SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Portland Cement Plants (40 CFR Part 60, Subpart F) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Portland Cement Plants (40 CFR Part 60, Subpart F) (Renewal), 

EPA ICR Number 1051.13, OMB Control Number 2060-0025.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Portland Cement Plants were 

proposed on August 17, 1971, and promulgated on December 23, 1971. These regulations were 

revised on: December 14, 1988; October 17, 2000; September 9, 2010; and most-recently on 

February 12, 2013. The NSPS applies to the following emission units in Portland cement plants: 

kilns, clinker coolers, raw mill systems, raw mill dryers, raw material storage, clinker storage, 

finished product storage, conveyor transfer points, bagging and bulk loading and unloading 

systems. The final amendment reduces emission limits for nitrogen oxides (NOx), sulfur dioxide 

(SO2), and particulate matter (PM) from new kilns constructed or modified June 16, 2008, and 

requires continuous emissions monitoring for each of the three pollutants. This information is 

being collected to assure compliance with 40 CFR Part 60, Subpart F.

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 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 U.S.

Environmental Protection Agency (EPA) regional office.

Based on information reported to the Agency under the Greenhouse Gas Reporting 

Program in calendar year 2012, we determined that there were 96 Portland cement plants 

(respondents) in the United States operating 136 cement kilns. We assume that two plants per 

year will undergo modifications or reconstruction such that they will be subject to the initial 

notification reports and performance test requirement of the final NSPS. This estimated number 

of reconstructed sources per year is based on our 2010 amendment estimating that 7 kilns will 

undergo reconstruction during a three-year period. 

The Office of Management and Budget (OMB) approved the currently active ICR 
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without any “Terms of Clearance.”

There are approximately 96 cement plants, all of which are owned and operated by the 

portland cement industry. None of the plants in the United States are owned by either state, 

local, tribal, or the Federal government. They are all owned and operated solely by private forprofit businesses. The “burden” to the “Affected Public” may be found below in Table 1: 

Annual Respondent Burden and Cost – NSPS for Portland Cement Plants (40 CFR Part 60, 

Subpart F) (Renewal). The Federal Government “burden” is attributed entirely to work 

performed by either Federal employees or government contractors and may be found below in 

Table 2: Average Annual EPA Burden and Cost – NSPS for Portland Cement Plants (40 CFR 

Part 60, Subpart F) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for 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

four 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, NOx, SO2, and PM emissions from portland cement 
3

plants either cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health and/or welfare. Therefore, the NSPS were promulgated for this source category at 

40 CFR Part 60, Subpart F.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which where 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. Continuous emission monitors are used to 

ensure compliance with the standard 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 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 standard 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 60, Subpart F.

3(a) Non-duplication

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 either a state or local agency has adopted its own similar 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.

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 (78 FR 35023) on June 11, 2013. No comments were received on the 

burden published in the Federal Register.
4

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts. 

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 Portland Cement Association, at (202) 

408-9494, and the Concrete Foundation Association, at (319) 895-6940.

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 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

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 these standards do not include sensitive 
5

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are Portland cement 

plants. The United States Standard Industrial Classification (SIC) code for the respondents 

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

Classification System (NAICS) code 327310 for Cement Manufacturing. 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Portland 

Cement Plants (40 CFR Part 60, Subpart F). 

A source must make the following reports:

Notifications

Notification of construction/reconstruction 60.7(a)(1)

Notification of anticipated startup 60.7(a)(2)

Notification of actual startup 60.7(a)(3)

Notification of physical or operational change which may increase the 

emission rate

60.7(a)(4)

Notification of demonstration of continuous monitoring system 60.7(a)(5)

Notification of initial performance tests notice 60.8(d)

Notification of initial performance test results 60.8(a)

Repeat performance test results 60.64

Semiannual malfunction report 60.7(b), 60.65(c)

Semiannual report on excess emissions 60.7(c), 60.65(a-b)

Site-specific monitoring plan for bag leak detectors 60.63(f)(2)

A source must keep the following records:

Recordkeeping

Startup, shutdown, malfunctions, periods where the continuous 60.7(b), 60.65(c)
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Recordkeeping

monitoring system is inoperative 

Records of ongoing monitoring 60.7(f)

Record daily production and kiln feed rates 60.63(a)

Records of exceedance 60.65(a-b)

Maintain all records for two years 60.7(f)

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. 

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.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate SO2 and NOx Continuous Emission Monitoring 

Systems (CEMS), flow meters, and PM continuous parametric monitoring system (CPMS).

Perform initial performance test, Reference Method 5 or 5l 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 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.
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Respondent Activities

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly

reduced the burden associated with monitoring and recordkeeping. 

