Burden Calculation Table- NESHAP for Lime Manufacturing

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Overview

Table 1
Table 2
Total Responses

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Lime Manufacturing (40 CFR Part 63, Subpart AAAAA) (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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$141.06
3. Acquisition, Installation, And Utilization of Technology and Systems c	40	1	40	1	40	2	4	$5,327.60		Technical	$120.27
4. Reporting Requirements										Clerical	$58.67
a. Familiarization with Regulatory Requirements	2	1	2	37	74	4	7	$9,856.06
b. Required Activities
Repeat performance tests for existing kilns and material handling d, e, f	40	1	40	22.6	904	45	90	$120,403.76
Visible emission (VE) report for material handling g	8	1	8	37	296	15	30	$39,424.24
Annual inspection of capture, collection, and transport system h	8	1	8	37	296	15	30	$39,424.24
Inspection and maintenance of affected sources, control devices, and monitoring systems according to operation, maintenance, and monitoring plan i	4	1	4	37	148	7	15	$19,712.12
c. Create Information	See 4B
d. Gather Existing Information	See 4B
e. Write Report
Notification of Applicability c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Construction/Reconstruction c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Anticipated Startup c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Actual Startup c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Special Compliance Requirements	N/A
Compliance Extension Request c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Initial and Repeat Performance Tests d, e, f	2	1	2	23.6	47	2	5	$6,286.57
Notification of Opacity/VE Observations	2	1	2	37	74	4	7	$9,856.06
Operation, Maintenance, and Monitoring Plan c	40	1	40	1	40	2	4	$5,327.60
Startup, Shutdown, and Malfunction Plan c	40	1	40	1	40	2	4	$5,327.60
Site-Specific Test Plan c	40	1	40	1	40	2	4	$5,327.60
Notification of Compliance Status c	8	1	8	1	8	0.4	0.8	$1,065.52
Waiver Application	N/A
Semiannual Compliance Reports j	8	2	16	37	592	30	59	$78,848.48
Emergency Startup, Shutdown, and Malfunction Reports k,l	8	1	8	1.9	15	0.7	1	$1,971.21
Subtotal for Reporting Requirements					3,018			$349,491
5. Recordkeeping Requirements
a. Familiarization with Regulatory Requirements	See 4A
b. Plan Activities	3	1	3	1	3	0.2	0.3	$399.57
c. Implement Activities m	12	1	12	1	12	0.6	1.2	$1,598.28
d. Develop Record System	3	1	3	1	3	0.2	0.3	$399.57
e. Time to Enter Information
Record of All Information Required by Standards n	3	52	156	37	5,772	289	577	$768,772.68
f. Train Personnel o	3	1	3	1	3	0.2	0.3	$399.57
g. Time to Adjust Existing Waste to Comply with Previously Applicable Requirements p	3	1	3	1	3	0.2	0.3	$399.57
h. Time to Transmit or Disclose Information q	0.25	2	0.5	37	19	0.9	1.9	$2,464.02
g. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					6,687			$774,433
Total Labor Burden and Costs (rounded) r					9,700			$1,120,000		67	hrs/response
Capital and O&M Cost (rounded) r								$335,000
Grand Total (rounded) r								$1,460,000
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 36 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 37 existing and new respondents per year.
b. This ICR uses the following labor rates: $141.06 per hour for Executive, Administrative, and Managerial labor; $120.27 per hour for Technical labor, and $58.67 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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.
c. This is a one-time only activity. New facilities install kilns and material handling equipment. New facilities submit notifications and plans.
d. Assumed that there will be a total of three new kilns brought into production (installed) over the three year period of the ICR. This averages out to one unit per year. One new kiln per year is expected to conduct an initial Method 5 test. The performance testing costs are covered in Section 6(b)(iii) of the Supporting Statement.
e. Respondents must conduct repeat performance tests on existing kilns every 5 years to demonstrate continuous compliance. There are 102 existing affected kilns. The number of respondents to repeat a performance test is 20.4 performance tests per year (102 affected kilns/5years).
f. Respondents must conduct repeat performance tests on existing materials handling operations whose emissions exit through stacks every 5 years to demonstrate continuous compliance. There are 11 existing affected materials handling operations with stacks that would conduct a Method 5 performance test every 5 years. The number of respondents to repeat a performance test is 2.2 performance tests per year (11 affected materials handling operations/5years).
g. Assumed that each respondent will take 8 hours to complete the annual visible emission (VE) tests for material handling.
h. Assumed that each respondent will take 8 hours to complete the annual inspection of the capture, collection, and transport system.
i. 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.
j. Assumed that it will take 8 hours each and two times per year to complete semiannual compliance reports.
k. Assumed that it will take 8 hours once a year to write the emergency startup, shutdown, or malfunction reports.
l. Assumed that 5 percent of respondents will have to complete the emergency startup, shutdown, or malfunction reports.
m. Assumed that it will take 12 hours to record activities implemented.
n. Assumed that all respondents will take 3 hours each to enter records of all the required information 52 times a year.
o. Assumed that it will take 3 hours to train each personnel.
p. Assumed that it will take 3 hours for each respondent to adjust existing ways to comply with previously applicable requirements.
q. Assumed that respondents are required to transmit/disclose information twice per year.
r. Totals are rounded to three significant figures. Figures may not add up exactly due to rounding.
		70 percent subject to these rules – 1,675
		Total number of respondents subject to LQG requirements = 18,135
	25 percent subject to these rules = 4,534

