**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Portland Cement Plants (40 CFR Part**  **63, Subpart**  **LLL) (Renewal)**  **1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NESHAP for Portland Cement Plants (40 CFR Part 63, Subpart LLL) (Renewal), EPA ICR Number 1801.12 , OMB Control Number 2060

- 0416

. **1(b) Short Characterization/Abstract**  The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Portland Cement Plants (40 CFR Part 63, Subpart LLL) were initially proposed on March 24, 1998, and promulgated on June 14, 1999. Following a court

- ordered remand, amendments were proposed on December 2, 2005 , and a final rule issued on December 20, 2006 c oncurrently with a notice of re consideration. Additional amendments were finalized on : September 9, 2010 ; February 12, 2013 ; July

27, 2015 ; and September 11, 2015

. The 2015 amendment removed the affirmative defense provision , but did not affect the polluti on reduction or cost associated with the rule

. These regulations apply

to the following affected sources at each new and existing P ortland cement plant that is a major or area source: each kiln, in

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

- line kiln/raw mills that burn hazardous waste and are subject to 40 CFR Part 63, Subpart EEE. In addition, the rule applies to each new and existing clinker cooler; raw mill; finish mill; raw material, clinker or finished product storage bin; conveying system transfer point; and bagging s ys tem and bulk loading and unloading s ys tem at faciliti es that are major or area sources. This information is being collected to assure compliance with 40 CFR Part 63, Subpart LLL. In general, all NESHAP standards require initial notification report s, performance tests, and periodic reports b y 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 NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file containing these documents, and retain the file for at least five ye ars following the generation date of such maintenance reports, and records. All reports are sent to the dele gated state or local authority. In the event that there is no such delegated authority, the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Potential respondents are owners or operators of P ortland cement manufacturing plants, except for kilns and in

- line kiln/raw mills that burn hazardous waste and are subject to 40 CFR2

Part 63, Subpart EEE

. The “burden ” to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Portland Cement Plants (40 CFR Part 63, Subpart LLL) (Renewal). The “burden” to the Federal Government is attributed entirel y to work performed b y either F ederal employees or government contractors, and can be found below in Table 2: Average Annual EPA Burden and Cost

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

. Over the next three ye ars, a pproximately

87 Portland cement plants with 138 non hazardous waste cement kilns are subject to the regulation. It is estimated that 25 new kilns will be built over the next five years or 5 additional sources per year that will become subject to the regulation. All 25 new kilns are estimated to be newly constructed at existing Portland cement plants. 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 currentl y active 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/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 re cords 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 Admini strator may reasonabl y require. In the Administrator's judgment, hazardous air pollutant (HAP) emissions from P ortland cement manufacturing facilities either cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated3

for this source category

at 40 CFR Part 63, Subpart LLL

. **2(b) Practical Utility/Users of the Data**  The control of HAP emissions from P ortland 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 P ortland 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 which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard s . Continuous emission monitors are used to ensure compliance with the se standard s at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard s 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 properl y installed and operated , leaks are being detected and repaired , and that the standard s are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations. **3. Non** 
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart LLL

. **3(a) Non** 
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency

. If a state or local agency has adopted its own s imilar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, duplication does not exist.4

**3(b) Public N**  **otice 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 (80 FR 32120) on June 5, 2015

. No comments were received on the burden published in the Federal Regi ster

. **3(c) Consultations**  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 s , is the Integrated Compliance Information System (ICI S). IC IS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owne d facilities. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Approximately 87 respondents will be subject to the standard over the three

- year period covered b y this ICR. Industry trade associati ons and other interested parties were provided an opportunity to comment on the burden associated with the standard s as they were being developed and the se same standard s have been reviewed previousl y to determine the minimum information needed for compliance purposes. Indeveloping this ICR, we contacted both the Portland Cement Association , at (202)408

- 9494 ; and the National Ready Mixed Concrete Association , at (240 ) 485

- 1156. 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 f irst Federal Register notice. In this case, no comments were received. **3(d) Effects of Less Frequent Collec** **tion** 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 b y these standards was collected less

- frequently, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less l ikely

. **3(e) General Guidelines**  These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR Part 1320, Section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the5

Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars allows EPA to establish the compliance history of a source, any pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA ha s found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **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/SIC 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 b y the standards is SIC 3241 , which corresponds to the North American Industry Classification System (NAICS ) code 32731 for Portland cement manufacturing facilities

