U.S. Environmental Protection Agency
Information Collection Request
Title: NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)
OMB Control Number: 2060-0063
EPA ICR Number: 1167.14
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 existing and new rotary lime kilns used in the manufacturing of lime. These standards do not apply to facilities used in the manufacture of lime at kraft pulp mills. New facilities include those that commenced construction, modification or reconstruction after the date of proposal. 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 required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where the delegated state or local authority can review them. In the event that there is no such delegated authority, the EPA regional office can review them. All other 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 EPA regional offices. The use of the term "Designated Administrator" throughout this document refers to the U.S. EPA or a delegated authority such as a state agency. The term "Administrator" alone refers to the U.S. EPA Administrator.
The “Affected Public” are owners or operators of lime manufacturing plants and/or lime kilns. 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 either Federal employees or government contractors and may be found in Table 2: Average Annual EPA Burden and Cost – NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal). There are approximately 41 lime manufacturing facilities. None of the facilities in the United States are owned by state, local, tribal or the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond.
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).
Over the next three years, approximately 41 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.
The active (previous) ICR had the following Terms of Clearance (TOC):
“In accordance with 5 CFR 1320, the information collection is approved for three years. As terms of clearance, upon renewal of this collection, EPA is required to include the following in its supporting statement for this and other NESHAP ICRs: (1) a description of the regulatory text applicable to the ICR including submission specifications; (2) a clear description of the data elements being collected under the ICR; (3) screen shots of the electronic portal where the reporting requirements are submitted to EPA (with the control number and burden statement); (4) a detailed discussion of how information is submitted and the extent to which electronic reporting is available; (5) evidence of consultation with respondents (by actively reaching out to stakeholders as permitted by the PRA) to ensure the supporting statement's accuracy on availability of data, frequency of collection, clarity of instructions, accuracy of burden estimate, relevance of data elements, and similar PRA matters; and (6) discussion of how EPA addressed substantive concerns raised by respondents and other stakeholders during consultation and in response to comments received on FR notices. In addition, please convert the supporting statement to the standard 18 question SS-A format upon renewal.”
The relevant regulatory text is referenced in section 12(b) of this document. We have created a supplementary document including the regulatory text that describes the ICR requirements as identified in section 12(b) of this document as requested. This NSPS does not require electronic reporting, and the Agency has not developed specific reporting forms for these subparts for use within CEDRI. The list of rules and required reports available in CEDRI are available at https://www.epa.gov/electronic-reporting-air-emissions/cedri. The notifications and reports required of respondents may be submitted to the authority by any appropriate method such as paper letter or electronic data file. A description of the EPA’s consultation with respondents and how EPA responded to any concerns raised by respondents or other stakeholders is discussed in section 8 of this document. Per the Terms of Clearance on the previous ICR, this supporting statement follows the standard 18-question format.
Supporting Statement A
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate 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 eight 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 (PM) emissions from lime manufacturing plants 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.
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
The recordkeeping and reporting requirements in the standards 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 standards. Continuous emission monitors are used to ensure compliance with the standards 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 standards 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, leaks are being detected and repaired, and 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.
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
Following notification of startup, the reviewing authority could 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 and note the operating conditions under which compliance was achieved. 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 reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. EPA uses ICIS 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.
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication.
For all other reports, 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 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, duplication does not exist.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The majority of 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. 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 to be the minimum requirements 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.
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
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 proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.
An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (88 FR 31748) on May 18, 2023. No comments were received on the burden published in the Federal Register for this renewal.
8b. Consultations
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 41 respondents will be subject to the standard over the three-year period covered by this ICR.
Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Lime Association of Texas at (512) 771-3667 and then National Lime Association at (703) 243-5463. In this case, no comments were received.
Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
No payments or gifts are made to respondents.
ASSURANCE OF CONFIDENTIALITY
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
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).
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
The reporting or recordkeeping requirements in the standard do not include sensitive questions.
Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.
The respondents to the recordkeeping and reporting requirements are lime manufacturing plants. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards is SIC 3274 which corresponds to the North American Industry Classification System (NAICS) 327410 for Lime Manufacturing.
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 Number of Respondents below, is 41 per year. The number of respondents is calculated using the table Number of Respondents that addresses the three years covered by this ICR.
The total number of annual responses per year is calculated using the table Total Annual Responses shown below. The number of Total Annual Responses is 82.
In this ICR, all the data that are recorded or reported are required by the NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH).
A source must make the following reports:
Notifications |
|
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), 60.8(d) |
Notification that continuous monitoring system data will be used to determine compliance |
§60.7(a)(7) |
Reports |
|
Semiannual excess emissions report |
§60.7(c) |
Initial performance test results |
§60.8(a) |
A source must keep the following records:
Recordkeeping |
|
Record of startup, shutdown, and malfunctions |
§60.7(b) |
Records of measurements and all other information required by the standard |
§60.7(f) |
Records are required to be retained for two years |
§60.7(f) |
Observe and record Method 9 opacities |
§§60.344(b)(4), 60.11(b) |
Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.
Respondent Activities |
Familiarization with the regulatory requirements. |
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 collecting, validating, and verifying information. |
Develop, acquire, install, and utilize technology and systems for processing and maintaining information. |
Develop, acquire, install, and utilize technology and systems for disclosing and providing information. |
Train personnel to be able to respond to a collection of information. |
Transmit, or otherwise disclose the information. |
The specific frequency for each information collection activity within this request is shown at the end of this document in Table 1: Annual Respondent Burden and Cost – NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal).
12d. Respondent Burden Hours and Labor Costs
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 average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 3,820 hours (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously approved ICR, and any comments received.
This ICR uses the following labor rates:
Managerial $163.17 ($77.70 + 110%)
Technical $130.28 ($62.04 + 110%)
Clerical $65.71 ($31.29 + 110%)
These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).
The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
The type of industry costs associated with the information collection activities in the subject standards 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.
The total capital/startup costs for this ICR are $0. This is the total of column D shown below in the table Capital/Startup vs. Operation and Maintenance (O&M) Costs.
The total operation and maintenance (O&M) costs for this ICR are $61,500. This is the total of column G shown below in the table Capital/Startup vs. Operation and Maintenance (O&M) 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. These are recordkeeping costs.
Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
14a. Agency Activities
The EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.
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 Enforcement and Compliance History Online (ECHO) and ICIS.
14b. Agency Labor 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 burden and cost over next three years is estimated to be 377 labor hours at a cost of $20,100; see below in Table 2: Average Annual EPA Burden and Cost – NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal).
This cost is based on the average hourly labor rate as follows:
Managerial $73.46 (GS-13, Step 5, $45.91 + 60%)
Technical $54.51 (GS-12, Step 1, $34.07 + 60%)
Clerical $29.50 (GS-6, Step 3, $18.44 + 60%)
These rates are from the Office of Personnel Management (OPM), 2023 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. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal).
We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
14c. Agency Non-Labor Costs
There are no non-labor costs to the Agency associated with this information collection.
REASONS FOR CHANGE IN BURDEN
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.
There is no change in burden from the most recently approved ICR as currently identified in the OMB Inventory of Approved Burdens. 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. Second, the growth rate for this industry is very low or non-existent, so there is no significant change in the overall burden. There is an increase in labor costs, which is wholly due to the use of updated labor rates. There was also an increase in the capital/O&M costs due to an adjustment made using the CEPCI CE Index.
