

 	 	New Sources - Physical or Operational Change	2	1	2	9	18.0	0.9	1.8
$1,935

 	 	New Sources - Notification of Demonstration of CEMS	2	1	2	9	18.0
0.9	1.8	$1,935

 	 	New Sources - Report of Performance Test (included in 4B)









 	 	New Sources - Notification of Initial Performance Test	2	1	2	9
18.0	0.9	1.8	$1,935

 	 	New Sources - Report of Performance Test	2	1	2	9	18.0	0.9	1.8
$1,935

 	 	New Sources - Report of Semi-Annual Reports	24	2	48	9	432.0	21.6
43.2	$46,433

 	 	New Sources - BLD - site-specific monitoring plan	40	1	40	9	360.0
18.0	36.0	$38,694

5. RECORDKEEPING REQUIREMENTS









 	A. Read Instructions (Included in 4A)









 	B. Plan Activities (Included in 4B)









 	C. Implement Activities (Included in 4B)









 	D. Record Data ( Not Applicable)









 	E. Time to Transmit or Disclose Information









 	 	Existing Sources - Data Collection	0.1	300	30	160	4,800.0	240.0
480.0	$515,925

 	 	Existing Sources - Records of Startups, Shutdowns, malfunctions,
etc	1.5	1	1.5	160	240.0	12.0	24.0	$25,796

 	 	New Sources - Data Collection	0.1	300	30	4	120.0	6.0	12.0	$12,898

 	 	New Sources - Records of Startups, Shutdowns, malfunctions, etc
1.5	1	1.5	4	6.0	0.3	0.6	$645

 	F. Time to Train Personnel	16	2	32	164	5,248.0	262.4	524.8	$564,078

 	G. Time for Audits (Not Applicable)









TOTAL ANNUAL LABOR BURDEN AND COST

2456.4

839	17,712	886	1,771	$1,903,773







20,369	Hours

	ANNUAL CAPITAL COSTS









 	Performance tests







$325,232

 	Other Capital Costs of Installation (ODC and Labor)







$1,656,028

 	Total annual capital







$1,981,260

ANNUALIZED CAPITAL COSTS







$3,962,519

 	Total annualized capital







$3,962,519

TOTAL ANNUAL COSTS (O&M)







$174,169

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)







$4,136,688

*Assumes that 10% of the 93 facilities (9 facilities) will have new
construction/reconstruction and will be required to complete performance
tests and new/revised reports.

Table 2a	Year 1 Agency Burden and Cost, NESHAP for Portland Cement
Plants (40 CFR part 63, subpart LLL)]

Activities -- Year 1	(A) EPA Hours/ Occurrence	(B) Occurrences/
Plant/Year	(C) EPA Hours/ Plant/Year (A x B)	(D) Plants/ Year	(E) EPA
Technical Hours/ Year (C x D)	(F) EPA Managerial Hours/Year	(G) EPA
Clerical Hours/Year	(H) Cost, $

Observe Initial Performance Tests	24	1	24	1	24	1.2	0.24	$1,396

Observe Repeat Performance Tests 	24	0.2	4.8	1	4.8	0.24	0.048	$279

Notification of construction/reconstruction commencement	0.5	1	0.5	9	4.5
0.225	0.045	$262

Notification of actual startup	0.5	14	7	9	63	3.15	0.63	$3,664

Notification of performance test	0.5	14	7	9	63	3.15	0.63	$3,664

Notification of Physical or Operational Change	0.5	14	7	9	63	3.15	0.63
$3,664

Review Test/CEMS Results	8	1	8	156	1248	62.4	12.48	$72,587

Review BLD site specific monitoring plan	8	1	8	9	72	3.6	0.72	$4,188

Review Semi-Annual reports	8	1	8	156	1248	62.4	12.48	$72,587

Total Annual Hours



	2,790	139.515	27.903	$162,292







2,957.72	hours

	Travel Expenses







$400

Total







$162,692

Travel Expenses = (1 person x 1 plant/year x 3 days/plant x $50 per
diem) + ($250 round trip/plant x 1 plant/year) = $400/year 

Assumes EPA will visit 1 plant per year

Performance test assumes 10% failure rate or 1 extra plant

Assumes that 10% of the 93 facilities (9 facilities) will have new
construction/reconstruction and will be required to complete performance
tests and new/revised reports.