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

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 Online Tracking Information System (OTIS). 

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 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 entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 
8

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.

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 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 – NSPS for Portland Cement 

Plants (40 CFR Part 60, Subpart F) (Renewal).

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 three years from these recordkeeping 

and reporting requirements is estimated to be 14,535 (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 NSPS program, the previouslyapproved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs
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This ICR uses the following labor rates: 

Managerial $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

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

2013, “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.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type 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 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 

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)

CEMS $19,507 2 $39,014 $7,490 96 $719,040

Flow Meter $8,090 2 $16,180

Total $55,194 $719,040

The total capital/startup costs for this ICR are $55,194. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $719,040. This is the 

total of column G. 

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 $774,234. 

6(c) Estimating Agency Burden and 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 such activities as the 

examination of records maintained by the respondents, periodic inspection of sources of 
10

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 

$41,325. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 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 below in Table 2: Average Annual EPA Burden and Cost – NSPS for Portland 

Cement Plants (40 CFR Part 60, Subpart F) (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 years, approximately

96 existing respondents will be subject to these standards. It is estimated that no additional 

respondents per year will become subject. However, two existing respondents per year will 

undergo reconstruction. The overall average number of respondents, as shown in the table 

below, is 96 per year. 

The 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)

1

2 96 0 2 96

2

2 96 0 2 96

3

2 96 0 2 96

Average 2 96 0 2 96

1

New respondents include sources with constructed, reconstructed and modified affected facilities. 
11

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 96. 

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 construction/ 

reconstruction 2 1 N/A 2

Notification of actual startup 2 1 N/A 2

Notification of physical or 

operational change 2 1 N/A 2

Notification of demonstration 

of CEMS 2 1 N/A 2

Notification of initial 

performance tests 2 1 N/A 2

Report of performance test 2 1 N/A 2

Semiannual report 96 2 N/A 192

Total Number of Annual 

Responses 204

The number of Total Annual Responses is 204. 

The total annual labor costs are $1,421,761. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Portland Cement 

Plants (40 CFR Part 60, Subpart F) (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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 14,535. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NSPS for Portland Cement Plants (40 

CFR Part 60, Subpart F) (Renewal).
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Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 71 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $774,234. 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 917

labor hours at a cost of $41,325. See below Table 2: Average Annual EPA Burden and Cost –

NSPS for Portland Cement Plants (40 CFR Part 60, Subpart F) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment decrease in the respondent and Agency burden. This is not due to 

any program changes. The decrease occurred because we have modified the number of existing 

cement plants from 118 to 96 to reflect the latest industry data collected by the Agency’s 

Greenhouse Gas Reporting Program. This revision provides a more accurate estimate for the 

Portland cement sector, and results in an overall decrease in burden estimate. 

6(g) Burden Statement

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

is estimated to average 71 hours per response. “Burden” means the total time, effort, or financial 

resources expended by 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 systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and 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; 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 not 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-2013-0327. 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 
13

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 is (202) 566-1744. 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 Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2013-0327 and OMB Control Number 2060-0025 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NSPS for Portland Cement Plants (40 CFR Part 60, Subpart F) (Renewal)

Burden item

(A) 

Person hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person hours 

per 

respondent 

per year 

(AxB)

(D) 

Respondent

per year a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person/ 

hours per 

year 

(Ex0.05)

(G) 

Clerical 

person 

hours per 

year 

(Ex0.1)

(H) 

Total Cost per 

year b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c1 1 1 2 2 0.1 0.2 $224.98 

 B. Required activities 

 Initial performance test d36 1 36 2 72 3.6 7.2 $8,099.28 

 Repeat performance test e36 1 36 1 36 1.8 3.6 $4,049.64 

 CEMS initial performance test f8 1 8 2 16 0.8 1.6 $1,799.84 

 CEMS monitoring 0.5 1 0.5 2 1 0.05 0.1 $112.49 

 CEMS quarterly inspections g2 4 8 2 16 0.8 1.6 $1,799.84 

 CEMS daily calibration drift tests h0.3 330 99 2 198 9.9 19.8 $22,273.02 

 Daily monitoring (CEMS) i0.5 330 165 2 330 16.5 33 $37,121.70 

 C. Create information See 3B

 D. Gather existing information See 3E

 E. Write report 

 Notification of construction/reconstruction 2 1 2 2 4 0.2 0.4 $449.96 

 Notification of actual startup 2 1 2 2 4 0.2 0.4 $449.96 

 Notification of physical or operational change 2 1 2 2 4 0.2 0.4 $449.96 

 Notification of demonstration of CMS 2 1 2 2 4 0.2 0.4 $449.96 

 Report of performance test See 3B
15

Burden item

(A) 

