SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Lime Manufacturing (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Lime Manufacturing (40 CFR part 63, subpart AAAAA) (Renewal)

1(b) Short Characterization/Abstract

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

regulations published at regulatory citation were proposed on December 20, 2002, (67 FR 

78045), and promulgated on January 5, 2004 (69 FR 393). These regulations apply to each 

existing and new lime manufacturing plant (LMP) that emits or has the potential to emit any

single hazardous air pollutant (HAP) at a rate of 9.07 megagrams (10 tons) or more per year or 

any combination of HAP at a rate of 22.68 megagrams (25 tons) or more per year from all 

emission sources at the plant site. This subpart applies to each existing and new lime kilns and 

their associated coolers, and processed stone handling (PSH) operations systems located at a 

LMP that is a major source. A new lime kiln is a lime kiln, and its associated lime cooler for 

which construction or reconstruction began after December 20, 2002, and a new PSH operations 

system is the equipment for which construction or reconstruction began after December 20, 2002. 

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

In general, all NESHAP 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 (SSM) 

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. Semiannual summary reports are 

also required. To demonstrate continuous compliance, plants must conduct repeat performance 

tests every five years (sixth year after effective date).

Any owner/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.

Based on consultations with industry representatives during a previous ICR renewal, there 

is an average of three effected facilities at each plant site and each plant site has only one 

respondent (i.e., the owner/operator of the plant site).
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Over the next three years, an average of 62 respondents per year will be subject to the 

standard, with one additional respondent per year becoming subject to the regulation over the 

next three years.

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/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, HAP emissions from lime manufacturing 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 category at 40 CFR part 63,

subpart AAAAA.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard 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. 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 
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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 and leaks are being detected and repaired and the standard is 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. Nonduplication, Consultations, and Other Collection Criteria

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

AAAAA).

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted its own 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, 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 (74 FR 32580) on July 8, 2009. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

For this information collection, the previous ICR renewal was used to obtain burden 

estimates since this ICR renewal was process under the “Expedited Approach” option provided 

in May 1, 2008 guidance. Per this guidance, all data and assumptions from the previous ICR 

renewal were used as the basis for estimating the hourly and cost burdens associated with this 

renewal. 

In the previous ICR, consultation with a government agency and industry representatives

was conducted to determine if there is anyway for EPA to reduce the recordkeeping and reporting 

burden or improve the language in the standard to make it easier to comply. 

The previous ICR used other resources to obtain the most recent data available which 

included reviewed information available from the United States Census Bureau, the AIRS
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Facility Subsystem (AFS), which is the primary source of information regarding the number of 

existing sources, and websites covering lime manufacturing. In the previous ICR, we also 

consulted with EPA’s Office of Air Quality Planning and Standards, Information Transfer and 

Program Integration Division.

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.

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 year records retention requirement is consistent with 

the Part 70 permit program 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 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. 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 (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.
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4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are lime manufacturing 

facilities. The United States Standard Industrial Classification (SIC) codes for the respondents 

affected by the standards, which corresponds to the North American Industry Classification 

System (NAICS) codes, are listed below for source category descriptions.

Standard (40 CFR part 63, subpart AAAAA)

SIC 

Codes

NAICS 

Codes

Lime Manufacturing 3274 327410

Iron and Steel Mills and Ferroalloy Manufacturing 33111

Nonferrous Metal (except Aluminum) Production and Processing 3314

Non-clay Refractory Manufacturing 327125

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NESHAP for Lime 

Manufacturing (40 CFR part 63, subpart AAAAA).

A source must make the following reports:

Notifications

Standard Citation by 

Sections

Applicability 63.9(b), 63.7130(a)

Anticipated startup 63.9(b)(4), 63.7130(a)

Commencement of construction 63.9(b)(4), 63.7130(a)

Actual startup 63.9(b)(4), 63.7130(a)

Intention to construct/reconstruct 63.9(b)(4)-(5), 

63.7130(a)

Compliance dates/extension 63.9(c), 63.7130(a)

Performance test/opacity observations 63.9(e), 63.7130(a)

Compliance status 63.9(g), 63.7130(a)
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Reports

Operation, maintenance, and monitoring plan 63.7100(d)

Startup, shutdown, and malfunction plan 63.6(e)(3), 63.10(d)(5), 

63.7100(e)

Semiannual compliance report 63.10(d)(2), 63.7131(b)

Emergency SSM reports, including where procedures were not 

followed

63.6(e)(3), 63.10(d)(5), 

63.7131(b)

A source must keep the following records:

Recordkeeping

Notifications and reports 63.10(b)(2)(xiv), 

63.7132(a)(1)

Startup, shutdown, and malfunction plan/events 63.6(e)(3)(iii)-(v), 

63.7132(a)(2)

Performance tests and opacity observations 63.10(b)(2)(viii), 

63.7132(a)(3)

Records required to demonstrate continuous compliance 63.10(b)(2)(vii), 

63.7132(c)

Visual observations 63.6(h)(6), 63.7132(b)

Records are required to be retained for five years 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.

