TABLE 1: Annual Respondent Burden and Cost-NESHAP for Lime Manufacturing (40 CFR part 63, subpart AAAAA)

REPORTING/RECORDKEEPING REQUIREMENT

(A) 

Respondent 

Hours per 

Occurence 

(Technical 

hours) 

(B) 

Number of 

Occurences 

per 

Respondent 

per Year 

(C) 

Hours per 

Respondent 

per Year 

(C=A x B) 

(D) 

Number of 

Respondents 

per Yeara 

(E) 

Technical 

Hours per 

Year 

@ $97.59 

(E=C x D) 

(F) 

Managemen

t Hours per 

Year 

@ $114.77 

(F= E x 

0.05) 

(G) 

Clerical 

Hours per 

Year 

@ $48.26 

(G= E x 0.1) 

 

Total Labor 

Costs per Year 

1. APPLICATIONS N/A N/A N/A N/A N/A N/A N/A N/A

2. SURVEY AND STUDIES N/A N/A N/A N/A N/A N/A N/A N/A

3. 40 1 40 1 40 2 4 $4,326.18

4. REPORTING REQUIREMENTS

a. Read Instructionsb 2 1 2 1 2 0.1 0.2 $216.31

b. Required Activities

Repeat performance testsc 40 1 40 12.2 488 24.4 48.8 $52,779.40

Visible emission (VE) report for material 

handlingf

8 1 8 62 496 24.8 49.6 $53,644.63

Annual inspection of capture, collection, and 

transport systemg

8 1 8 62 496 24.8 49.6 $53,644.63

Inspection and maintenance of affected 

sources, control devices, and monitoring 

systems according to operation, maintenance, 

and monitoring planh

4 1 4 62 248 12.4 24.8 $26,822.32

c. Create Information

d. Gather Existing Information

e. Write Report

Notification of Applicabilityb 2 1 2 1 2 0.1 0.2 $216.31

Notification of Construction/Reconstructionb 2 1 2 1 2 0.1 0.2 $216.31

Notification of Anticipated Startupb 2 1 2 1 2 0.1 0.2 $216.31

Notification of Actual Startupb 2 1 2 1 2 0.1 0.2 $216.31

Notification of Special Compliance 

Requirements N/A N/A N/A N/A N/A N/A N/A N/A

Compliance Extention Requestb 2 1 2 1 2 0.1 0.2 $216.31

Notification of Performance Test 2 1 2 13.2 26.4 1.32 2.64 $2,855.28

Notification of Opacity/VE Observations 2 1 2 62 124 6.2 12.4 $13,411.16

Operation, Maintenance, and Monitoring Planb 40 1 40 1 40 2 4 $4,326.18

Startup, Shutdown, and Malfunction Planb 40 1 40 1 40 2 4 $4,326.18

Site-Specific Test Planb 40 1 40 1 40 2 4 $4,326.18

ACQUISITION, INSTALLATION, AND UTILIZATION OF 

TECHNOLOGY AND SYSTEMSb 

------------------------Included in 4b----------------------------

------------------------Included in 4b----------------------------
Notification of Compliance Statusb 8 1 8 1 8 0.4 0.8 $865.24

Waiver Application N/A N/A N/A N/A N/A N/A N/A N/A

Semiannual Compliance Reportsi 8 2 16 62 992 49.6 99.2 $107,289.26

Emergency Startup, Shutdown, and Malfunction 

Reportsj, k 8 1 8 3.1 25 1.2 2.5 $2,682.23

1,305 65 131

TOTAL REPORTING BURDEN 1,501 Hours $141,163

5. RECORDKEEPING REQUIREMENTS

a. Read Instructions

b. Plan Activities 3 1 3 1 3 0.15 0.3 $324.46

c. Implement Activitiesl 12 1 12 1 12 0.6 1.2 $1,297.85

d. Develop Record System 3 1 3 1 3 0.15 0.3 $324.46

e. Time to Enter Information

Record of All Information Required by

Standardsm 3 52 156 62 9,672 484 967 $1,046,070.32

f. Train Personneln 3 1 3 1 3 0.15 0.3 $324.46

g. 3 1 3 1 3 0.15 0.3 $324.46

h. Time to Transmit or Disclose Informationp 0.25 2 0.50 62 31 1.55 3.1 $3,352.79

g. Time for Audits N/A N/A N/A N/A N/A N/A N/A N/A

11,497 575 1,150

TOTAL RECORDKEEPING BURDEN 13,222 Hours $1,243,452

12,802 640 1,280

TOTAL ANNUAL LABOR BURDEN AND COST 14,723 Hours $1,384,616

6. ANNUAL CAPITAL COSTS

a. 13.2 $17,750

b. Performance test for material handlingc, e 13.2 $17,750

c. Bag Leak Detectorp 62 $88,908

TOTAL ANNUAL CAPITAL and O&M COSTS $124,408

Assumptions

b. This is a one-time only activity.

c. To demonstrate continuous compliance, plants must conduct performance tests every 5 years. The number of respondents to repeat performance test is 12.2 performance 

tests per year (61 existing respondents/5years). The cost to conduct a repeat Method 5 performance test is $5,000. The annualized capital cost to conduct this test is $1,250 per 

Performance test for kilnsc, d

------------------------Included in 4a----------------------------

a. Assumed that the average number of respondent that will be subject to the rule will be 61 existing respondents. There will be one additional new source per year that will 

become subject to the rule over the three-year period of this ICR. 