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
Although this rule does not require electronic reporting, respondents could choose to submit notifications or reports electronically. All non-CBI data submitted electronically to the Agency through CEDRI are available to the public for review and printing and are accessible using WebFIRE. Electronically submitted emissions data from performance testing or performance evaluations using the Electronic Reporting Tool or templates attached to CEDRI, as well as data from reports from regulations with electronic templates, are tabulated; data submitted as portable document format (PDF) files attached to CEDRI are neither tabulated nor subject to complex analytical techniques. Electronically submitted emissions data used to develop emissions factors undergo complex analytical techniques and the draft emissions factors are available on the Clearinghouse for Inventories and Emission Factors listserv at https://www.epa.gov/chief/chief-listserv for public review and printing. Electronically submitted emissions data, as well as other data, obtained from one-time or sporadic information collection requests often undergo complex analytical techniques; results of those activities are included in individual rulemaking dockets and are available at https://www.regulations.gov/ for public review and printing.
DISPLAY OF EXPIRATION DATE
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
EPA will display the expiration date for OMB approval of the information collection.
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
There are no exceptions to the topics of the certification statement.
Table 1: Annual Respondent Burden and Cost – NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)
Burden Item |
(A) |
(B) |
(C)
|
(D) |
(E)
|
(F) |
(G) |
(H) |
|||||
1. Applications |
N/A |
|
|
|
|
|
|
|
|||||
2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|||||
3. Reporting Requirements |
|
|
|
|
|
|
|
|
|||||
A. Familiarize with regulatory requirements c |
1 |
1 |
1 |
41 |
41 |
2.05 |
4.1 |
$5,945.39 |
|||||
B. Required activities: |
|
|
|
|
|
|
|
|
|||||
Initial performance tests d |
280 |
1 |
280 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
Reference Method 9 Test e |
4 |
1.2 |
4.8 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
Repeat of performance test f |
280 |
0.2 |
56 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
C. Create information |
See 3B |
|
|
|
|
|
|
|
|||||
D. Gather Existing Information |
See 3B |
|
|
|
|
|
|
|
|||||
E. Write report |
|
|
|
|
|
|
|
|
|||||
Notification of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
Notification of any physical or operational change |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
Notification of demonstration of continuous monitoring system |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
Notification of initial performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
Notification that continuous monitoring system (CMS) |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
|||||
Performance test results |
See 3B |
|
|
|
|
|
|
|
|||||
Semiannual excess emissions reports g |
8 |
2 |
16 |
41 |
656 |
32.8 |
65.6 |
$95,126.23 |
|||||
Subtotal for Reporting Requirements |
802 |
$101,072 |
|||||||||||
4. Recordkeeping requirements |
|
|
|
|
|
|
|
||||||
A. Familiarize with regulatory requirements |
See 3A |
|
|
|
|
|
|
|
|||||
B. Plan activities |
See 3B |
|
|
|
|
|
|
|
|||||
C. Implement activities |
See 3B |
|
|
|
|
|
|
|
|||||
D. Develop record system |
N/A |
|
|
|
|
|
|
|
|||||
E. Time to enter information |
|
|
|
|
|
|
|
|
|||||
Records of CMS operating parameters h |
0.25 |
250 |
62.5 |
41 |
2,562.5 |
128.13 |
256.25 |
$371,586.84 |
|||||
Records of startup, shutdown, malfunction i |
1.5 |
1 |
1.5 |
41 |
61.5 |
3.08 |
6.15 |
$8,918.08 |
|||||
F. Time to train personnel |
N/A |
|
|
|
|
|
|
|
|||||
G. Time for audits |
N/A |
|
|
|
|
|
|
|
|||||
Subtotal for Recordkeeping Requirements |
|
3,018 |
$380,505 |
||||||||||
Total Labor Burden and Costs (rounded) i |
|
3,820 |
$482,000 |
||||||||||
Total Capital and O&M Cost (rounded) i |
|
$61,500 |
|||||||||||
GRAND TOTAL (rounded) i |
|
$544,000 |
|||||||||||
Assumptions:
a We assume that an average of 41 respondents will be subject to this rule, and that no new sources will become subject to the rule over the three-year period of the ICR.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 We have assumed that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take 280 hours to complete a performance test.