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.
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Respondent Activities

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device.

Perform initial performance test, Reference Method 9 test, and repeat performance tests if 

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for 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 collection of information.

Transmit, or otherwise disclose the information.

Currently, sources are using automated monitoring equipment that provides parameter 

data. Although personnel at the sources 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

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.

Input, analyze, and maintain data in the Air Facility System (AFS).

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
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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.

Information contained in the reports is entered into the 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 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 five 

years.

5(c) Small Entity Flexibility

The impact on small entities (i.e., small businesses) was taken into consideration during 

the development of the regulation. In the final rulemaking notice, EPA prepared a regulatory

flexibility analysis (FRFA) which examined the impact of the final rule on small entities (See 69

FR 411, January 5, 2004). EPA identified 19 of the 45 companies owning potentially affected 

facilities as small businesses. Eight of these 45 companies manufacture beet sugar (which will 

not be subject to the final NESHAP), three of which are small firms. Further, an additional 3 of 

the 19 small companies will not be subject to the final NESHAP because they do not 

manufacture lime in a kiln (e.g., they are only depot or hydration facilities), and/ or we do not 

expect them to be major sources. It is, therefore, expected that 13 of the 34 companies subject to 

the final NESHAP will be small businesses, representing 38 percent of the affected companies. 

This percentage was applied to the total number of lime manufacturing plants affected by this 

regulation. In the 2004 final rulemaking notice and supporting ICR, EPA estimated 56 plants 

were affected by the regulation for the 3-year ICR period including calendar years 2004, 2005 

and 2006. Further, the 2007 ICR renewal indicated that EPA expected 1 new plant per year to 

become subject to the rule. For this 3-year ICR period, which includes calendar years 2010, 

2011, and 2012 it is estimated that there will be an average of 62 lime manufacturing plants, and 

EPA estimates that 24 of these 62 plants are owned by small entities. 

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 in Table 1: Annual Industry Burden for NESHAP for Lime Manufacturing (40 CFR part 
9

63, subpart AAAAA).

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 14,723 hours (Total Labor Hours from Table 1). 

The recordkeeping hours shown in Table 1 are 13,222. The reporting requirement hours shown 

in Table 1 are 1,501. 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.

(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. It is assumed that for each kiln control device, a bag leak detector will 

be installed. The one-time capital cost for a bag leak detector is estimated to be $10,000. 
10

The annual operation and maintenance costs are the ongoing costs to maintain the bag

leak detection monitors, costs to hire third party contractors to conduct Method 5 testing, 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/Startu

p Cost for 

One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost

(B X C)

(E)

Annualized 

Capital and

O&M Costs 

for One 

Respondent

(F)

Number of 

Respondents

with O&M

(G)

Total O&M,

(E X F)

Bag leak 

detector $10,000 1 $10,000 $1,434 62 $88,908

Performance 

Test for 

New Kilns

$0 1 $0 $2,500 1 $2,500

Performance 

Test for 

Existing 

Kilns

$0 1 $0 $1,250 12.2 $15,250

Performance 

Test for 

New

Material 

Handling

$0 1 $0 $2,500 1 $2,500

Performance 

Test for 

Existing 

Material 

Handling

$0 1 $0 $1,250 12.2 $15,250

The total capital/startup costs for this ICR are $10,000. This is the total of column D in 

the above table. The capital cost associated with the bag leak detector was annualized assuming a 

7 percent interest rate and 10-year life (i.e., capital recovery factor [CRF] of 0.1434). To 

calculate annualized costs, the CRF was multiplied by the capital cost of the detector, or $1,434 

per respondent.

The total operation and maintenance (O&M) costs for this ICR are $3,934 per existing 

respondent and $6,434 per new respondent and total $35,500 per year for all respondents. This is 

the total of column G. These costs include annualized costs for hiring a third party contractor to 

conduct Method 5 performance tests and the annual O&M costs for the bag leak detector.