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Lime Manufacturing (40 CFR Part 63, Subpart AAAAA) (Renewal)
Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per respondent per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
Initial Performance Tests c	40	1	40	1	40	2	4	$2,217.84		Labor Rates
Retesting Preparation for Repeat Performance Tests d	2	1	2	22.6	45	2.26	4.5	$2,506.16		Management	$66.62
Repeat Performance Tests d	40	1	40	[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Does EPA intend to attend these tests? Reply: OC Reviewer: Note that this burden was included for agency in prior ICRs, and has been included here - may overestimate agency burden. Confirm this is appropriate. 22.6	904	45	90	$50,123.18		Technical	$49.44
Report Review										Clerical	$26.75
Notification of Applicability	1	1	1	1	1	0.05	0.1	$55.45
Notification of Construction/Reconstruction	1	1	1	1	1	0.05	0.1	$55.45
Notification of Anticipated Startup	1	1	1	1	1	0.05	0.1	$55.45
Notification of Actual Startup	1	1	1	1	1	0.05	0.1	$55.45
Notification of Special Compliance Requirements	N/A
Notification of Initial Performance Tests	1	1	1	1	1	0.05	0.1	$55.45
Notification of Compliance Status	4	1	4	1	4	0.2	0.4	$221.78
Review of Repeat Performance Test Report e	2	1	2	22.6	45	2.3	4.5	$2,506.16
Review of Semiannual Compliance Report	4	2	8	37	296	15	30	$16,412.02
Review of Waiver Application	N/A
Review of Emergency Startup, Shutdown, and Malfunction Report f	4	1	4	1.9	7.4	0.37	0.74	$410.30
Total (rounded) g					1,550			$74,700
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 36 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 37 existing and new respondents per year.
b. This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c. One new source per year will conduct a performance test on their kiln and materials handling operations. The Agency will spend 40 hours to attend the test and review the performance test report.
d. To demonstrate continuous compliance, plants must conduct repeat performance tests every 5 years. The number of respondents to repeat performance test is 22.6 tests/year ((102 existing kilns + 11 existing materials handling operations)/5years = 22.6 performance tests per year). Assumed that it will take 40 hours for respondents to repeat performance tests.
e. Assumed that it will take 2 hours for respondents to review repeat performance test report.
f. Assumed five percent of sources will need to submit emergency startup, shutdown, and malfunction reports.
g. Totals have been rounded to three significant figures. Figures may not add together exactly due to rounding.

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Sheet 3: Total Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of applicability	1	1	0	1
Notification of construction/ reconstruction	1	1	0	1
Notification of anticipated startup	1	1	0	1
Notification of actual startup	1	1	0	1
Notification of special compliance requirements	N/A	N/A	N/A	N/A
Compliance extension request	1	1	0	1
Notification of performance tests	23.6	1	0	23.6
Notification of opacity/VE observations	37	1	0	37
Operation, maintenance, and monitoring plans	1	1	0	1
Startup, shutdown, and malfunction plans	1	1	0	1
Site-specific test plan	1	1	0	1
Notification of compliance status	1	1	0	1
Waiver application	N/A	N/A	N/A	N/A
Semiannual compliance reports	37	2	0	74
Emergency startup, shutdown, or malfunction reports	1.9	1	0	1.9		hours	9,704
			Total	145		hr/response	67
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A)	(B)	(C)	(D)	(E)
	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	1	35	0	0	36
2	1	36	0	0	37
3	1	37	0	0	38
Average	1	36	0	0	37
a New respondents include sources with constructed, reconstructed and modified affected facilities.
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M (E X F)
Bag leak detector a	$0	1	$0	$1,424	98	$139,552
Performance Test for New and Existing Kilns b	$10,000	1	$10,000	$7,750	20.4	$158,100
Performance Test for New and Existing Material Handling c	$10,000	1	$10,000	$7,750	2.2	$17,050
Total d			$20,000			$315,000
a The cost of a bag leak detection monitor is $10,000. The bag leak detector has a life span of 10 years. The capital cost associated with the bag leak detector was annualized assuming a seven percent interest rate and 10-year life (i.e., capital recovery factor [CRF] of 0.1424). To calculate annualized costs, the CRF was multiplied by the capital cost of the detector, or $1,424 per known fabric filter or ESP. Information from the RTR in progress indicate there are 98 fabric filters or ESP in operation. We assume that the bag leak detector is replaced every 10 years and include this as an O&M cost.
b Each new respondent is assumed to conduct an initial Method 5 performance test. It is 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 per new unit. It is also assumed that each existing affected unit would conduct a Method 5 performance test every 5 years. The cost of a repeat Method 5 test is approximately $7,750. We assume 20.4 respondents will need to conduct repeat performance test per year (102 affected kilns / 5 = 20.4).
c Each new respondent is assumed to have a material handling operation that would conduct an initial Method 5 performance test. It is 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 of the initial test is $10,000 per new unit. Most material handling is not vented through a stack, and therefore do not conduct Method 5 tests. It is assumed that 11 existing material handling operations have stacks that would conduct a Method 5 performance test every 5 years. The cost of a repeat Method 5 test is approximately $7,750. We assume 2.2 existing respondents per year will conduct repeat tests (11 affected stacks / 5 = 2.2).
d Totals have been rounded to three significant figures. Figures may not add exactly due to rounding.