SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Portland Cement (40 CFR Part 63, Subpart LLL) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Portland Cement (40 CFR Part 63, Subpart LLL) (Renewal), 

EPA ICR Number 1801.08, OMB Control Number 2060-0416

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the 

regulations published at 40 CFR part 63, subpart LLL, were proposed on March 24, 1998, 

promulgated on June 14, 1999, and subsequently revised on December 20, 2006. These 

regulations apply to the following facilities: each new, existing or reconstructed kiln, in-line 

kiln/raw mill and greenfield raw material dryer at these facilities, except for kilns and in-line 

kiln/raw mills that burn hazardous waste and are subject to 40 CFR 63, subpart EEE or that burn 

municipal solid waste and are subject to 40 CFR part 60, subpart Cb or Ea. In addition, the rule 

applies to each new, existing or reconstructed clinker cooler; raw mill; finish mill; raw material, 

clinker or finished product storage bin; conveying system transfer point; bagging system and bulk 

loading and unloading system at facilities that are major sources; and to each existing, 

reconstructed or new brownfield raw material dryer at facilities that are major sources. This 

information is being collected to assure compliance with 40 CFR part 63, subpart LLL.

Emission limits for mercury from new cement kilns were established under the December 

2006 final amendments. A mercury performance test is required to demonstrate compliance with 

the emission limits for mercury. The final amendments also established emission limits for total 

hydrocarbons (THC) for new kilns and revise the emission limits for new greenfield kilns. To 

demonstrate compliance with the THC limits, owners or operators of new kilns would be 

required to continuously monitor THC emissions. To ensure proper combustion of organic HAP 

from existing kilns, owners or operators of portland cement manufacturing plants must 

implement good combustion practices (GCP) designed to minimize THC from fuel combustion. 

Respondents are required to maintain additional records to demonstrate compliance with THC 

limits. The 2006 final amendments also required that records be kept of the amount of cement 

kiln dust (CKD) that is removed from existing and new kiln systems and either disposed of as 

solid waste or otherwise recycled for a beneficial use outside of the kiln system. 

In addition to the new requirements established from the 2006 amendments, in general, 

all NESHAP standards require initial notifications, performance tests, and periodic reports. 

Owners or operators are also required to maintain records of the occurrence and duration of any

startup, shutdown, or malfunction in the operation of an affected facility, or any period during 

which the monitoring system is inoperative. These notifications, reports, and records are 
essential in determining compliance, and are required of all sources subject to the NESHAP.

Any owner or operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

Approximately 94 portland cement plants with 158 non-hazardous waste cement kilns are 

currently subject to the regulation. It is estimated that 20 new kilns will be built over the next 

five years or 12 additional sources will become subject to the regulation over the next three year

ICR period. All new kilns are estimated to be constructed at existing portland cement plants, and 

it is estimated that two new kilns will be installed at two existing plants, for a total of 4 new kilns 

per year. Since the records and reports are maintained at the plant-level, the estimate for the 

number of respondents to this ICR is tracked at the plant-level. Although there are new kilns 

estimated at existing plants, there are no new respondents estimated during this ICR.

The Office of Management and Budget (OMB) approved the currently active Information 

Collection Request (ICR) without any ”Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner or operator subject to any

requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, 

at such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, hazardous air pollutant (HAP) emissions from portland cement 

manufacturing facilities cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health or welfare. Therefore, the NESHAP were promulgated for this source 
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category at 40 CFR part 63, subpart LLL.

2(b) Practical Utility/Users of the Data

The control of emissions of HAPs from portland cement manufacturing facilities requires 

not only the installation of properly designed equipment, but also the operation and maintenance 

of that equipment. Emissions of HAPs from portland cement manufacturing facilities are the 

result of operation of the affected facilities. The subject standards are achieved by the capture of 

particulate HAP emissions using fabric filters or electrostatic precipitators control, temperature 

control for the reduction of dioxins and furans (D/F), and feed selection for reduction of other 

organic HAP. 

The recordkeeping and reporting requirements in the standard(s) ensure compliance with 

the applicable regulations that 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 and 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.