Time to Adjust Existing Wast to Comply with 

Previously Applicable Requirementso

Total Reporting Hours by Labor Category

Total Recordkeeping Hours by Labor Category

Total Hours by Labor Category

d. Assumed that there will be a total of three new kilns in production over the three year period of the ICR, which will average out to one unit per year. The cost for an initial Method 

5 test is $10,000, and the annualized cost for an initial performance test is $2,500 per new unit. One new unit per year is expected to conduct an initial Method 5 test.
e. Assumed that each existing plant has a material handling operation that would conduct a Method 5 performance test every 5 years. The number of respondents to conduct 

subsequent performance tests each year would be 61 existing respondents/5 years, or 12.2 respondents per year. Each respondent would incur an annual cost of $1,250 to 

perform subsequent Method 5 performance tests. Each new respondent is assumed to have a material handling operation that would conduct an initial Method 5 performance test. 

The cost of the initial test is $2,500 per new unit.

f. Assumed that each respondent will take 8 hours to complete the annual visible emission (VE) tests for material handling.

g. Assumed that each respondent will take 8 hours to complete the annual inspection of the capture, collection, and transport system.

h. Assumed that each respondent will take 4 hours to complete the inspection and maintenance of affected sources, control devices, and monitoring systems according to 

operation, maintenance, and monitoring plan.
REPORTING/RECORDKEEPING REQUIREMENT

(A) 

EPA Hours 

per 

Occurence 

(Technical 

hours) 

(B) 

Number of 

Occurences 

per Plant 

per Year 

(C) 

EPA Hours 

per Year 

(C=A x B) 

(D) 

Plants per 

Year a 

(E) 

Technical 

Hours per 

Year 

@ $45.52 

(E=C x D) 

(F) 

Management 

Hours per 

Year 

@ $61.36 

(F= E x 0.05) 

(G) 

Clerical 

Hours per 

Year 

@ $24.64 

(G= E x 0.1) 

 

Costs per 

Year 

INITIAL PERFORMANCE TESTS 40 1 40 1 40 2 4 $2,042.08

2 1 2 12.2 24.4 1.22 2.44 $1,245.67

REPEAT PERFORMANCE TESTb, c 40 1 40 12.2 488 24.4 48.8 $24,913.38

Notification of Applicability 1 1 1 1 1 0.05 0.1 $51.05

Notification of Construction/Reconstruction 1 1 1 1 1 0.05 0.1 $51.05

Notification of Anticipated Startup 1 1 1 1 1 0.05 0.1 $51.05

Notification of Actual Startup 1 1 1 1 1 0.05 0.1 $51.05

Notification of Special Compliance N/A N/A N/A N/A N/A N/A N/A N/A

Notification of Initial Performance Tests 1 1 1 1 1 0.05 0.1 $51.05

Notification of Compliance Status 4 1 4 1 4 0.2 0.4 $204.21

Review of Repeat Performance Test Reportb, d 2 1 2 12.2 24.4 1.22 2.44 $1,245.67

Review of Semiannual Compliance Report 4 2 8 62 496 24.8 49.6 $25,321.79

Review of Waiver Application N/A N/A N/A N/A N/A N/A N/A N/A

Review of Emergency Startup, Shutdown, and 

Malfunction Reporte 4 1 4 3.1 12.4 0.62 1.24 $633.04

SALARY BURDEN (per year) 1,094.2 54.71 109.42 $55,861

TOTAL ANNUAL BURDEN $55,861

Assumptions

c. Assumed that it will take 40 hours for respondents to repeat performance tests.

d. Assumed that it will take 2 hours for respondents to review repeat performance test report.

e. Assumed five percent of sources will need to submit emergency startup, shutdown, and malfunction reports.

a. Assumed that the average number of respondents that will be subject to the rule will be 61 existing respondents. There will be one additional new source per year that 

will become subject to the rule over the three-year period of this ICR for an average of 62 existing and new respondents per year.

b. To demonstrate continuous compliance, plants must conduct repeat performance tests every 5 years. The number of respondents to repeat performance test is 12.2 

test/year (61 existing respondents/5years = 12.2 performance tests per year) starting in the second year of this ICR. 

1,258

TABLE 2: Annual Agency Burden and Cost - NESHAP for Lime Manufacturing (40 CFR part 63, subpart AAAAA)

REPORT REVIEW

RETESTING PREPARATION FOR REPEAT 

PERFORMANCE TESTSb