STANDARD
FORM
83
SUPPORTING
STATEMENT
ICR
NO.
2072.02
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
(
NESHAP)
FOR
LIME
MANUFACTURING
(
40
CFR
PART
63,
SUBPART
WWWW)

U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
North
Carolina
27711
June
2003
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.
NESHAP
for
Lime
Manufacturing
(
40
CFR
part
63,
subpart
WWWW),
ICR
No.
2072.02.
(
b)
Short
Characterization/
Abstract.
Potential
respondents
are
owners
or
operators
of
new
or
existing
lime
manufacturing
plants.
The
final
rule
applies
to
lime
manufacturing
plants
that
are
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions;
but
the
final
rule
does
not
apply
to
lime
plants
at
pulp
and
paper
mills
or
beet
sugar
factories.
Emission
limitations
for
particulate
matter
(
PM)
are
promulgated
for
kilns
(
including
coolers
if
applicable)
along
with
operating
limits
for
control
devices.
Emissions
from
material
processing
operations
associated
with
transferring
limestone
from
feed
stockpiles
to
kilns
are
subject
to
PM
and/
or
opacity
(
or
no
visible
emissions
(
VE))
limits.
Plants
are
required
to
conduct
performance
tests
to
demonstrate
initial
compliance
with
each
emission
and
opacity
limit
and
establish
operating
limits
for
control
devices.
The
final
rule
also
requires
all
plants
to
prepare
an
operation,
maintenance,
and
monitoring
plan
for
affected
sources
and
control
devices
in
addition
to
a
startup,
shutdown,
and
malfunction
plan.
All
plants
must
demonstrate
initial
compliance
by
3
years
after
promulgation
except
that
under
Section
112(
i),
plants
may
request
an
additional
year
if
needed
to
install
controls.
To
demonstrate
continuous
compliance,
plants
must
conduct
repeat
performance
tests
(
every
5
years),
monitor
operating
parameters
for
control
devices,
and
perform
annual
inspections
of
emission
capture,
collection,
and
transport
systems.
Brief
monthly
VE
tests
are
required
for
certain
material
processing
operations
with
semiannual
or
annual
tests
if
no
VE
are
observed.
If
VE
are
observed,
a
6­
minute
opacity
test
is
required
to
demonstrate
compliance
with
the
opacity
limit
and
monthly
VE
tests
resume.
Respondents
must
submit
one­
time
notifications
as
required
by
the
NESHAP
General
Provisions
and
semiannual
compliance
reports
explaining
any
deviation.
An
immediate
report
is
required
if
actions
taken
in
response
to
the
startup,
shutdown,
or
malfunction
are
not
consistent
with
the
written
startup,
2
shutdown,
and
malfunction
plan.
Respondents
must
maintain
records
of
specific
information
to
ensure
that
the
emission
limitations
and
requirements
are
being
achieved
and
maintained.
These
requirements
are
listed
in
Attachment
1.
2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
charged
under
section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
NESHAP
for
new
or
existing
major
sources
or
area
sources
that
reflect:
...
the
maximum
degree
of
reduction
in
emissions
of
[
HAPs]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
emission
reduction,
any
nonair
quality
health
and
environmental
reduction,
and
energy
requirements.
[
section
112(
d)(
2)]

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).
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.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.
7414)
and
set
out
in
the
NESHAP
General
Provisions.

(
b)
Practical
Utility/
Users
of
the
Data.

The
information
will
be
used
by
Agency
enforcement
personnel
to:
(
1)
identify
major
sources
and
new
or
reconstructed
sources
subject
to
the
standards,
(
2)
ensure
that
MACT
is
being
properly
applied,
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.

Based
on
the
reported
information,
EPA
can
decide
which
plants,

records,
or
processes
should
be
inspected.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.
The
information
required
by
the
Lime
Manufacturing
NESHAP
is
not
duplicated
by
existing
EPA
3
regulations
and
is
not
expected
to
be
required
by
any
other
EPA
rulemaking
currently
in
progress.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,

a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.
The
EPA
has
issued
guidance
to
State
and
local
agencies
encouraging
them
to
consolidate
duplicative
requirements
into
a
single
element
to
be
reported.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.

This
section
is
not
applicable
since
public
notice
was
given
as
part
of
the
proposal
process
for
the
mercury
cell
chlor­
alkali
NESHAP.