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

The recordkeeping and reporting requested is required under 40 CFR part 63, subpart 

LLL.

3(a) Non-duplication

If the 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 regulation to implement the 

Federal standards, a copy of the report submitted to the State or local agency can be sent to the 
4

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 on July 8, 2009 (74 FR 32580). No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The agency is basing the burden estimates of this ICR on estimates prepared for the 

December 20, 2006 amendments. During those amendments, the Agency consulted with industry

experts and internal data sources to project the number of affected facilities and industry growth 

over the next three years. Those included in those consultations included State and local 

agencies, individual portland cement manufacturing plants, industry trade associations, and 

environmental groups. We specifically consulted with stakeholders on some of the ICR 

requirements of these final amendments. Participants in the development process for those 

amendments included STAPPA/ALAPCO, the Portland Cement Association (PCA), the 

American Portland Cement Alliance (APCA), the Small Company MACT Coalition, the Sierra 

Club, and Earth Justice. Several meetings with industry representatives were held in the period 

leading to proposal and the final amendments, and public comments received from trade 

associations, cement companies, State and local regulatory agencies, and environmental groups 

were considered in the development of the current rule. Public comments received following 

proposal were considered in developing the final amendments regarding monitoring, 

recordkeeping, or reporting procedures. 

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 proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 
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promulgated by OMB under 5 CFR Part 1320, section 1320.5. However, most NESHAP 

standards and a few NSPS standards require records to be kept more than three years. In general, 

these standards require the respondents to maintain all records, including reports and 

notifications, for five years. The five-year record retention requirement is consistent with the 

permit program at 40 CFR part 70, and the five-year statute of limitations on which the permit 

program is based.

The retention of records for five years allows EPA to establish the compliance history of 

the respondent for purposes of determining the appropriate level of enforcement action. 

Historically, EPA notes that the most flagrant violations have extended beyond a five-year 

period. If records are retained for less than five years, EPA would be deterred from pursuing the 

most flagrant violations due to the destruction of records documenting noncompliance.

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 (CBI) (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

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are portland cement 

manufacturing facilities. The United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards is 3241 which corresponds to the North American Industry

Classification System (NAICS) 32731 for portland cement manufacturing facilities.

4(b) Information Requested

(i) Data Items

All data in this ICR that is recorded and/or reported is required by NESHAP for the 

Portland Cement Manufacturing Industry (40 CFR part 63, subpart LLL).

A source must make the following reports:
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Notification Reports

Notification of anticipated startup 63.9(b)(3)

Notification of applicability 63.9(b)(1&2)

Notification of actual startup 63.9(b)(4)

Notification of construction/reconstruction 63.9(b)(5)

Request for extension of compliance 63.9(c)

Notification of special compliance requirements 63.9(d)

Notification of initial performance test 63.9(e), 63.7(b)

Notification of opacity and visible emission observations 63.9(f)

Notification of the continuous emission monitoring performance 

evaluation

63.8(e), 63.9(g)

Notification of compliance status 63.9(h)

Adjustments to time periods or postmark deadlines for submittal and 

review of required communications

63.9(i)

Change in information already provided 63.9(j)

Reports

Operations and maintenance plan 63.1350(a)

Report of performance test 63.10(d)(2)

Opacity and visual emission observation 63.10(d)(3)

Progress reports 63.10(d)(4)

Periodic startup, shutdown, malfunction reports 63.10(d)(5)(i)

Immediate startup, shutdown, malfunction reports 63.10(d)(5)(ii)

Reporting results of continuous monitoring system performance 

evaluations

63.10(e)(2)
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Reports

Excess emissions and continuous monitoring system performance 

report and summary report

63.10(e)(3)

Reporting continuous opacity monitoring system data produced during 

a performance test

63.10(e)(4)

Waiver of recordkeeping and reporting requirements 63.10(f)

A source must maintain the following records:

Recordkeeping

All reports and notifications 63.10(b)

Startups, shutdowns, malfunctions, periods where the continuous 

monitoring system is inoperative

63.10(b)(2)

Record of applicability 63.10(b)(3)

Records for sources with continuous monitoring systems 63.10(c)

Records for cement dust kilns (CDK) 63.1355(d)

Records are required to be retained for five (5) years. The first two (2) 

years of records must be retained at the facility

63.1355(a), 

63.10(b)(1)

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for: 1) opacity; 2) to record the temperature of 

the exhaust gases to monitor D/F; 3) to record the rate of carbon injection and the carrier gas 

parameter, if using activated carbon injection to control D/F; and 4) to measure Total 

Hydrocarbons (THC), if applicable.

