| TABLE 1: |
|
|
Annual Respondent Burden and Cost-NESHAP for Lime Manufacturing (40 CFR part 63, subpart AAAAA) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
REPORTING/RECORDKEEPING REQUIREMENT |
|
|
(A) Respondent Hours per Occurence (Technical hours) |
(B) Number of Occurences per Respondent per Year |
(C) Hours per Respondent per Year (C=A x B) |
(D) Number of Respondents per Yeara |
(E) Technical Hours per Year @ $97.59 (E=C x D) |
(F) Management Hours per Year @ $114.77 (F= E x 0.05) |
(G) Clerical Hours per Year @ $48.26 (G= E x 0.1) |
Total Labor Costs per Year |
| 1. |
APPLICATIONS |
|
|
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
| 2. |
SURVEY AND STUDIES |
|
|
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
| 3. |
ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMSb |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$4,326.18 |
| 4. |
REPORTING REQUIREMENTS |
|
|
|
|
|
|
|
|
|
|
|
a. |
Read Instructionsb |
|
2 |
1 |
2 |
1 |
2 |
0.1 |
0.2 |
$216.31 |
|
b. |
Required Activities |
|
|
|
|
|
|
|
|
|
|
|
|
Repeat performance testsc |
40 |
1 |
40 |
12.2 |
488 |
24.4 |
48.8 |
$52,779.40 |
|
|
|
Visible emission (VE) report for material handlingf |
8 |
1 |
8 |
62 |
496 |
24.8 |
49.6 |
$53,644.63 |
|
|
|
Annual inspection of capture, collection, and transport systemg |
8 |
1 |
8 |
62 |
496 |
24.8 |
49.6 |
$53,644.63 |
|
|
|
Inspection and maintenance of affected sources, control devices, and monitoring systems according to operation, maintenance, and monitoring planh |
4 |
1 |
4 |
62 |
248 |
12.4 |
24.8 |
$26,822.32 |
|
c. |
Create Information |
|
------------------------Included in 4b---------------------------- |
|
|
d. |
Gather Existing Information |
|
------------------------Included in 4b---------------------------- |
|
|
e. |
Write Report |
|
|
|
|
|
|
|
|
|
|
|
|
Notification of Applicabilityb |
2 |
1 |
2 |
1 |
2 |
0.1 |
0.2 |
$216.31 |
|
|
|
Notification of Construction/Reconstructionb |
2 |
1 |
2 |
1 |
2 |
0.1 |
0.2 |
$216.31 |
|
|
|
Notification of Anticipated Startupb |
2 |
1 |
2 |
1 |
2 |
0.1 |
0.2 |
$216.31 |
|
|
|
Notification of Actual Startupb |
2 |
1 |
2 |
1 |
2 |
0.1 |
0.2 |
$216.31 |
|
|
|
Notification of Special Compliance Requirements |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
Compliance Extention Requestb |
2 |
1 |
2 |
1 |
2 |
0.1 |
0.2 |
$216.31 |
|
|
|
Notification of Performance Test |
2 |
1 |
2 |
13.2 |
26.4 |
1.32 |
2.64 |
$2,855.28 |
|
|
|
Notification of Opacity/VE Observations |
2 |
1 |
2 |
62 |
124 |
6.2 |
12.4 |
$13,411.16 |
|
|
|
Operation, Maintenance, and Monitoring Planb |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$4,326.18 |
|
|
|
Startup, Shutdown, and Malfunction Planb |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$4,326.18 |
|
|
|
Site-Specific Test Planb |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$4,326.18 |
|
|
|
Notification of Compliance Statusb |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$865.24 |
|
|
|
Waiver Application |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
Semiannual Compliance Reportsi |
8 |
2 |
16 |
62 |
992 |
49.6 |
99.2 |
$107,289.26 |
|
|
|
Emergency Startup, Shutdown, and Malfunction Reportsj, k |
8 |
1 |
8 |
3.1 |
25 |
1.2 |
2.5 |
$2,682.23 |
|
|
|
|
Total Reporting Hours by Labor Category |
1,305 |
65 |
131 |
|
|
TOTAL REPORTING BURDEN |
|
|
|
|
|
|
|
1,501 |
Hours |
$141,163 |
| 5. |
RECORDKEEPING REQUIREMENTS |
|
|
|
|
|
|
|
|
|
|
|
a. |
Read Instructions |
|
------------------------Included in 4a---------------------------- |
|
|
b. |
Plan Activities |
|
3 |
1 |
3 |
1 |
3 |
0.15 |
0.3 |
$324.46 |
|
c. |
Implement Activitiesl |
|
12 |
1 |
12 |
1 |
12 |
0.6 |
1.2 |
$1,297.85 |
|
d. |
Develop Record System |
|
3 |
1 |
3 |
1 |
