	SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NSPS for Lime Manufacturing (40 CFR part 60, subpart HH) (Renewal), EPA
ICR 1167.09, OMB Control Number 2060-0063

	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,
promulgated on April 26, 1984, and amended on October 17, 2000 (65 FR
61760).  These regulations apply to each rotary lime kiln used in the
manufacturing of lime, which commenced construction or modification
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 by the owners/operators of the
affected facilities.  They are also required to maintain records of the
occurrence and duration of any startup, shutdown, or malfunction in the
operation of an affected facility, or any period during which the
monitoring system is inoperative.  These notifications, reports, and
records are essential in determining compliance, and are required of all
affected facilities subject to NSPS.

	Any owner/operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
two years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) regional office.

	Based on our consultations with industry representatives, there are an
average of 2.47 affected facilities at each plant site and each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

	Approximately 41 respondents are currently subject to the regulation,
and it is estimated that no additional respondents per year will become
subject to the regulation in the next three years.

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

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost - NSPS for Lime Manufacturing (40 CFR Part
60, Subpart HH) (Renewal).  The burden to the “Federal Government”
is attributed entirely to work performed by federal employees or
government contractors; this burden may be found in Table 2: Average
Annual EPA 

Burden - NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH)
(Renewal).

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

	The EPA is charged under section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every four years.

	In addition, section 114(a) states that the Administrator may require
any owner/operator subject to any requirement of this Act to: 

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

	In the Administrator's judgment, particulate matter emissions from
rotary lime kilns cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NSPS were promulgated for this source category at 40 CFR
part 60, subpart HH.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

	

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to 

ensure compliance with the standard at all times.  During the
performance test, a record of the operating parameters under which
compliance was achieved may be recorded and used to determine compliance
in place of a continuous emission monitor.

	The notifications required in the standard 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 ensure that the pollution control devices are
properly installed and operated, that leaks are being detected and
repaired, and that the standards are being met.  The performance test
may also be observed.

	The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Non-duplication, Consultations, and Other Collection Criteria

	The requested recordkeeping and reporting are required under 40 CFR
part 60, subpart HH.

	3(a)  Non-duplication

	 If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, 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 (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

	3(c)  Consultations

	

	For the information collection, past consultations included referencing
the most recent ICR, consultation with the preparer of the active ICR,
and use of other resources to obtain the most recent data available. 
Information from the United States Census Bureau, U.S. Department of the
Interior, U.S. Geological Survey, the Air facility System (AFS), and
websites covering lime manufacturing plants was reviewed; additionally,
EPA’s Office of Air Quality Planning and 

standards, Information Transfer, the Program Integration Division, and
the National Lime Association were consulted.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.  In this case, no comments were received.

	3(d)  Effects of Less Frequent Collection

	

	Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet 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.

	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

	

	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
lime manufacturing plants.  The United States Standard Industrial
Classification (SIC), codes for the respondent 

affected by the standards are SIC 3274, which corresponds to the North
American Industry Classification System (NAICS) 327410 for Lime
Manufacturing.

	

Information Requested

	

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR 1320.5.

		(i)  Data Items

	

	All data in this ICR that is recorded and/or reported is required by
NSPS Lime Manufacturing (40 CFR part 60, subpart HH).

	A source must make the following reports:

Notifications	Standard Citation by Sections

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 make the following reports:

Recordkeeping

Record of startup, shutdown, and malfunctions	60.7(b)

Records are required to be retained for two years	60.7(f)

Observe and record Method 9 opacities	60.344(b)(4) and 60.11(b)



Electronic Reporting

At the present, respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

	Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for
pressure drop and liquid supply pressure for wet scrubber.

Perform initial performance test, Reference Method 9 test, and repeat
performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.

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

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

Transmit, or otherwise disclose the information.



5.  The Information Collected: Agency Activities, Collection
Methodology, and Information Management

	

	5(a)  Agency Activities

	

	EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

	Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

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

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).



	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 the 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
data for approximately 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/operator for two years.

	

	5(c)  Small Entity Flexibility

	A majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  The number of small entities affected by this rule could
not be determined, based on review of the following sources: the
promulgated rule notice in the Federal Register; the Standards Support
and Environmental Impact Statement Volume I: Proposed Standards of
Performance for Lime Manufacturing Plants (1977); and a search of
publicly available current data sources.  The Environmental Impact
Statement document concludes that the trend is toward new plants with
production greater than 300 tons per day; plant size has been increasing
steadily and should continue to do so.

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 1: Annual Industry Burden for NSPS for
Lime Manufacturing (40 CFR Part 60, Subpart HH).