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 $124,408. This is the average 
11

annual cost for the 3-year ICR that includes annual O&M costs and annualized capital costs as 

discussed above. These are recordkeeping costs.

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 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 

$55,861.

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 

in Table 2: Average Annual EPA Burden – NESHAP for Lime Manufacturing (40 CFR part 63, 

subpart AAAAA), below.

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

61 existing respondents and 1 new respondent will be subject to the standard. In the final 

rulemaking in 2004, EPA identified 56 lime manufacturing plants that were subject to the final 

rule in the three year period covering calendar years 2004, 2005, and 2006. The previous ICR 

renewal estimated that one additional respondent per year will become subject and thus the

overall average number of respondents for calendar years 2010, 2011, and 2012 is 62 per year, as 

shown in the table below.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR.

Number of Respondents
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Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year (A)

Number of New 

Respondents

(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 1 60 0 0 61

2 1 61 0 0 62

3 1 62 0 0 63

Average 1 61 0 0 62

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 62.

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 1 1 0 1

Notification of construction/ reconstruction 1 1 0 1

Notification of anticipated startup 1 1 0 1

Notification of actual startup 1 1 0 1

Notification of special compliance 

requirements N/A N/A N/A N/A

Compliance extension request 1 1 0 1

Notification of performance tests 13.2 1 0 13.2

Notification of opacity/VE observations 62 1 0 62

Operation, maintenance, and monitoring 

plans 1 1 0 1

Startup, shutdown, and malfunction plans 1 1 0 1

Site-specific test plan 1 1 0 1

Notification of compliance status 1 1 0 1

Waiver application N/A N/A N/A N/A

Semiannual compliance reports 62 2 0 124

Emergency startup, shutdown, or 

malfunction reports 3.1 1 0 3.1

Total 211.3

The number of Total Annual Responses is 211 (rounded).
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The total annual labor costs are $1,384,616. Details regarding these estimates may be 

found in Table 1: Annual Respondent Burden and Cost, NESHAP for Lime Manufacturing (40 

CFR part 63, subpart AAAAA), below.

The total annual capital/startup and O&M costs to the regulated entities are $124,408. 

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

Maintenance (O&M) Costs.

The average annual Agency burden and cost over next three years is estimated to be 1,258

labor hours at a cost of $55,861. See Table 2: Annual Agency Burden and Cost, NESHAP for 

Lime Manufacturing (40 CFR part 63, subpart AAAAA), below.

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 costs are $1,384,616. Details regarding these estimates may be 

found in Table 1: Annual Respondent Burden and Cost, NESHAP for Lime Manufacturing (40 

CFR part 63, subpart AAAAA), below. Furthermore, the annual public reporting and 

recordkeeping burden for this collection of information is estimated to average 70 (rounded) 

hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $124,408. 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 1,258

labor hours at a cost of $55,861. See Table 2: Annual Agency Burden and Cost, NESHAP for 

Lime Manufacturing (40 CFR part 63, subpart AAAAA), below.

6(f) Reasons for Change in Burden

The increase in burden hours and number of responses from the most recently approved 

ICR is due to an increase in the number of respondents. This ICR based the number of 

respondents on the number of lime manufacturing plants identified during the rulemaking and 

accounted for the one additional respondent per year since the rule became final. The previous 

ICR had identified the number of respondents as the number of companies with plants subject to 

the rule, but each plant should be considered a separate respondent and this correction is reflected 

in this ICR. An increase in burden per response also occurred due to an incorrect calculation of 

the number of responses in the previous ICR. 
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The decrease in capital and annual O&M costs reflects a change made to account for the 

fact that initial performance testing for Method 5 has been completed for existing sources, and 

the only units subject to initial testing is estimated to be one respondent per year. The existing 61 

respondents are only subject to repeat performance testing every five years, or 12.2 respondents 

per year. The capital and O&M costs also changed to include the costs for bag leak detection 

monitors to be consistent with the costs presented in the 2004 ICR associated with the final 

rulemaking notice for 40 CFR part 63, subpart AAAAA. 

6(g) Burden Statement

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

is estimated to average 70 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-2009-0408. 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 docket center is (202) 566-1927. 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-2009-0408 and OMB Control Number 2060-0544 in any 

correspondence. 
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Part B of the Supporting Statement

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