3 |
0.15 |
0.3 |
$324.46 |
|
e. |
Time to Enter Information |
|
|
|
|
|
|
|
|
|
|
|
|
Record of All Information Required by Standardsm |
3 |
52 |
156 |
62 |
9,672 |
484 |
967 |
$1,046,070.32 |
|
f. |
Train Personneln |
|
3 |
1 |
3 |
1 |
3 |
0.15 |
0.3 |
$324.46 |
|
g. |
Time to Adjust Existing Wast to Comply with Previously Applicable Requirementso |
3 |
1 |
3 |
1 |
3 |
0.15 |
0.3 |
$324.46 |
|
h. |
Time to Transmit or Disclose Informationp |
|
0.25 |
2 |
0.50 |
62 |
31 |
1.55 |
3.1 |
$3,352.79 |
|
g. |
Time for Audits |
|
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
|
Total Recordkeeping Hours by Labor Category |
11,497 |
575 |
1,150 |
|
|
TOTAL RECORDKEEPING BURDEN |
|
|
|
|
|
|
|
13,222 |
Hours |
$1,243,452 |
|
|
|
|
Total Hours by Labor Category |
12,802 |
640 |
1,280 |
|
|
TOTAL ANNUAL LABOR BURDEN AND COST |
|
|
|
|
|
|
|
14,723 |
Hours |
$1,384,616 |
| 6. |
ANNUAL CAPITAL COSTS |
|
|
|
|
|
|
|
|
|
|
|
a. |
Performance test for kilnsc, d |
|
|
|
13.2 |
|
|
|
$17,750 |
|
b. |
Performance test for material handlingc, e |
|
|
|
|
13.2 |
|
|
|
$17,750 |
|
c. |
Bag Leak Detectorp |
|
|
|
|
62 |
|
|
|
$88,908 |
|
TOTAL ANNUAL CAPITAL and O&M COSTS |
|
|
|
$124,408 |
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions |
|
|
|
|
|
|
|
|
|
|
|
| a. Assumed that the average number of respondent that will be subject to the rule will be 61 existing respondents. There will be one additional new source per year that will become subject to the rule over the three-year period of this ICR. |
| b. This is a one-time only activity. |
| c. To demonstrate continuous compliance, plants must conduct performance tests every 5 years. The number of respondents to repeat performance test is 12.2 performance tests per year (61 existing respondents/5years). The cost to conduct a repeat Method 5 performance test is $5,000. The annualized capital cost to conduct this test is $1,250 per year. |
| d. Assumed that there will be a total of three new kilns in production over the three year period of the ICR, which will average out to one unit per year. The cost for an initial Method 5 test is $10,000, and the annualized cost for an initial performance test is $2,500 per new unit. One new unit per year is expected to conduct an initial Method 5 test. |
| e. Assumed that each existing plant has a material handling operation that would conduct a Method 5 performance test every 5 years. The number of respondents to conduct subsequent performance tests each year would be 61 existing respondents/5 years, or 12.2 respondents per year. Each respondent would incur an annual cost of $1,250 to perform subsequent Method 5 performance tests. Each new respondent is assumed to have a material handling operation that would conduct an initial Method 5 performance test. The cost of the initial test is $2,500 per new unit. |
| f. Assumed that each respondent will take 8 hours to complete the annual visible emission (VE) tests for material handling. |
| g. Assumed that each respondent will take 8 hours to complete the annual inspection of the capture, collection, and transport system. |
| h. Assumed that each respondent will take 4 hours to complete the inspection and maintenance of affected sources, control devices, and monitoring systems according to operation, maintenance, and monitoring plan. |
| i. Assumed that it will take 8 hours each and two times per year to complete semiannual compliance reports. |
|
|
|
|
|
|
|
|
|
|
|
| j. Assumed that it will take 8 hours once a year to write the emergency startup, shutdown, or malfunction reports. |
| k. Assumed that 5 percent of respondents will have to complete the emergency startup, shutdown, or malfunction reports. |
| l. Assumed that it will take 12 hours to record activities implemented. |