(
c)
Consultations.

This
final
rule
was
developed
with
participation
from
the
National
Lime
Association,
individual
lime
manufacturing
companies,
control
equipment
vendors,
Federal
agencies,
and
State
and
local
air
pollution
control
agencies.
This
final
rule
also
takes
into
consideration
the
findings
of
the
Small
Business
Advocacy
Review
Panel
(
SBAR
Panel)
convened
under
the
authority
of
the
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996
(
SBREFA).

Key
non­
EPA
persons
consulted
prior
to
proposal
of
the
standards
are
identified
in
Table
1.

TABLE
1.
PERSONS
CONSULTED
ON
INFORMATION
COLLECTION
ACTIVITIES
Contact
Organization
Telephone
Number
Arline
Seeger
National
Lime
Association
703
243­
5463
Jonathon
Pawlow
Small
Business
Administration
202
205­
6951
David
Ousley
State
of
Alabama
334
271­
7861
Bryon
Allen
Office
of
Management
and
Budget
202
395­
3087
4
(
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
of
the
OMB
regulations
implementing
the
Paperwork
Reduction
Act
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
1,
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/
SIC
Codes.

Of
the
110
lime
manufacturing
plants
currently
in
operation,

we
estimate
that
30
of
the
plants
are
associated
with
beet
sugar
production
and
are
not
be
subject
to
the
requirements
of
the
final
rule.
Of
the
80
remaining
plants,
70
percent
(
56
plants)

are
believed
to
be
major
sources
of
HAP
emissions
and
are
subject
to
the
requirements
of
the
final
rule.
No
new
plants
are
expected
over
the
3­
year
clearance
period
for
this
ICR
although
6
new
kilns
are
projected.
The
NAICS
codes
for
the
respondents
are
32741)
for
commercial
plants,
33111
for
captive
plants
at
iron
and
steel
mills,
and
3314
for
captive
plants
at
nonferrous
metal
production
facilities.
Respondents
also
include
non­
clay
(
dead
burned
dolomite)
refractory
plants
classified
under
327125.

(
b)
Information
Requested.
5
(
i)
Data
Items,
Including
Recordkeeping
Requirements.

Attachment
1,
Source
Data
and
Information
Requirements,

summarizes
the
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
Activities.
The
respondent
activities
required
by
the
rule
are
identified
in
Table
2
and
introduced
in
section
6(
a).

5.
The
Information
CollectedBAgency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
Table
3
and
introduced
in
section
6(
c).

(
b)
Collection
Methodology
and
Management.

Information
contained
in
the
reports
will
be
entered
into
EPA's
Aerometric
Information
and
Retrieval
System
(
AIRS)
which
is
operated
and
maintained
by
the
Office
of
Enforcement
and
Compliance
Assurance.
AIRS
contains
emissions,
compliance,
and
enforcement
data
on
stationary
sources.
Data
obtained
from
records
maintained
by
the
respondent
during
periodic
visits
by
Agency
personnel
will
be
tabulated
and
published
for
internal
EPA
use
in
enforcement
and
compliance
programs.

(
c)
Small
Entity
Flexibility.

In
the
lime
manufacturing
industry,
a
small
entity
is
defined
as
a
lime
manufacturing
company
having
no
more
than
500
employees.
Of
the
39
companies
that
have
plants
that
are
subject
to
the
rule,
EPA
identified
12
entities
that
are
small
businesses.
Because
of
the
potential
impacts
on
small
businesses,
a
Small
Business
Advocacy
Review
Panel
(
SBAR
Panel)

was
convened
under
the
authority
of
the
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996
(
SBREFA).
The
SBAR
Panel
considers
the
concerns
of
small
entitiy
representatives
and
issues
findings
and
recommendations
relative
to
the
proposed
rule
under
development.

EPA
has
carefully
considered
the
findings
and
recommendations
of
6
the
SBAR
Panel
and
has
developed
a
final
rule
that
is
appropriate
for
all
companies,
including
small
entities.