	

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

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

	6(a)  Estimating Respondent Burden

	

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 3,773
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
regulation, Agency knowledge and experience with the NSPS program, the
previously approved ICR, and any comments received.

	6(b)  Estimating Respondent Costs

	

		(i)  Estimating Labor Costs 

	 

	This ICR uses the following labor rates: 

			Managerial	$97.46   ($46.41 + 110%)

			Technical	$83.71   ($39.86 + 110%)

			Clerical	$42.55   ($20.26 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “Table 2. Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	

	The type of industry costs associated with the information collection
activities in the subject standard are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

	

	(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Cost

	

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost, 

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

Continuous Opacity Monitor	$15,000	0	$0	$1,500	41	$61,500

	

	The total capital/startup costs for this ICR are zero.  This is the
total of column D in the above table.

	

	The total operation and maintenance (O&M) costs for this ICR are
$61,500.  This is the total of column G.

	

	The total respondent 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 $61,500.	

	

6(c)  Estimating Agency Burden and Cost

	

	The only costs to the Agency are those costs associated with analysis
of the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information.

	

	The average annual Agency cost during the three years of the ICR is
estimated to be $15,292.

	

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

			Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

			Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

			Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: NSPS for Lime
Manufacturing (40 CFR Part 60, Subpart HH) (Renewal), attached.

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

	

	Based on our research for this ICR, on average over the next three
years, approximately 41 existing respondents will be subject to the
standard.  It is estimated that no additional respondents per year will
become subject.  The overall average number of respondents, as shown in
the table below is 41 per year.

	The number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of New Respondents 	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)

1	0	41	0	0	41

2	0	41	0	0	41

3	0	41	0	0	41

Average	0	41	0	0	41

	.

	To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 41.

	 

	The total number of annual responses per year is calculated using the
following table: 

	

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses 

E=(BxC)+D

Notification of actual startup	0	1	0	0

Notification of initial performance test	0	1	0	0

Notification of any physical or operational changes	0	1	0	0

Notification of demonstration of CMS	0	1	0	0

Notification that continuous monitoring system (CMS)	0	1	0	0

Semiannual excess emission report	41	2	0	82



	Total	82



	The number of Total Annual Responses is 82.

		6(e)  Bottom Line Burden Hours and Cost Tables

	The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

	

		(i) Respondent Tally

	

	The total annual labor costs are $304,556.  Details regarding these
estimates may be found in Table 1: Annual Respondent Burden and Cost,
NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal),
attached.  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 46
hours per response 

	The total annual capital/startup and O&M costs to the regulated entity
are $61,500.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

		(ii) The Agency Tally

	

	The average annual Agency burden and cost over next three years is
estimated to be 377 labor hours at a cost of $15,292.  See Table 2:
Annual Agency Burden and Cost, NSPS for Lime Manufacturing (40 CFR Part
60, Subpart HH) (Renewal), attached.

	6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents in this
ICR compared to the previous ICR.  This is due to two considerations. 
First, the regulations have not changed over the past three years and
are not anticipated to change over the next three years.  Secondly, the
growth rate for respondents is very low, negative, or non-existent. 
Therefore, the labor hours and cost figures in the previous ICR reflect
the current burden to the respondents and are reiterated in this ICR. 
Apparent differences of less than $500 are attributable to rounding; in
previous years, O&M costs were rounded to the nearest thousand; this ICR
presents more exact figures.

	6(g)  Burden Statement

	

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 46 hours per response.
 Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, disclose,
or provide information to or for a Federal agency.  This includes the
time needed to review instructions; develop, acquire, install, and
utilize technology and systems for the purposes of collecting,
validating, and verifying information, processing and maintaining
information, and disclosing and providing information; adjust the
existing ways to comply with any previously applicable instructions and
requirements; train personnel to be able to respond to a collection of
information; search data sources; complete and review the collection of
information; and transmit or otherwise disclose the information.

	

	An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

	

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2008-0363.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1927.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2008-0363 and 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
collecting this information.



