SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
the
Portland
Cement
Manufacturing
Industry
(
40
CFR
Part
63,
Subpart
LLL)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
the
Portland
Cement
Manufacturing
Industry
(
40
CFR
Part
63,
Subpart
LLL)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
regulations
published
at
40
CFR
Part
63,
Subpart
LLL
were
proposed
on
March
24,
1998,
and
promulgated
on
June
14,
1999.
These
regulations
apply
to
the
following
facilities:
each
new,
existing
or
reconstructed
kiln,
in­
line
kiln/
raw
mill
and
greenfield
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,
existing
or
reconstructed
clinker
cooler;
raw
mill;
finish
mill;
raw
material,
clinker
or
finished
product
storage
bin;
conveying
system
transfer
point;
bagging
system
and
bulk
loading
and
unloading
system
at
facilities
which
are
major
sources;
and
to
each
existing,
reconstructed
or
new
brownfield
raw
material
dryer
at
facilities
which
are
major
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.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
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.

Approximately
107
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
regulation
over
the
next
three
years.
2
2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
Amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

(
A)
Establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
hazardous
air
pollutant
(
HAP)
emissions
from
portland
cement
manufacturing
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
LLL.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAPs
from
portland
cement
manufacturing
facilities
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAPs
from
portland
cement
manufacturing
facilities
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
capture
of
particulate
HAP
emissions
using
fabric
filters
or
electrostatic
precipitators
control,
temperature
control
for
the
reduction
of
dioxins
and
furans
(
D/
F),
and
feed
selection
for
reduction
of
other
organic
HAP.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and/
or
leaks
are
being
detected
and
repaired
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
3
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63,
Subpart
LLL.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
local
agency.
If
a
State
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

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
on
October
29,
2001.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.
4
3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
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
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
portland
cement
manufacturing
facilities.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
United
States
Standard
Industrial
Classification)
3241
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
32731
for
portland
cement
manufacturing
facilities.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
NESHAP
for
the
Portland
Cement
Manufacturing
Industry
(
40
CFR
Part
63,
Subpart
LLL).
5
A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
63,
Subpart
LLL
Notification
of
applicability
63.9(
b)(
1&
2)

Notification
of
actual
startup
63.9(
b)(
4)

Notification
of
construction/
reconstruction
63.9(
b)(
5)

Request
for
extension
of
compliance
63.9(
c)

Notification
of
special
compliance
requirements
63.9(
d)

Notification
of
initial
performance
test
63.9(
e),
63.7(
b)

Notification
of
opacity
and
visible
emission
observations
63.9(
f)

Notification
of
the
continuous
emission
monitoring
performance
evaluation
63.9(
g)

Notification
of
compliance
status
63.9(
h)

Adjustments
to
time
periods
or
postmark
deadlines
for
submittal
and
review
of
required
communications
63.9(
i)

Change
in
information
already
provided
63.9(
j)

Operations
and
maintenance
plan
63.1350(
a)

Report
of
performance
test
63.10(
d)(
2)

Opacity
and
visual
emission
observation
63.10(
d)(
3)

Progress
reports
63.10(
d)(
4)

Periodic
startup,
shutdown,
malfunction
reports
63.10(
d)(
5)(
i)

Immediate
startup,
shutdown,
malfunction
reports
63.10(
d)(
5)(
ii)

Reporting
results
of
continuous
monitoring
system
performance
evaluations
63.10(
e)(
2)

Excess
emissions
and
continuous
monitoring
system
performance
report
and
summary
report
63.10(
e)(
3)

Reporting
continuous
opacity
monitoring
system
data
produced
during
a
performance
test
63.10(
e)(
4)

Waiver
of
recordkeeping
and
reporting
requirements
63.10(
f)
6
A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
63,
Subpart
LLL
All
reports
and
notifications
63.10(
b)

Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
c)

Records
are
required
to
be
retained
for
five
(
5)
Years.
The
first
two
(
2)
years
of
records
must
be
retained
at
the
facility
63.1355(
a),
63.10(
b)(
1)

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for:
1)
opacity;
2)
to
record
the
temperature
of
the
exhaust
gases
to
monitor
D/
F;
3)
to
record
the
rate
of
carbon
injection
and
the
carrier
gas
parameter,
if
using
activated
carbon
injection
to
control
D/
F;
and
4)
to
measure
Total
Hydrocarbons
(
THC),
if
applicable.

Perform
initial
performance
test,
Reference
Method
5
test
for
Particulates,
Method
9
test
for
Opacity,
Method
23
test
for
dioxin/
furans
(
D/
F),
and
Performance
Specification
8A
of
Appendix
B
to
Part
60
for
THC,
if
applicable.
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.
7
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
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.