The
final
rule
will
reduce
HAP
emissions
while
keeping
the
associated
recordkeeping
and
reporting
burden
to
a
minimum.
For
example,
existing
affected
plants
have
3
years
to
demonstrate
compliance
and
the
Administrator
or
permitting
authority
may
grant
one
additional
year
if
more
time
is
needed
to
install
controls.
Lime
manufacturing
facilities
at
beet
sugar
plants
or
those
that
produce
hydrated
lime
only
are
not
covered.
The
promulgated
emission
limits
are
based
on
the
MACT
floor
rather
than
on
more
costly
options
that
are
beyond
the
MACT
floor.
The
final
rule
provides
flexibility
to
affected
sources,
including
small
entities,
in
choosing
how
they
will
meet
the
PM
emission
limits.
Compliance
demonstrations
for
material
processing
operations
are
based
on
monthly,
rather
than
daily,
monitoring
which
will
reduce
the
recordkeeping
burden.
Furthermore,
the
minimum
performance
testing
frequency
(
every
5
years)
is
being
promulgated.
Because
the
rule
does
not
apply
to
area
sources,

many
small
lime
manufacturing
plants
will
not
be
subject
to
the
rule.

The
final
rule
provides
a
maximum
degree
of
operational
flexibility
and
the
ICR
requirements
are
the
minimum
necessary
to
demonstrate
compliance.

(
d)
Collection
Schedule.

The
compliance
date
of
the
standard
is
3
years
after
promulgation
of
the
rule.
Compliance
reports
are
required
semiannually
beginning
with
the
compliance
date
of
the
rule.

Existing
affected
sources
must
submit
their
initial
notification
no
later
than
120
days
after
the
effective
date
of
the
standard.

Affected
sources
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
days
before
the
test
is
scheduled
to
begin.
Additional
notifications
are
triggered
by
actions
of
the
respondents.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
7
(
a)
Estimating
Respondent
Burden.

The
information
burden
estimates
for
reporting
and
recordkeeping
are
presented
in
Table
2.
These
numbers
were
derived
from
estimates
based
on
EPA's
knowledge
and
experience
with
the
NESHAP
program
and
with
previously
approved
ICR.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
the
final
rule
are
presented
in
Table
2.
Because
much
of
the
data
are
already
collected
by
respondents
or
required
by
existing
law,
minimal
respondent
development
costs
are
associated
with
the
information
collection
activities
for
the
final
rule.

(
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
civilian
workers
were
taken
from
the
2000
Employment
Cost
Trends
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t02.
htm).
Wages
for
civilian
workers
(
white­
collar
occupations)
are
used
as
the
basis
for
the
labor
rates
with
a
total
compensation
of
$
26.15/
hour
for
technical,
$
37.19/
hour
for
managerial,
and
$
17.22/
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
$
54.92,
management
at
$
78.10,
and
clerical
at
$
36.16.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)

Costs.
It
is
assumed
that
for
each
kiln
control
device,
a
bag
leak
detector
will
be
installed.
The
one­
time
capital
cost
for
a
bag
leak
detector
is
estimated
to
be
$
10,000,
with
a
total
annual
cost
of
$
3,300/
yr.
Estimated
annual
O&
M
cost
for
all
bag
leak
detectors
averaged
over
the
3­
year
ICR
period
is
$
206,333.
As
shown
in
Table
2,
the
total
annualized
capital
and
operation
and
maintenance
costs
are
estimated
to
be
$
377,933
per
year.
8
(
iii)
Capital/
Startup
vs.
O&
M
Costs.
The
annual
O&
M
cost
averaged
over
the
3­
year
period
of
this
ICR
is
an
estimated
$
206,333.
The
estimate
of
capital/
startup
costs
versus
O&
M
costs
is
shown
in
Table
2.

(
iv)
Annualizing
Capital
Costs.
For
52
kilns/
yr
over
the
3­
year
ICR
period,
the
annualized
capital
cost
for
bag
leak
detectors
will
be
$
171,600
per
year.

(
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
General
Provisions
for
the
MACT
standards,
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
Table
3.
Labor
rates
and
associated
costs
for
the
Agency
are
assumed
to
be
the
same
as
the
respondent's
hourly
rates.
The
Agency
labor
rates
are
estimated
as
follows:
technical
at
$
54.92,
management
at
$
78.10,
and
clerical
at
$
36.16.