Perform initial performance test, Reference Method 5 test for Particulates, Method 9 test for 

Opacity, Method 23 test for dioxin/furans (D/F), and Performance Specification 8A of 

Appendix B to part 60 for THC, if applicable. Repeat performance tests, if necessary.

Write the notifications and reports listed above.
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Respondent Activities

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.

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

requirements.

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

Transmit, or otherwise disclose the information.

Electronic Reporting

At the present, many respondents to CAA standards use 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.

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

Management

5(a) Agency Activities

EPA conducts one or more of 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.
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Agency Activities

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 AIRS (Aerometric Information Retrieval System) 

Facility Subsystem (AFS) database.

5(b) Collection Methodology and Management

The required data and reports can be evaluated on-site by conducting a partial compliance 

evaluation, full compliance evaluation or inspection, or through an off-site review of compliance 

monitoring records and reports. Evaluation reports and inspection results are maintained by the 

Agency or delegated authority.

The results of these evaluations are entered into the Air Facility Subsystem (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 delegated authorities can retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

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. 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. The PCA study “U.S. and Canadian Portland Cement 

Industry: Plant Information Summary,” indicates there are 35 companies with affected Portland 

cement facilities. Of these, six companies (or 17 percent) are considered small entities. The 

Agency assumes that 17 percent of the 94 facilities affected by this ICR, or 16 facilities, are small 

entities.
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5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown below in Table 1.

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. 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 28,242 hours (Total Labor Hours from Table 1). 

The recordkeeping hours shown below in Table 1 are 25,545 hours. The reporting requirement 

hours shown below in Table 1 are 2,697. These hours are based on Agency studies and 

background documents from the development of the regulation, Agency knowledge and 

experience with the NESHAP 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 $114.77 ($54.65 + 110%) 

Technical $97.59 ($46.47 + 110%)

Clerical $48.26 ($22.98 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2009, “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.
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(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The types of industry costs associated with the information collection activity in the regulations 

are for labor and continuous emission monitoring (CEM). Since the 2006 amendments required 

all new kilns constructed on or after December 2, 2005, to install THC monitors, it is also 

assumed that a THC CEM will be installed on each new kiln. The capital cost and the O&M cost 

of the THC monitor were estimated using an updated Version 3 of EPA’s Continuous Emission 

Monitoring System Cost Model. 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) Costs

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 

Costs, 

(B X C)

(E)

Annual 

O&M Cost 

for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M 

Costs,

(E X F)

Continuous 

Emission 

Monitors

$220,000 4 $880,000 $7,400 94 $791,800

THC 

Continuous 

Emission 

Monitors

$139,800 4 $559,200 $22,073 4 $88,292

The total capital/startup costs for this ICR are $1,439,200. This is the total of column D 

in the above table. 

The total operation and maintenance (O&M) costs for this ICR are $880,092. This is the 

total of column G. 

The average annual cost for capital/startup and O&M costs to the industry over the next 

three years of the ICR is estimated to be $2,319,292. This is the average annual cost for the 3-

year ICR period from column G above which includes annual O&M costs and annualized capital 

costs as discussed below. These are recordkeeping costs.
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(iv) Annualizing Capital Costs

The capital cost associated for a THC monitor and CEM was annualized assuming a 7 

percent interest rate and 10-year life (i.e., capital recovery factor [CRF] of 0.1424). The total 

annualized capital costs total $204,910.

6(c) Estimating Agency Burden and Costs

The only costs to the Agency are those 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 and the publication and distribution of 

collected information.

The average annual Agency cost during the three years of the ICR is estimated to be 

$243,774 and is shown below in Table 2. 