5(
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
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AIRS
(
Aerometric
Information
Retrieval
System
Facility
Subsystem
(
AFS)
database
which
is
operated
and
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
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.

These
standards
require
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five
year
records
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
8
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
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
in
Table
2:
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements,
NESHAP
for
the
Portland
Cement
Manufacturing
Industry
(
40
CFR
Part
63,
Subpart
LLL).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
Subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
Control
Number.

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
53,181
[
Total
Labor
Hours
from
Table
2:
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements,
NESHAP
for
the
Portland
Cement
Manufacturing
Industry
(
40
CFR
Part
63,
Subpart
LLL)].
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
9
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
85.81
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
57.12
per
hour
for
Technical
labor,
and
$
36.27
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
2001,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
85.81
($
40.86
+
110%)
Technical
$
57.12
($
27.20
+
110%)
Clerical
$
36.27
($
17.27
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
for
labor
and
continuous
emission
monitoring
(
CEM).
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
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)
Startup
Cost
($)
for
One
Affected
Facility
(
C)
Number
of
New
Affected
Facilities
to
Startup
(
D)
Total
Startup
(
B
X
C)
(
E)
Annual
O&
M
Costs
($)
for
One
Affected
Facility
(
F)
Number
of
Affected
Facilities
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Continuous
Emission
Monitors
$
190,000
0
0
$
6,400
107
$
684,800
There
are
no
capital/
startup
costs
for
this
ICR
due
to
the
fact
that
no
new
facilities
are
expected
to
startup
over
the
next
three
years.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
684,800.
These
costs
are
associated
with
continuous
opacity
monitors
for
50
kilns
and
74
clinker
coolers
located
at
10
major
sources
not
subject
to
the
NSPS;
data
acquisition
systems
for
48
facilities;
temperature
monitoring
and
recording
systems
for
48
facilities;
temperature
monitoring
and
recording
systems
on
170
kiln
air
pollution
control
devices;
THC
CEMS
on
2
new
kilns
and
one
new
raw
material
dryer;
and
particulate
matter
(
PM)
CEMS
on
129
kilns.
The
annual
O&
M
cost
for
one
facility
is
can
be
found
in
column
E.
The
total
O&
M
cost
can
be
found
in
column
G.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
non­
labor
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
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
$
684,800
.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
185,557
(
See
attached
Table
1:
Average
Annual
EPA
Resource
Requirement,
NESHAP
for
the
Portland
Cement
Manufacturing
Industry
(
40
CFR
Part
63,
Subpart
LLL)).
This
cost
is
based
on
the
following
average
hourly
labor
rates:

Managerial
$
51.62
(
GS­
13,
Step
5,
$
32.26
x
1.6)
Technical
$
38.30
(
GS­
12,
Step
1,
$
23.94
x
1.6)
Clerical
$
20.72
(
GS­
6,
Step
3,
$
12.95
x
1.6)]

These
rates
are
from
the
Office
of
Planning
and
Management
(
OPM)
"
2002
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Average
Annual
EPA
Resource
Requirement,
NESHAP
for
the
Portland
Cement
Industry
(
40
CFR
Part
63,
Subpart
LLL).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
11
Respondent
Universe
and
Number
of
Responses
Per
Year
Regulation
Citation
(
A)
Average
Number
of
New
Respondents
per
Year
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD)+
F
40
CFR
Part
63,
Subpart
LLL
0
0
107
2
0
214
The
number
of
total
respondents
is
107.
This
number
is
the
sum
of
column
A
and
column
C
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period.
It
is
shown
in
block
13
(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
214.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
It
is
shown
in
block
13
(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.

The
total
annual
labor
costs
are
$
3,007,594.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
the
Portland
Cement
Manufacturing
Industry
(
40
CFR
Part
63,
Subpart
LLL).

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
684,800.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
section
6(
b)(
iii),
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
During
the
previous
ICR,
all
existing
facilities
were
conducting
performance
testing
to
come
into
compliance
with
the
standard.
As
a
result,
the
majority
of
the
burden
hours
from
the
previous
ICR
were
associated
with
initial
notifications
and
performance
testing
and
reporting.
Since
the
compliance
date
has
recently
past,
it
is
assumed
that
all
existing
facilities
have
completed
compliance
testing
during
the
previous
ICR
period.
Therefore,
all
of
the
burden
hours
associated
with
this
ICR
are
related
to
reporting
requirements
for
facilities
that
have
already
demonstrated
compliance.
No
new
facilities
are
expected
to
startup
over
the
next
three
years.
12
6(
g)
Burden
Statement
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
standards
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
Ms.
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822T),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
Number
and
OMB
Control
Number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