|
|
|
|
|
|
|
|
|
|
|
| m. Assumed that all respondents will take 3 hours each to enter records of all the required information 52 times a year. |
|
|
|
|
|
|
|
|
|
|
|
| n. Assumed that it will take 3 hours to train each personnel. |
| o. Assumed that it will take 3 hours for each respondent to adjust existing ways to comply with previously applicable requirements. |
| p. Assumed that respondents are required to transmit/disclose information twice per year. |
|
|
|
|
|
|
|
|
|
|
|
| q. The cost of a bag leak detection monitor is $10,000. The annulized cost of this capital is $1,434 per respondent per year. Each of the 62 respondents is expected to have at least one kiln with a bag leak detection monitor installed, or $88,908. |
| TABLE 2: Annual Agency Burden and Cost - NESHAP for Lime Manufacturing (40 CFR part 63, subpart AAAAA) |
|
|
|
|
|
|
|
|
|
|
|
| REPORTING/RECORDKEEPING REQUIREMENT |
|
|
(A) EPA Hours per Occurence (Technical hours) |
(B) Number of Occurences per Plant per Year |
(C) EPA Hours per Year (C=A x B) |
(D) Plants per Year a |
(E) Technical Hours per Year @ $45.52 (E=C x D) |
(F) Management Hours per Year @ $61.36 (F= E x 0.05) |
(G) Clerical Hours per Year @ $24.64 (G= E x 0.1) |
Costs per Year |
| INITIAL PERFORMANCE TESTS |
|
|
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$2,042.08 |
| RETESTING PREPARATION FOR REPEAT PERFORMANCE TESTSb |
2 |
1 |
2 |
12.2 |
24.4 |
1.22 |
2.44 |
$1,245.67 |
| REPEAT PERFORMANCE TESTb, c |
|
|
40 |
1 |
40 |
12.2 |
488 |
24.4 |
48.8 |
$24,913.38 |
| REPORT REVIEW |
|
|
|
|
|
|
|
|
|
|
Notification of Applicability |
1 |
1 |
1 |
1 |
1 |
0.05 |
0.1 |
$51.05 |
|
|
Notification of Construction/Reconstruction |
1 |
1 |
1 |
1 |
1 |
0.05 |
0.1 |
$51.05 |
|
|
Notification of Anticipated Startup |
1 |
1 |
1 |
1 |
1 |
0.05 |
0.1 |
$51.05 |
|
|
Notification of Actual Startup |
1 |
1 |
1 |
1 |
1 |
0.05 |
0.1 |
$51.05 |
|
|
Notification of Special Compliance Requirements |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
Notification of Initial Performance Tests |
1 |
1 |
1 |
1 |
1 |
0.05 |
0.1 |
$51.05 |
|
|
Notification of Compliance Status |
4 |
1 |
4 |
1 |
4 |
0.2 |
0.4 |
$204.21 |
|
|
Review of Repeat Performance Test Reportb, d |
2 |
1 |
2 |
12.2 |
24.4 |
1.22 |
2.44 |
$1,245.67 |
|
|
Review of Semiannual Compliance Report |
4 |
2 |
8 |
62 |
496 |
24.8 |
49.6 |
$25,321.79 |
|
|
Review of Waiver Application |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
Review of Emergency Startup, Shutdown, and Malfunction Reporte |
4 |
1 |
4 |
3.1 |
12.4 |
0.62 |
1.24 |
$633.04 |
| SALARY BURDEN (per year) |
|
|
|
|
|
|
1,094.2 |
54.71 |
109.42 |
$55,861 |
| TOTAL ANNUAL BURDEN |
|
|
|
|
|
|
1,258 |
$55,861 |
|
|
|
|
|
|
|
|
|
|
|
| Assumptions |
|
|
|
|
|
|
|
|
|
|
| a. Assumed that the average number of respondents that will be subject to the rule will be 61 existing respondents. There will be one additional new source per year that will become subject to the rule over the three-year period of this ICR for an average of 62 existing and new respondents per year. |
| b. To demonstrate continuous compliance, plants must conduct repeat performance tests every 5 years. The number of respondents to repeat performance test is 12.2 test/year (61 existing respondents/5years = 12.2 performance tests per year) starting in the second year of this ICR. |
| c. Assumed that it will take 40 hours for respondents to repeat performance tests. |
|
|
|
|
|
|
|
|
|
|
| d. Assumed that it will take 2 hours for respondents to review repeat performance test report. |
|
|
|
|
|
|
|
|
|
|
| e. Assumed five percent of sources will need to submit emergency startup, shutdown, and malfunction reports. |
|
|
|
|
|
|
|
|
|
|