SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Lime
Manufacturing
(
40
CFR
Part
60,
Subpart
HH)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Lime
Manufacturing
(
40
CFR
Part
60,
Subpart
HH)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
the
regulations
published
at
40
CFR
Part
60,
Subpart
HH
were
proposed
on
May
3,
1977,
and
promulgated
on
April
26,
1984.
These
regulations
apply
to
the
following
facilities
in
40
CFR
Part
60,
Subpart
HH:
each
rotary
lime
kiln
used
in
lime
manufacturing,
which
commenced
construction,
modification
or
reconstruction
after
May
3,
1977.
The
standards
do
not
apply
to
facilities
used
in
the
manufacture
of
lime
at
kraft
pulp
mills.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
HH.

In
general,
all
NSPS
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
NSPS.

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
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
Regional
Office.

Approximately
51
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
one
additional
source
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.

The
Office
of
Management
and
Budget
(
OMB)
requested
that
EPA
address
the
following
"
Terms
of
Clearance"
in
the
re­
submission
of
this
ICR
for
extension:

This
ICR
is
approved
for
three
years.
This
ICR
assumes
that
no
new
sources
will
report
to
EPA
during
the
next
three
years.
Before
re­
submission
of
this
ICR
for
extension,
the
agency
should
revisit
the
estimate
for
the
number
of
new
lime
manufacturing
plants
and
demonstrate
to
OMB
that
the
estimates
are
consistent
with
agency
experience.
Further,
the
agency
should
revise
wage
estimates
to
reflect
guidance
provided
by
EPA
and/
or
OMB.
2
EPA's
Online
T
existing
lime
manu
environmental
staff
a
next
three
years.
Howev
undergo
modifications
such
one
additional
facility
per
year
This
ICR
used
a
revised
technical
la
Bureau
of
Labor
Statistics,
March
2001
for
the
benefit
packages
available
to
those
Estimating
Labor
Costs
,
for
additional
information.
In
addition,
this
Office
of
Planning
and
Management
(
OPM)

on
the
Agency.
See
Section
6(
c),
Estimating
Agency
Burden
and
Cost
,
for
additional
information.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act
(
CAA),
as
establish
standards
of
performance
for
new
stationary
sources
that
reflect:

.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated.

Section
111(
a)(
l).

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).

Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
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.
3
In
the
Administrator's
or
contribute
to
air
pollu
welfare.
Therefore,
NS
Subpart
HH.

2(
b)
Practical
Utility/
Users
of
the
The
control
of
emissions
of
particulate
ma
installation
of
properly
designed
equipment,

equipment.
Emissions
of
particulate
matter
from
the
affected
facilities.
The
subject
standards
are
ac
emissions
using
wet
scrubbers.
The
notifications
requ
inform
the
Agency
or
delegated
authority
when
a
source
the
regulations.
The
reviewing
authority
may
then
inspect
t
control
devices
are
properly
installed
and
operated
and/
or
leak
and
the
regulations
are
being
met.
Performance
test
reports
are
n
record
of
a
source's
initial
capability
to
comply
with
the
emission
sta
of
the
operating
conditions
under
which
compliance
was
achieved.
The
used
for
problem
identification,
as
a
check
on
source
operation
and
mainte
compliance
determinations.
EPA
reduced
the
reporting
frequency
for
this
inf
quarterly
to
semiannually
in
a
December
1990
Federal
Register
Notice.
The
red
reporting
frequency
was
in
response
to
OMB's
previous
questions
regarding
the
nee
quarterly
versus
semiannual
reporting.
The
information
generated
by
monitoring,

recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessa
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
requested
recordkeeping
and
reporting
are
required
under
40
CFR
Part
60,

Subpart
HH.

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.
4
3(
b)
Public
Notice
R
An
announcement
of
a
pub
in
the
Federal
Register
on
Jun
3(
c)
Consultations
This
section
is
intended
to
reflect
addition
the
First
Federal
Register
Notice
(
FFRN).
C
conducted
to
determine
the
industry
growth
rate
of
new
affected
facilities
over
the
next
three
years.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margi
are
continuing
to
meet
the
standards.
Requirements
for
informati
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
emission
limitations
are
met.
If
the
information
required
by
these
stand
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
noncompliance
would
decrease.

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
has
been
determined
not
to
be
confidential.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
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.
5
4.
The
Responden
4(
a)
Respondents/
SIC
C
The
respondents
to
the
recordke
plants
that
commenced
constructio
code
for
the
respondents
affected
by
t
Classification)
3274
which
corresponds
Classification
System)
32741
for
lime
manu
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
require
Subpart
HH.

A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
60,
Part
HH
Notification
of
construction/
reconstruction
60.7(
a)(
1)

Notification
of
actual
startup
60.7(
a)(
3)

Notification
of
any
physical
or
operational
change
60.7(
a)(
4)

Notification
of
demonstration
of
Continuous
Monitoring
System
(
CMS)
60.7(
a)(
5)

Notification
of
the
anticipated
date
of
the
performance
test
60.7(
a)(
6)

Notification
that
continuous
monitoring
system
data
will
be
used
to
determine
compliance
60.7(
a)(
7)

Initial
performance
test
results
60.8(
a)

Semiannual
excess
emissions
report
60.7(
c)

A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
60,
Subpart
HH
Record
of
startups,
shutdowns,
and
malfunctions
60.7(
b)

Records
are
required
to
be
retained
for
two
years
60.7(
f)
6
(
ii)
Respondent
Ac
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
opera
pressure
for
wet
scrubber.