. **4(b) Information Requested**  **(i) Data Items**  In this ICR , all the data that is recorded or reported is require d by the NESHAP for the Portland Cement Manufacturing Industry (40 CFR Part 63, Subpart LLL)

. A source must make the following reports:

**Notification s**  Notification of anticipated startup 63.1353(b)(1) , 63.9(b)(3) Notification of applicability 63.9(b)(1&2)6
**Notification s**  Notification of actual startup 63.1353(b)(1) , 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 63.1353(b)(2) , 63.9(e), 63.7(b) Notification of opacity and visible emission observations 63.9(f) Notification of the continuous emission monitoring performance evaluation 63.1353(b)(4) , 63.8(e), 63.9(g) Notification of compliance status 63.1353(b)(5) , 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 63.1354(b)(1) , 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)
Excess emissions and continuous monitoring system performance report 63.10(e)(3)7 **Reports** and summary

report Reporting continuous opacity monitoring s ys tem data produced during a performance test 63.10(e)(4) Reporting monitoring exceedance 63.1354(b)(8)

- (10) , 63.10(e)(5) Waiver of recordkeeping and reporting requirements 63.10(f) A source must keep the following records: **Recordkeeping** All reports and notifications 63.1355(b)(1)

- (3) , 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 63.1355(c) , 63.10(c) Records for cement dust kilns (CDK) 63.1355(d) Operation and Maintenance Plan 63.1346(f), 63.1343(c), 63.6(e) Records are required to be retained for five (5) ye ars. The first two (2) ye ars of records must be retained at the facility . 63.1355(a), 63.10(b)(1) Electronic Reporting 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. **(ii) Respondent Activities**  **Respondent Activities** Familiarization with the regulatory requirements. Install, calibrate, maintain, and operate CMS for: 1) opacity; 2) to record the temperature of8 **Respondent Activities** 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, Method 25A test for THC, Method 321 test for HCL , Method 30B test for Hg, if applicable. Repeat performance tests, if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collecti on of information. Transmit, or otherwise disclose the information.

**5. The Information Collected:**  **Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information : **Agency Activities** Observe initial performance tests and repeat performance tests, if necessary. Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records.9 **Agency Activities** Input, anal yz e, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICI S. **5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are prop erl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capabi lity to comply

with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations. In formation contained in the reports is reported b y state and local governments in the IC IS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Sm**  **all Entity Flexibility** There is a distribution of business sizes for the business that operate P ortland cement plants. 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 regul ation. One consideration in the development of the final rule was that the size of the business does not necessarily correlate with emissions potential. Even a small entity can and does operate cement kilns that emit large quantities of HAP. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency

considers th ese 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. **5(d) Collection Schedule**  The specific frequency

for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

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

.10

**6. Estimating the Burden and Cost of the Collection**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden**  The average annual burden to industry over the next thre e years from these recordkeeping and reporting requirement s is estimated to be 59,600 hours ( Total Labor Hours from Table 1 below). 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 $1 2 9

. 93 ($ 61.87 + 110%) Technical $ 10 3

. 97 ($4 9

. 51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs**  The ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs incurred when a facility

bec omes subject to the regulation. The annual operation and maintenance costs are the ongoing costs required to maintain the monitor(s) and such other costs as photocopying and postage.11
**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**  The annual total capital (including startup) cost for CEMS will be used to monitor THC, Hg, HCl, and PM (plus flow CEMS) is $604,456 per kiln. The annual O&M costs for CEMS for these parameters is $116,459 per kiln per ye ar (costs derived from EPA’s CEM.xls spre adsheet, Method 321 costs from EPA, and Hg costs from 69FR4694). It is anticipated that new kilns will use CEMS for compliance with the THC, Hg, HCl (or Method 321 for scrubber

- equipped kilns), and PM emission limits. The initial CEMS testing cost is estimated to be $131,222 per kiln. An estimated 26 kilns have integrated coal mills with stand

- alone stacks. For these kilns, the capital costs are estimated at $35,780 per kiln for purchase and installation of a flow monitoring device, and $50,800 per kiln for HCl, THC, and Hg testing. O&M costs for flow meters is $2,589 per ye ar per facility

.

**Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)
Continuous Emission Monitors $604,456 5 $3,022,280 $116,459 138 $16,071,342 Initial CEMS testing $131,222 5 $656,110 Flow monitoring device for coal mills $35,780 0 $0 $2,589 26 $67,314 Coal mill testing $50,800 0 $0 **TOTAL** $3,680,000 $16,100,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. The total capital/startup costs for this ICR are $ 3,680,000

. This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this ICR are $ 16,100,000

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to this industry

over the next three years of the ICR is estimated to be $ 19,800,000

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported12

information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 97,500. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packag es available to government employees . Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

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

. **6(d) Estimating the Respondent**  **Universe and Total Burden and Costs** Based on our research for this ICR, on average over the next three ye ars, approximately 87 existing respondents with 133 non

- hazardous waste cement kilns will be subject to the standard. It is estimated that an additional 5 kilns per year will become subject. The overall average number of respondents, as shown in the table below, is 87 per ye ar. Growth in this sector was estimated using data compiled by the Portland Cement Association showing capacity expansion estimates for the industry . Using this information it is estimated that an additional 25 new Portland cement kilns will become subject to the regulation over the five

- year NESHAP review period. All new kilns are estimated to be newl y constructed at existing Portl and cement plants. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR :13 **Number of Respondents** Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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)

1 5 87 0 5 87 2 5 87 0 5 87 3 5 87 0 5 87 Average 5 87 0 5 87 1 New respondents include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 87

. The total number of annual responses per ye ar 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 construction/reconstruction 13.7 1 0 13.7 Notification of actual startup 13.7 1 0 13.7 Physical or Operational Change 13.7 1 0 13.7 Notification of Demonstration of CEMS 13.7 1 0 13.7
Notification of Initial Performance Test 13.7 1 0 13.7 Report of Performance Test 13.7 1 0 13.7 Report of Semi

- Annual Reports 87 2 0 174 Total 256 The number of Total Annual Responses is 256.

The total annual labor costs are $5,990,000

. Details regarding these estimates may be14

found below in Table 1: Annual Respondent Burden and Cost

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

. **6(e) Bottom Line Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 below , respectively, and summarized below. **(i) Respondent Tally**  The total annual labor hours are 59,600 hours

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

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

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical 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 ty pic al duties of clerical staff are to proofread the reports, make copies and maintain records. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 233 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $19,800,000

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

**(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 2,140 labor hours at a cost of $97,500

. See (below) Table 2: Average Annual EPA Burden and Cost

– NESHAP for Portland Cement Plants (40 CFR Part 63, Subpart LLL) (Renewal). We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks becaus e the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. **6(f) Reasons for Change in Burden**  There is an overall decrease in burden as currently identified in the OMB Inventory of Approved Burdens. This decreas e is not due to any program changes. The change in the burden and cost estimates occurred because the standard s have been in effect for more than three ye ars and the requirements are different during initial compliance (new facilities) as compared to on

going compliance (existing facilities). The previous ICR reflected those burdens and costs associated with the initial activities for subject facilities. This includes purchasing monitoring15

equipment, conducting performance tests and establishing recordkeeping systems. This ICR, by in large, reflects the on

- going burden and costs for existing facilities. Activities for ex isting source include continuously monitoring of pollutants and the submission of semiannual reports. In addition, we have updated the number of respondents from 100 to 87 using the most recent data available. The overall result in a decrease in the number of responses, labor hours, and costs (including capital and O&M cost). **6(g) Burden Statement**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 233 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is no t required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA

- HQ

- OECA

- 2013

- 0337

. 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), WJC West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory A ffairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2013

- 0337 and OMB Control Number 2060

- 0416 in any correspondence. **Part B of the Suppor ting Statement**  This part is not applicable because no statistical methods were used in collecting this16

information.17

**Table 1: Annual Respondent Burden and Cost** 

**– NESHAP for Portland Cement Plants (40 CFR**  **Pa rt**  **63, Subpart**  **LLL) (Renewal)** 

**Burden Item** (A) Hours per Occurrence (B)

Occurrence per Respondent /Year (C)

Hours/ Respondent/ Year (A x B) (D)

Respondent

/ Yeara (E)

Technical Hours/ Year (C x D) (F)

Managerial Hours/ Year (E x 0.05) (G)

Clerical Hours/ Year (E x 0.10) (H)