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

Managerial $61.36 (GS-13, Step 5, $38.35 + 60%) 

 Technical $45.52 (GS-12, Step 1, $28.45 + 60%)

 Clerical $24.64 (GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personnel Management (OPM) 2009 General Schedule, which 

excludes locality rates of pay. The rates have been increased by 60% to account for the benefit 

packages available to government employees. Details upon which this estimate is based appear

below in Table 2: Average Annual EPA Burden – NESHAP for Portland Cement (40 CFR Part 

63, Subpart LLL) (Renewal).

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

Number of respondents is calculated using the following table that 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 1

(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)
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Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any 

Reports

1 2 94 0 2 94

2 2 94 0 2 94

3 2 94 0 2 94

Average 2 94 0 2 94

1

New respondents include sources with constructed, reconstructed and modified affected facilities.

Because all of the new kilns expected to be constructed are located at plants that also 

have existing sources, two of the 94 plants (respondents) can be classified as both a new and 

existing source. To avoid double-counting respondents, column D is subtracted. The average 

Number of Respondents over the three-year period of this ICR is shown in column E. 

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 Applicability 2 2 0 4

Notification of 

Construction/Reconstruction 2 2 0 4

Notification of Actual Startup 2 2 0 4

Notification of THC 

Performance Tests 2 2 0 4

Notification of Hg 

Performance Tests 2 2 0 4

Notification of Performance 

Test 56.4 1.1 0 62

Notification of Opacity and 

Visible Emissions Observation 56.4 1 0 56.4

Notification of the Continuous 

Emission Monitor Performance 

Evaluation

2 2 0 4
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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 Compliance 

Status 2 2 0 4

Report of Initial Performance 

Tests 2 2 0 4

Report of Periodic 

Performance Tests 56.4 1.1 0 62

Excess Emissions and 

Continuous Monitoring System 

Performance Report and 

Summary Report

94 2 0 188

Immediate Startup, Shutdown, 

Malfunction Reports 5 1 0 5

Total 405.5

The number of Total Annual Responses is shown in column E.

The total annual labor cost may be found in Table 1.

The average annual Agency burden and cost over next three years is shown in Table 2.

6(e) Bottom Line Burden Hours 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 hours are 28,242. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost - NESHAP for Portland Cement (40 

CFR Part 63, Subpart LLL) (Renewal). Furthermore, the annual public reporting and 

recordkeeping burden for this collection of information is estimated to average 69.56 hours per 

response.

The average annualized capital/startup and annual O&M costs to the regulated entity are 

$2,319,292. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation 

and Maintenance (O&M) Costs.
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(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 5,437

labor hours at a cost of $243,774. See below Table 2: Annual Agency Burden and Cost -

NESHAP for Portland Cement (40 CFR Part 63, Subpart LLL) (Renewal).

6(f) Reasons for Change in Burden

The increase in burden hours and dollars from the most recently approved ICR renewal

(EPA ICR number 1801.07) is due to a 2006 program change in the regulation requiring

additional performance testing, monitoring, recordkeeping, and reporting requirements. These 

amendments would affect any new, modified, or reconstructed sources after December 2, 2005. 

There was a decrease in number of responses currently identified in the OMB Inventory

of Approved Burdens. This decrease is due to the correction of transpose error in the currently

approved burden estimates in ICRAS. Further, the number of responses also decreased due to a 

decrease in the number of estimated portland cement plants affected by ICR since the last 

renewal. 

The increase in capital/start-up and O&M costs is also due to a 2006 program change in 

the regulation requiring new monitoring equipment. The THC monitors are a new requirement 

for new sources since the last ICR renewal. Further, the change in labor costs for industry and 

EPA is due to the use of more current labor rates.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 69.56 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; to 

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; to adjust the existing ways to comply with any previously applicable 

instructions and requirements; to train personnel to be able to respond to a collection of 

information; to search data sources; to complete and review the collection of information; and to 

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 
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Docket ID Number EPA-HQ-OECA-2009-0425. 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 Enforcement and Compliance Docket and Information Center Docket is (202) 

566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, 

Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: 

Desk Office for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2009-0425

and OMB Control Number 2060-0416 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.