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

The
EPA
estimates
that
56
facilities
will
install
the
required
monitoring
equipment;
conduct
initial
performance
tests;

prepare
operation,
maintenance,
and
monitoring
plans
and
startup,

shutdown,
and
malfunction
plans;
provide
the
one­
time
9
notifications;
and
keep
required
records
during
the
3­
year
clearance
period
for
this
ICR.
Details
on
the
number
of
respondents
and
process
units
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
2.
The
total
burden,

provided
in
Table
2,
is
7,766
hours;
the
estimated
cost
associated
with
this
burden
is
$
621,673
per
year
including
technical,
management,
and
clerical
hours.
The
total
cost
given
in
Table
2,
including
the
cost
of
labor,
capital,
operation,
and
maintenance,
is
$
1.0
million
per
year.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
Table
2,
are
calculated
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,

and
clerical
staff,
and
by
adding
down
the
cost
column.
The
total
annual
hours
are
7,766
hours.
The
annualized
cost
of
capital
for
monitoring
devices
is
$
171,600
averaged
over
the
first
3
years
of
the
ICR.
Monitoring
device
operation
and
maintenance
costs
(
excluding
any
labor
hours
given
in
the
labor
burden
estimate)
are
estimated
at
$
206,333
per
year
over
the
3­

year
ICR
period.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Table
3,
are
calculated
as
in
the
respondent
table,
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,
total
cost
is
the
sum
of
this
total
salary
cost
and
total
travel
expenses
for
tests
attended.
The
total
annual
hours
are
159.
The
total
annual
cost
is
$
7,169.

(
iii)
Variations
in
the
annual
bottom
line.
This
section
does
not
apply
since
no
significant
variation
is
anticipated.

(
f)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
ICR.

(
g)
Burden
Statement
10
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
415
hours
per
facility.
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
are
listed
in
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
No.
OAR­
2002­
0052
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,

Room
B102,
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
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
11
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.
Once
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,
DC
20503,
Attention:

Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OAR­

2002­
0052
in
any
correspondence.

PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
12
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
PROMULGATED
STANDARD
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
H)
Cost,$
a
1.
Applications
N/
A
0
0
0
0
$
0
2.
Survey
and
Studies
N/
A
0
0
0
0
$
0
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
40
1
40
18.7b
748
$
46,706
4.
Reporting
Requirements
A.
Read
instructions
2
1
2
18.7b
37
$
2,335
B.
Required
activities
Method
5
performance
test
for
kilns
52c
$
130,000
Method
5
performance
test
for
material
handlingd
18.7d
$
70,000
Repeat
PM
performance
testse
N/
A
0
0
0
0
$
0
Monthly/
semiannual,
or
annual
VE
tests
for
material
handlinge
N/
A
0
0
0
0
$
0
Annual
inspection
of
capture,

collection,
and
transport
systemse
0
0
0
0
0
$
0
Inspection
and
maintenance
of
affected
sources,
control
devices,
and
monitoring
systems
according
to
operation,

maintenance,
and
monitoring
plane
N/
A
0
0
0
0
$
0
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
PROMULGATED
STANDARD
(
continued)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
H)
Cost,$
a
13
E.
Write
report
Notification
of
applicability
2
1
2
18.7f
37
$
2,335
Notification
of
constr./
reconstr.
2
1
2
2g
4
$
250
Notification
of
anticipated
startup
2
1
2
2g
4
$
250
Notification
of
actual
startup
2
1
2
2g
4
$
250
Notification
of
special
compliance
requirements
N/
A
0
0
0
0
$
0
Compliance
extension
request
2
1
2
18.7b
37
$
2,335
Notification
of
performance
tests
2
1
2
54g
108
$
6,744
Notification
of
opacity/
VE
observations
2
1
2
2
d
4
$
250
Operation,
maintenance,
and
monitoring
plan
40
1
40
18.7b
748
$
46,706
Startup,
shutdown,
and
malfunction
plan
40
1
40
18.7b
748
$
46,706
Site­
specific
test
plan
40
1
40
18.7b
748
$
46,706
Notification
of
compliance
status
8
1
8
18.7b
150
$
9,341
NESHAP
waiver
application
N/
A
0
0
0
0
$
0
Semiannual
compliance
reportse
N/
A
0
0
0
0
$
0
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
PROMULGATED
STANDARD
(
continued)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
H)
Cost,$
a
14
Emergency
startup,
shutdown,
or
malfunction
reportse
N/
A
0
0
0
$
0
5.
Recordkeeping
Requirements
A.
Read
instructions
See
4A
B.
Plan
activities
3
1
3
18.7b
56.1
$
3,503
C.
Implement
activities
12
1
12
18.7b
224.4
$
14,012
D.
Develop
record
system
3
1
3
18.7b
56.1
$
3,503
E.
Time
to
enter
information
Records
of
all
info.
required
by
standards
3
52
h
156
18.7b
2,917
$
182,153
F.
Time
to
train
personnel
3
1
3
18.7b
56.1
$
3,503
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
3
1
3
18.7b
56.1
$
3,503
H.
Time
to
transmit
or
disclose
information
0.25i
2
0.5
18.7b
9.4
$
584
I.
Time
for
audits
N/
A
0
0
0
0
$
0
TOTAL
LABOR
BURDEN
AND
COST
Total
Technical
hrs
Management
hrs
Clerical
hrs
Total
hrs
6,753.2
337.7
675.3
7,766.1
$
621,673
Annualized
cost
of
capitalj
$
171,600
Operation
and
maintenance
(
O&
M)
$
206,333
Total
(
capital
recovery
plus
O&
M)
$
377,933
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
PROMULGATED
STANDARD
(
continued)