Person hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person hours 

per 

respondent 

per year 

(AxB)

(D) 

Respondent

per year a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person/ 

hours per 

year 

(Ex0.05)

(G) 

Clerical 

person 

hours per 

year 

(Ex0.1)

(H) 

Total Cost per 

year b

 Notification of initial performance test 2 1 2 2 4 0.2 0.4 $449.96 

 Report of performance test 2 1 2 2 4 0.2 0.4 $449.96 

 Semiannual reports j24 2 48 96 4,608 230.4 460.8 $518,353.92 

Subtotal for Reporting Requirements 6,098.5 $596,534.47

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities See 3B 

 C. Implement activities See 3B

 D. Develop record system N/A

 E. Time to enter information

 Daily production and kiln feed rates k0.125 330 41.25 96 3,960 198 396 $445,460.40 

 Data Collection l0.1 330 33 96 3,168 158.4 316.8 $356,368.32 

 Records of startup, shutdown malfunction m1.5 1 1.5 96 144 7.2 14.4 $16,198.56 

 F. Train personnel for CEMS maintenance n16 2 32 2 64 3.2 6.4 $7,199.36 

 G. Audits 16 1 16 0 0 0 0 $0.00 

Subtotal for Recordkeeping Requirements 8,436.4 $825,226.64

TOTAL LABOR BURDEN AND COST

(rounded)

14,535 $1,421,761 

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be 96 existing plants, operating 136 kilns. There will be no additional 

sources over the three-year period of this ICR. We assume that two existing plants will undergo modification or reconstruction which will require re-submittal or 

notifications and retesting.

b

 This ICR uses the following labor rates: $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and $51.18 per 
16

hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March, 2013, 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 it will take one hour for each respondent to read instructions.

d

 We have assumed that each respondent will take 36 hours to perform initial performance tests.

e

 We have assumed that one respondent will have to repeat initial performance tests.. 

f

 We have assumed that it will take each respondent eight hours four times per year to perform CEMS inspections.

g We have assumed that it will take each respondent 2 hours 4 times per year to record daily production and kiln feed rates.

h

 We have assumed that it will take each respondent 0.3 hours 330 times per year to perform daily calibration drift tests.

i We have assumed that it will take each respondent 0.5 hours 330 times per year to perform daily CEMS monitoring.

j

 We have assumed that it will take each respondent 24 hours two times per year to prepare semiannual reports.

k

 We have assumed that it will take each respondent 0.125 hours 330 times per year to enter daily production and kiln feed rates information.

l

 We have assumed that it will take each respondent 0.1 hours 330 times per year to enter data collection information.

m

 We have assumed that it will take each respondent 1.5 hours once per year to record SSM.

n

 We have assumed that it will take each respondent 16 hours twice a year to train personnel on how to maintain the CEMS.
17

Table 2: Average Annual EPA Burden and Cost – NSPS for Portland Cement Plants (40 CFR Part 60, Subpart F) (Renewal)

Activity

(A) 

EPA personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours per 

plant per 

year 

(AxB)

(D) 

Plants per 

year a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

personhours per 

year 

(Ex0.1)

(H) 

Cost, $ b

Report review

 Notification of construction/reconstruction c

2 1 2 2 4 0.2 0.4 $207.30 

 Notification of actual startup c, d

0.5 1 0.5 2 1 0.05 0.1 $51.82 

 Notification of physical and operational change c

2 1 2 2 4 0.2 0.4 $207.30 

 Notification of initial performance test c, e

0.5 1.2 0.6 2 1.2 0.06 0.12 $62.19 

 Review test results c, f

8 1.2 9.6 2 19.2 0.96 1.92 $995.03 

 Review of semiannual reports i

4 2 8 96 768 38.4 76.8 $39,801.22 

TOTAL LABOR BURDEN AND COST 

(rounded) 917 $41,325

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be 96 existing plants with 136 operating kilns. There will be no 

additional sources over the three-year period of this ICR. We assume that two existing plants will undergo modification or reconstruction which will require resubmittal or notifications, and retesting.

b

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 

Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6). These rates 

are from the Office of Personnel Management (OPM) “2013 General Schedule”, which excludes locality rates of pay.

c

 We have assumed that the number of existing plants that undergo construction or reconstruction will be two.

d

 We have assumed that it will take each respondent 0.5 hours to review the actual startup report.

e

 We have assumed that it will take each respondent 0.5 hours to review initial performance test report.

f

 We have assumed that it will take each respondent 8 hours to review performance test results.

g

 We have assumed that it will take each respondent 4 hours two times per year to review semiannual reports.