Table 1:  Annual Respondent Burden and Cost - NSPS for Lime
Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per 	year

(Ex0.1)	

(H)

Cost, $  b



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Reporting Requirements	

	

	

	

	

	

	

	





  A.  Read instructions	

1	

1	

1	

0	

0	

0	

0	

$0



  B.  Required activities:	

	

	

	

	

	

	

	





        Initial performance tests  c	

280	

1	

280	

0	

0	

0	

0	

$0



        Reference Method 9 Test d	

4	

1.2	

4.8	

0	

0	

0	

0	

$0



        Repeat of performance test e	

280	

          0.2	

56	

0	

0	

0	

0	

$0



 C.   Create information	

Included in 3B



	

	

	

	





 D.  Gather Existing Information	

Included in 3B









 E.  Write report











      Notification of construction /            reconstruction	

2	

1	

2	

0	

0	

0	

0	

$0

      

      Notification of actual startup	

2	

1	

2	

0	

0	

0	

0	

$0



      Notification of initial                        

     performance test	

2

	

1	

2	

0	

0	

0	

0	

$0



     Notification of any physical or          operational change	

2	

1	

2	

0	

0	

0	

0	

$0



     Notification of demonstration of       continuous monitoring system


2	

1	

2	

0	

0	

0	

0	

$0



     Notification that continuous              monitoring system (CMS)	

2	

1	

2	

0	

0	

0	

0	

$0



     Semiannual excess emissions f          reports	

8	

2	

16	

41	

656	

32.8	

65.6	

$60,901.73



     Performance test results	

Included in 3B







SUBTOTAL Reporting



754.4	$60,901.73



4.  Recordkeeping requirements







	

     A.  Read instructions	

Included in 3A	

	

	

	

	

	





 B.  Plan activities	

Included in 3B	

	

	

	

	

	



 

C.  Implement activities	

Included in 3B	

	

	

	

	

	





D.  Develop record system	

N/A









E.  Time to enter information











     Records of CMS operating g             parameters	

0.25	

250	

62.5	

41	

2,563	

128.15	

256.3	

$237,943.80



     Records of startup, shutdown,           malfunction	

1.5	

1	

1.5	

41	

61.5	

3.08	

6.15	

$5,710.03



F.  Time to train personnel	

N/A	

	

	

	

	

	

	





G. Time for audits	

N/A	

	

	









SUBTOTAL Recordkeeping



	3,018.18	$243,653.8



Subtotals Labor Burden and Cost  	

	

	

	

	

3,280.5	

164.03	

328.05	

$304,555.56



TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	

3,773	

$304,556



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 41, and no additional new sources will
become subject to the rule over the three-year period of this ICR. 

b  This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2: Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110% to
account for the benefit packages available to those employed by private
industry.

c  We have assumed that it will take 280 hours to complete a performance
test.

d  It will take respondents 4 hours to conduct a reference Method 9
test.

e  We have assumed that 20 percent of new respondents will have to
repeat the performance test.

f  We have assumed that it will take 8 hour two times per year for each
respondent to complete the semiannual report of exceedances. 

g  We have assumed that it will take 250 days per year to record CMS
operating parameters information.

h  We have assumed that it will take 1.5 hours once a year to record 
information on startup, shutdown, malfunction.

Table 2:  Average Annual EPA Burden - NSPS for Lime Manufacturing (40
CFR Part 60, Subpart HH) (Renewal)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year

	

(C)

EPA person-

hours per

plant per

year

(C=AxB)	

(D)

Plants

per

year a

	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per

year

(Ex0.1)

	

(H)

Cost, $ b



Initial  performance tests c	

38	

1	

38	

0	

0	

0	

0	

$0



Repeat  performance test d	

38	

0.2	

7.6	

0	

0	

0	

0	

$0



Report Review:	

	

	

	

	

	

	

	





   Notification of  e                        construction/reconstruction


2	

1	

2	

0	

0	

0	

0	      

  $0



   Notification of actual startup	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



   Notification of physical or  f      operational change	

0.5	

1.2	

0.6	

0	

0	

0	

0	

$0



    Notification of demonstration     of CMS 	0.5	1	0.5	0	0	0	0	

$0



    Notification of CMS data to       determine compliance	0.5	1	0.5	0	0
0	0	

$0



   Performance test results g	

8	

1.2	

9.6	

0	

0	

0	

0	

$0



    Semiannual report h	

4	

2	

8	

41	

328	

16.4	

32.8	

$15,291.69



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	377	

          $15,292



Assumptions:

a  We have assumed that there are approximately 41 respondents currently
operating in the United States which are subject to the regulation.  It
is estimated that no additional respondents will become subject to the
regulation in the next three years based on information available on the
sector.  Therefore, the average number of respondents per year is
estimated to be 41.

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2005 General Schedule” which
excludes locality rates of pay.

    c  We have assumed that it will take 38 hours to perform an initial
performance test. 

    d  We have assumed that 20 percent of new respondents will have to
repeat the performance test.

    e  It will take 2 hours to review construction/reconstruction
report.

 f  It will take 0.5 hours to review the physical or operational change
review.

g  We have that it will take 8 hours to review the performance test
results report.

    h  We have assumed that it will take 4 hour two times per year for
each respondent to review the semiannual report. 

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