15
Footnotes
to
Table
2
a
Costs
are
based
on
the
following
hourly
labor
rates:
technical
at
$
54.92,
management
at
$
78.10,
and
clerical
at
$
36.16.

b
One
time
event
for
56
respondents
over
3­
year
term
of
ICR
is
56/
3
=
18.7
respondents/
yr.

c
Method
5
performance
tests
are
required
for
150
existing
kilns.
A
total
of
6
new
kilns
are
expected
over
the
3­
year
term
of
the
ICR.
One­
time
test
for
156
kilns
over
3­
year
term
of
ICR
=
52
tests/
yr.
The
annualized
cost
for
a
Method
5
performance
test
is
$
2,500.

d
Assume
that
56
plants
have
material
handling
operations
and
would
incur
a
one­
time
cost
of
$
15,000
($
3,750
annualized)
to
perform
Method
5
performance
tests.
Costs
are
based
on
two
PM
tests/
plant
for
MHO's.
The
total
one­
time
cost
for
the
first
PM
test
is
$
10,000
and
a
$
5,000
onetime
cost
for
each
additional
test.
The
annualized
costs
is
calculated
as
follows:
1*
2500
+
(
1*
1250)
=
$
3,750
per
plant.
For
the
56
respondents
over
the
3­
yr
ICR
term,
the
cost
is:
56/
3($
3,750)
=
$
70,000.

e
This
activity
will
not
occur
during
the
3­
year
clearance
period
of
this
ICR.

f
One
time
event
for
56
existing
respondents
over
3­
year
term
of
ICR
is
56/
3
=
18.7
respondents/
yr.
No
new
plants
are
expected.

g
One
time
notification
for
50
PM
tests/
yr
of
existing
kilns,
2
PM
tests/
yr
at
plants
with
existing
material
handling
operations
and
PM
tests
for
2
new
kilns/
yr
over
the
3­
year
period
of
ICR.
Total
notifications
over
3­
year
term
of
ICR
is
50
+
2
+
2
=
54/
yr
h
Assumes
3
hours
per
week
per
plant
to
enter
into
records.

i
Assumes
15
minutes
to
transmit
recorded
information.

J
Cost
includes
156
bag
leak
detection
systems
for
new
and
existing
lime
kilns.
16
16
TABLE
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
OF
THE
PROMULGATED
STANDARD
Activity
(
A)

Hours
per
occurrence
(
B)

Hours
per
plant
per
year
(
C)
Plants
per
year
(
D)
Technical
person­
hours
per
year
(
D=
BxC)
(
E)
Management
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
person­
hours
per
year
(
Dx0.1)
(
G)