Perform
initial
performance
test,
Reference
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,

systems
for
the
purpose
of
collecting,
validating,
and
verifying
i
Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
p
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
providing
information.

Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,

and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.
7
Agency
Activitie
Input,
analyze,
and
ma
Facility
Subsystem
(
AFS
5(
b)
Collection
Methodolo
Following
notification
of
startup,
t
determine
whether
the
pollution
contr
test
reports
are
used
by
the
Agency
to
di
emission
standard.
Data
and
records
mainta
for
use
in
compliance
and
enforcement
progra
identification,
as
a
check
on
source
operation
and
determinations.

Information
contained
in
the
reports
is
entered
into
AFS
w
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance.

collection,
maintenance,
and
retrieval
of
compliance
data
for
ov
government­
owned
facilities.
EPA
uses
AFS
for
tracking
air
pollu
enforcement
by
local
and
State
regulatory
agencies,
EPA
Regional
Of
Headquarters.
EPA
and
its
delegated
authorities
can
edit,
store,
retrieve
The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
opera
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,
NSPS
For
Lime
Manufacturing
(
40
CFR
Part
60,
Subpart
HH).

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
40
CFR
Part
60,
Subpart
HH.
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
8
major
assumptions
ha
The
Agency
may
not
co
collection
of
information
un
6(
a)
Estimating
Respondent
Bu
The
average
annual
burden
to
industry
and
reporting
requirements
is
estimated
to
These
hours
are
based
on
Agency
studies
and
regulation,
Agency
knowledge
and
experien
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
Technical
Labor
Rate
of
$
57.12
per
hour.
This
rate
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
2001,
"
T
by
occupational
and
industry
group."
The
rate
is
from
column
1,
"
Total
co
wage
rate
has
been
increased
by
110%
to
account
for
the
benefit
packages
av
employed
by
private
industry.

(
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
opacity
monitoring
(
COM).
The
capital/
startup
costs
a
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
($)
for
One
Affected
Facility
(
C)
Number
of
New
Affected
Facilities
to
Startup
(
D)
Total
Startup
(
BxC)
(
E)
Annual
O&
M
Costs
($)
for
One
Affected
Facility
(
F)
Number
of
Affected
Facilities
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Continuous
Opacity
Monitor
$
15,000
1
$
15,000
$
1,500
51
$
76,500
9
The
estimated
cost
$
15,000.
This
estimat
column
D
in
the
above
ta
capital/
startup
costs,
on
the
the
OMB
83­
I
form
are
rounde
The
total
operation
and
maintenance
total
of
column
G.
These
costs
are
show
OMB
83­
I
form.
The
numbers
in
block
14
thousands
of
dollars.

The
total
respondent
non­
labor
costs
in
block
14
ha
the
capital/
startup
costs,
and
the
annual
operation
and
cost
for
capital/
startup
and
operation
and
maintenance
co
of
the
ICR
is
estimated
to
be
$
91,500.
This
cost
is
shown
on
Total
annualized
cost
requested.
The
numbers
in
block
14
of
th
show
the
cost
in
thousands
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
re
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
prog
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
2,766.94
[
see
Table
1:
Average
Annual
EPA
Resource
Requirement,
NSPS
For
Lime
Manufacturing
(
40
CFR
Part
60,
Subpart
HH)].
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
38.30.
This
rate
is
from
the
Office
Planning
and
Management
(
OPM)
"
2002
General
Schedule"
which
excludes
locality
rates
of
pay.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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
60,
Subpart
HH
1
4
51
2
0
106
The
number
of
total
respondents
is
52.
This
represents
the
number
of
existing
sources
10
plus
the
number
of
Number
of
responden
The
number
of
Total
Annua
Respondent
Universe
and
Num
annual
responses,
on
the
OMB
83
The
total
annual
labor
costs
are
$
253,25
form
in
block
13(
c),
Total
hours
requested
Details
upon
which
this
estimate
is
based
app
Recordkeeping
Requirements,
NSPS
For
Lime
M
The
total
annual
capital
and
O&
M
costs
to
the
regulate
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
ann
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
an
6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
And
Cost
Tab
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
th
attached.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.

increase
in
burden
from
most
recently
approved
ICR
is
primarily
due
to
an
increase
in
number
of
existing
sources
as
a
result
of
more
accurate
estimates
of
existing
and
anticipated
sources.
In
addition,
a
revised
technical
labor
rate
resulted
in
an
increase
in
the
respondent
cost
burden
from
the
previous
ICR.

6(
g)
Burden
Statement
Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
42
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.

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
11
Docket
ID
No.
OECA­
2002­
0007,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
(
ECDIC)
Docket
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
Enforcement
and
Compliance
Docket
and
Information
Center
(
ECDIC)
is
(
202)
566­
1514.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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.
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.
(
OECA­
2002­
0007)
OMB
control
number
2060­
0063
in
any
correspondence.

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