Cost/ Year

b
1. APPLICATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3.ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS 16 1 16 5 80 4 8 $9,251.64 4. REPORT REQUIREMENTS A. Familiarize with regulatory requirement 1 1 1 87 87 4.35 8.7 $10,061.16 B. Required Activities Existing Sources Initial Performance Test 24 1 24 8.7 208.8 10.44 20.88 $24,146.78 Reference Method 321 Test 8 1 8 8.7 69.6 3.48 6.96 $8,048.93 Repeat Performance Test (assumes 10% repeat test) 24 1 24 1 24 1.2 2.4 $2,775.49 Initial THC Performance Test 8 1 8 8.7 69.6 3.48 6.96 $8,048.93 Repeat THC Performance Test 8 1 8 1 8 0.4 0.8 $925.16 Initial Hg Performance Test 40 1 40 8.7 348 17.4 34.8 $40,244.63 Repeat Hg Performance Test 8 1 8 1 8 0.4 0.8 $925.16 Initial HCl Performance Test 16 1 16 8.7 139.2 6.96 13.92 $16,097.85 Repeat HCl Performance Test 16 0.2 3.2 1 3.2 0.16 0.32 $370.07 Initial PM CEMS Performance Specification 11 40 0.2 8 8.7 69.6 3.48 6.96 $8,048.93 Repeat PM CEMS Performance Specification 11 40 0.2 8 1 8 0.4 0.8 $925.16 CEMS Monitoring 0.5 1 0.5 138 69 3.45 6.9 $7,979.54 CEMS Quarterly Inspections 2 4 8 138 1,104 55.2 110.4 $127,672.6318

CEM S Daily Calibration Drift Tests 0.3 330 99 138 13,662 683.1 1366.2 $1,579,948.82 Daily monitoring (CEMS) 2 4 8 138 1,104 55.2 110.4 $127,672.63 All CEMS must follow

appropriate performance specifications 0.3 330 99 138 13,662 683.1 1366.2 $1,579,948.82 New Sources Initial Performance Test 0.3 330 99 5 495 24.75 49.5 $57,244.52 Reference Method 321 Test 8 1 8 5 40 2 4 $4,625.82 Repeat Performance Test (assumes 10% repeat test) 8 1 8 1 8 0.4 0.8 $925.16 Initial THC Performance Test 24 1 24 5 120 6 12 $13,877.46 Repeat THC Performance Test 8 1 8 1 8 0.4 0.8 $925.16 Initial Hg Performance Test 8 1 8 5 40 2 4 $4,625.82 Repeat Hg Performance Test 40 1 40 1 40 2 4 $4,625.82 Initial HCl Performance Test 0 0 0 5 0 0 0 $0.00 Repeat HCl Performance Test 16 1 16 1 16 0.8 1.6 $1,850.33 Initial PM CEMS Performance Specification 11 16 0.2 3.2 5 16 0.8 1.6 $1,850.33 Repeat PM CEMS Performance Specification 11 40 1 40 1 40 2 4 $4,625.82 CEMS Monitoring 40 0.2 8 5 40 2 4 $4,625.82 CEMS Quarterly Inspections 0.5 1 0.5 5 2.5 0.13 0.25 $289.11 CEM S Daily Calibration Drift Tests 2 4 8 5 40 2 4 $4,625.82 Daily mo nitoring (CEMS) 2 4 8 5 40 2 4 $4,625.82 All CEMS must follow

appropriate performance specifications 0.3 330 99 5 495 24.75 49.5 $57,244.52 C. Create Information (Included in 4B) D. Gather Existing Information (Included in 4E) E. Write Report Existing Sources Notification of construction/reconstruction 2 1 2 8.7 17.4 0.87 1.74 $2,012.23 Notification of actual startup 2 1 2 8.7 17.4 0.87 1.74 $2,012.23 Physical or Operational Change 2 1 2 8.7 17.4 0.87 1.74 $2,012.23 Notification of Demonstration of CEMS 2 1 2 8.7 17.4 0.87 1.74 $2,012.2319

Report of Performance Test (included in 4B) Notification of Initial Performance Test 2 1 2 8.7 17.4 0.87 1.74 $2,012.23 Report of Performance Test 2 1 2 8.7 17.4 0.87 1.74 $2,012.23 Report of Semi

- Annual Reports 2 2 4 87 348 17.4 34.8 $40,244.63 New Sources Notification of construction/reconstruction 2 1 2 5 10 0.5 1 $1,156.46 Notification of actual startup 2 1 2 5 10 0.5 1 $1,156.46 Physical or Operational Change 2 1 2 5 10 0.5 1 $1,156.46 Notification of Demonstration of CEMS 2 1 2 5 10 0.5 1 $1,156.46 Report of Performance Test (included in 4B) Notification of Initial Performance Test 2 1 2 5 10 0.5 1 $1,156.46 Report of Performance Test 2 1 2 5 10 0.5 1 $1,156.46 Report of Semi