Cost,
$
a
Initial
performance
tests
40
40
1b
40
2.0
4.0
$
2,498
Repeat
performance
test­
Retesting
preparation
2
2
0.0c
0
0.0
0.0
$
0
Repeat
performance­
Retesting
40
40
0.0c
0
0
0
$
0
Litigation
2080
2080
0.0d
0
0
0
$
0
Excess
Emissions
Enforcement
Activities
120
120
0.0d
0
0
0
$
0
Report
Review
Notification
of
applicability
1
1
18.7e
19
1
2
Notification
of
constr./
reconstr.
1
1
2f
2
0
0
Notification
of
anticipated
startup
1
1
2f
2
0
0
Notification
of
actual
startup
1
1
2f
2
0
0
Notification
of
special
compliance
requirements
N/
A
0
0
0
0
0
Notification
of
initial
performance
tests
1
2
18.7e
37
1.9
3.7
$
2,336
Notification
of
compliance
status
4
2
18.7e
37
1.9
3.7
$
2,335
Review
of
repeat
performance
test
report
N/
A
0
0.0c
0
0.0
0.0
$
0
Review
of
semi­
annual
compliance
report
N/
A
0
0.0f
0
0.0
0.0
$
0
Review
of
NESHAP
waiver
application
N/
A
0
0.0g
0
0
0
$
0
Review
of
emergency
startup,
shutdown,
and
malfunction
report
N/
A
0
0.0
f
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY)
139
7
13
$
7,169
Travel
Expenses
for
Tests
Attendedh
(
1
person
x
1
plant/
yr
x
1
day/
plant
x
$
100
per
diem)
+
($
400/
round
trip
x
1
round
trips/
yr)
=
$
500
TOTAL
ANNUAL
COST
$
7,418
+
$
500
=
$
7,918
17
Footnotes
to
Table
3
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
54.92,
management
at
$
78.10,
and
clerical
at
$
36.16.

b
Assumes
EPA/
State
personnel
will
attend
3
performance
tests
over
3
years
(
3/
3
=
1).

c
Assumes
no
plants
have
to
repeat
their
performance
test
over
the
3­
year
term
of
the
ICR.

d
Assumes
no
plants
will
be
involved
in
litigation
or
excess
emissions
enforcement
activities
over
the
3­
year
term
of
the
ICR.

e
For
56
plants
over
3­
year
term
of
the
ICR
(
56/
3
=
18.7).

f
Assumes
no
plants
will
submit
semi­
annual
reports
or
emergency
startup,
shutdown,
and
malfunction
reports
during
the
3­
year
clearance
period
of
this
ICR.

g
Assumes
no
plants
ask
for
waivers
or
have
an
emergency
report.
18
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions
citation
Record
retention1
NOTIFICATIONS
Applicability
63.7130(
a)
63.9(
b)
5
years
Anticipated
startup
63.130(
a)
63.9(
b)(
4)
5
years
Commencement
of
construction
63.7130(
a)
63.9(
b)(
4)
5
years
Actual
startup
63.7130(
a)
63.9(
b)(
4)
5
years
Intention
to
construct/
reconstruct
63.7130(
a)
63.9(
b)(
4)­(
5)
5
years
Compliance
dates/
extension
63.7130(
a)
63.9(
c)
5
years
Performance
test/
opacity
observations
63.7130(
a)
63.9(
e)
5
years
Compliance
status
63.7130(
a)
63.9(
g)
5
years
PLANS
AND
REPORTS
Operation,
maintenance,
and
monitoring
plan
63.7100(
d)
N/
A
5
years
Startup,
shutdown,
and
malfunction
plan
63.7100(
e)
63.6(
e)(
3)
5
years
Semiannual
compliance
report
63.7131(
b)
63.10(
d)(
2)
5
years
Emergency
startup,
shutdown,
malfunction
reports2
63.7131(
b)
63.6(
e)(
3),
63.10(
d)(
5)
5
years
RECORDKEEPING
Notifications
and
reports
63.7132(
a)(
1)
63.10(
b)(
2)(
xiv)
5
years
Startup,
shutdown,
and
malfunction
plan/
events
63.7132(
a)(
2)
63.6(
e)(
3)(
iii)­(
v)
5
years
Performance
tests
and
opacity
observations
63.7132(
a)(
3)
63.10(
b)(
2)(
viii)
5
years
Records
required
to
demonstrate
continuous
compliance
63.7132(
c)
63.10(
b)(
2)(
vii)
5
years
Visual
observations
63.7132(
b)
63.6(
h)(
6)
5
years
1
All
records
must
be
retained
for
at
least
5
years.
The
records
for
the
most
recent
2
years
must
be
retained
onsite
but
records
for
the
remaining
3
years
may
be
kept
offsite
but
available
for
review.

2
Includes
reports
of
startups,
shutdowns,
or
malfunctions
where
procedures
in
startup,
shutdown,
and
malfunction
plan
were
not
followed.