Table 2b	Year 2 Agency Burden and Cost, NESHAP for Portland Cement
Plants (40 CFR part 63, subpart LLL)]

Activity -- Year 2	(A) EPA Hours/ Occurrence	(B) Occurrences/ Plant/Year
(C) EPA Hours/ Plant/Year (A x B)	(D) Plants/ Year	(E) EPA Technical
Hours/ Year (C x D)	(F) EPA Managerial Hours/Year	(G) EPA Clerical
Hours/Year	(H) Cost, $

Observe Initial Performance Tests	24	1	24	1	24	1.2	0.24	$1,396

Observe Repeat Performance Tests 	24	0.2	4.8	1	4.8	0.24	0.048	$279

Notification of construction/reconstruction commencement	0.5	1	0.5	8	4
0.2	0.04	$233

Notification of actual startup	0.5	14	7	8	56	2.8	0.56	$3,257

Notification of performance test	0.5	14	7	9	63	3.15	0.63	$3,664

Notification of Physical or Operational Change	0.5	14	7	8	56	2.8	0.56
$3,257

Review Test Results	8	1	8	8	64	3.2	0.64	$3,722

Review BLD site specific monitoring plan	8	1	8	8	64	3.2	0.64	$3,722

Review Semi-Annual reports	8	1	8	160	1280	64	12.8	$74,449

Total Annual Hours



	1,616	80.79	16.158	$93,980







1,712.75	hours

	Travel Expenses







$400

Total







$94,380

Travel Expenses = (1 person x 1 plant/year x 3 days/plant x $50 per
diem) + ($250 round trip/plant x 1 plants/year) = $400/year

Assumes EPA will visit 1 plant per year

Performance test assumes 10% failure rate or 1 extra plant

Assumes that 10% of the 93 facilities (9 facilities) will have new
construction/reconstruction and will be required to complete performance
tests and new/revised reports.

Table 2c	Year 3 Agency Burden and Cost, NESHAP for Portland Cement
Plants (40 CFR part 63, subpart LLL)]

Activity -- Year 3	(A) EPA Hours/ Occurrence	(B) Occurrences/ Plant/Year
(C) EPA Hours/ Plant/Year (A x B)	(D) Plants/ Year	(E) EPA Technical
Hours/Year (C x D)	(F) EPA Managerial Hours/Year	(G) EPA Clerical
Hours/Year	(H) Cost, $

Observe Initial Performance Tests	24	1	24	1	24	1.2	0.24	$1,396

Observe Repeat Performance Tests 	24	0.2	4.8	1	4.8	0.24	0.048	$279

Notification of construction/reconstruction commencement	0.5	1	0.5	12	6
0.3	0.06	$349

Notification of actual startup	0.5	14	7	12	84	4.2	0.84	$4,886

Notification of performance test	0.5	14	7	13	91	4.55	0.91	$5,293

Notification of Physical or Operational Change	0.5	14	7	12	84	4.2	0.84
$4,886

Review Test Results	8	1	8	12	96	4.8	0.96	$5,584

Review BLD site specific monitoring plan	8	1	8	12	96	4.8	0.96	$5,584

Review Semi-Annual reports	8	1	8	164	1312	65.6	13.12	$76,310

Total Annual Hours



	1,798	89.89	17.978	$104,566

 





1,905.67	hours

	Travel Expenses







$400

Total







$104,966

Travel Expenses = (1 person x 1 plant/year x 3 days/plant x $50 per
diem) + ($250 round trip/plant x 1 plants/year) = $400/year

Assumes EPA will visit 1 plant per year

Performance test assumes 10% failure rate or 1 extra plant

Assumes that 10% of the 93 facilities (9 facilities) will have new
construction/reconstruction and will be required to complete performance
tests and new/revised reports.

  PAGE   \* MERGEFORMAT  9 