e It will take respondents 4 hours to conduct a reference Method 9 test.
f We have assumed that 20 percent of new respondents will have to repeat the performance test.
g We have assumed that it will take 8 hour two times per year for each respondent to complete the semiannual report of exceedances.
h We have assumed that it will take 15 minutes, 250 days per year to record CMS operating parameters information.
i We have assumed that it will take 1.5 hours once a year to record information on startup, shutdown, and malfunction.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Table 2: Average Annual EPA Burden and Cost – NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)
Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
Activity: |
|
|
|
|
|
|
|
|
Initial performance tests c |
38 |
1 |
38 |
0 |
0 |
0 |
0 |
$0.00 |
Repeat performance test d |
38 |
0.2 |
7.6 |
0 |
0 |
0 |
0 |
$0.00 |
Report Review: |
|
|
|
|
|
|
|
|
Notification of construction/reconstruction e |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
Notification of actual startup |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
Notification of physical or operational change f |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
Notification of demonstration of CMS |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
Notification of CMS data to determine compliance |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
Performance test results g |
8 |
1.2 |
9.6 |
0 |
0 |
0 |
0 |
$0.00 |
Semiannual report h |
4 |
2 |
8 |
41 |
328 |
16.4 |
32.8 |
$20,051.62 |
TOTAL (rounded) h |
|
377 |
$20,100 |
|||||
|
||||||||
Assumptions: |
||||||||
a We assume that an average of 41 respondents will be subject to this rule, and that no new sources will become subject to the rule over the three-year period of the ICR. |
||||||||
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $44.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 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 We have assumed that it will take 38 hours to observe 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 assumed that it will take 8 hours to review the performance test results report. |
|
|
|
|
|
|||
h We have assumed that it will take 4 hour to review each semiannual reports. |
|
|
|
|
|
|
||
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
||||
Number of Respondents |
|||||
|
Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports |
|
||
|
(A) |
(B) |
(C) |
(D) |
(E) |
Year |
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) b |
1 |
0 |
41 |
0 |
0 |
41 |
2 |
0 |
41 |
0 |
0 |
41 |
3 |
0 |
41 |
0 |
0 |
41 |
Average |
0 |
41 |
0 |
0 |
41 |
a New respondents include sources with constructed and reconstructed affected facilities. |
|
|
|||
b Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 41.
Total Annual Responses |
||||
(A) |
(B) |
(C) |
(D) |
(E) |
Information Collection Activity |
Number of Respondents a |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
Total Annual Responses E=(BxC)+D |
Notification of construction/ reconstruction |
0 |
1 |
0 |
0 |
Notification of actual startup |
0 |
1 |
0 |
0 |
Notification of any physical or operational changes |
0 |
1 |
0 |
0 |
Notification of demonstration of continuous monitoring system (CMS) |
0 |
1 |
0 |
0 |
Notification of initial performance test |
0 |
1 |
0 |
0 |
Notification that (CMS) will be used to determine compliance |
0 |
1 |
0 |
0 |
Performance test results |
0 |
1 |
0 |
0 |
Semiannual excess emission report |
41 |
2 |
0 |
82 |
|
|
|
Total |
82 |
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 a |
Number of New Respondents |
Total Capital/Startup Cost, (B X C) |
Annual O&M Costs for One Respondent a |
Number of Respondents with O&M |
Total
O&M, |
Continuous Opacity Monitor |
$23,453 |
0 |
$0 |
$2,345 |
41 |
$61,500 |
|
|
|
|
|
|
|
a Costs were increased from 2009 $ to 2022 $ using the CEPCI CE Index. |
|
|
|
|
||
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | 18Q Supporting Statement Instructions_draft |
| Author | McGrath, Daniel |
| File Modified | 0000-00-00 |
| File Created | 2025-03-01 |