- Annual Reports 24 2 48 5 240 12 24 $27,754.92 **Subtotal for Reporting Requirements 37,854**  **$3,806,691** 5. RECORDKEEPING REQUIREMENTS A. Familiarize with regulatory requirement (Included in 4A) B. Plan Activities (Included in 4B) C. Implement Activities (Included in 4B) D. Record Data ( Not Applicable) E. Time to Transmit or Disclose Information Existing Sources Data Collection 0.1 330 33 138 4,554 227.7 455.4 $526,649.61 Records of Startups, Shutdowns, malfunctions, etc 0.1 330 33 138 4,554 227.7 455.4 $526,649.61 New Sources Data Collection 1.5 330 495 5 2,475 123.75 247.5 $286,222.61 Records of Startups, Shutdowns, malfunctions, etc 0.1 330 33 5 165 8.25 16.5 $19,081.51 Coal mill parameter monitoring 2 4 8 26 208 10.4 20.8 $24,054.2620

F. Time to Train Personnel 80 1 80 87 6,960 348 696 $804,892.68 G. Time for Audits (Not Applicable) **Subtotal for Recordkeeping Requirements 21,753**  **$2,187,550 TOTAL ANNUAL LABOR BURDEN AND**  **COST c**  **59,600 $5,990,000**  Total Capital and O&M Cost c $19,800,000 **GRAND TOTAL c**  **$25,800,000**

a We have assumed that there are approximately 87 respondents, 10% of the 87 existing facilities (8.7 facilities) will have new construction/reconstruction, and 5 new P ortland cement kilns per year will be required to complete performance tests and new/revised reports over the next three years.

b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 11 0 percent to account for the benefit packages available to those employed by private industry.

c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.21

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Portland Cement Plants (40 CFR**  **Pa rt**  **63, Subpart**  **LLL) (Renewal)** 

**Activity (A)**  **(B) (C)**  **(D) (E)**  **(F) (G)**  **(H)**
**EPA person**  **** **hours per occurrence**  **No. of**

**occurrences per plant**  **per year EPA** 

**person**   ** hours** **per plant**  **per year Plants** 

**per year**  **a Technical** 

**person**   ** hours per** **year Managem** **ent**

**person -**  **hours per year**  **Clerical**

**person**   ** hours per** **year Cost, $**  **b**

**(C=AxB) (E=CxD)**  **(Ex0.05) (Ex0.1)**  Initial performance tests c 24 1 24 13.7 328.8 16.4 32.9 $17,209. 39 Repeat performance test d 24 0.2 4.8 1 4.8 0.2 0.5 $251.23 Report Review Notification of construction 0.5 1 0.5 13.7 6.9 0.3 0.7 $358.53 Notification of actual startup 0.5 1 0.5 13.7 6.9 0.3 0.7 $358.53 Notification of performance test c 0.5 1.1 0.55 13.7 7.5 0.4 0.8 $394.38 Notification of P hysical or Operational Change 0.5 1 0.5 13.7 6.9 0.3 0.7 $358.53
Revie w test results/CEMS Results 8 1 8 13.7 109.6 5. 48 10.96 $5,736.4 6 Revie w semi

- annual summary report 8 2 16 87 1392 69.6 139.2 $72,857. 28 **Subtotals Labor Burden and C**  **ost 1,863.29**  **93.2 186.3**  **$97,524. 34**  **TOTAL ANNUAL BURDEN AND COST (rounded) e**  **2,140 $97,500** 

**Assu mptions:** 

a We have assumed that there are approximately 87 respondents, 10% of the 87 existing facilities (8.7 facilities) will have new construction/reconstruction, and 5 new P ortland cement kilns per year will be required to complete performance tests and new/revised reports over the next three years.22

b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government o verhead expenses: $62.90 for Managerial (GS

- 13, Step 5, $39.31 x 1.6), $46.67 for Technical (GS

- 12, Step 1, $29.17 x 1.6) and $25 .25 Clerical (GS

- 6, Step 3, $15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality rates of pay.

c We have assumed that it will take twenty

- four hours for each new respondent to perfo rm the initial performance test. d We have assumed that 10 percent of respondents would repeat performance test due to failure.

e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.