Burden Calculation Tables

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Overview

Cover
Inputs
Current ICR
TBL1-ResY1
TBL2-ResY2
TBL3-ResY3
TBL4-ResSUM
TBL5-EPAY1
TBL6-EPAY2
TBL7-EPAY3
TBL8-EPA SUMMARY

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Sheet 1: Cover

ATTACHMENT 1

SUPPORTING STATEMENT

National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA)

TABLES 1, 2, and 3

Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Lime Manufacturing NESHAP LEAN Proposed Rule – Years 1-3

TABLE 4

Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Lime Manufacturing NESHAP LEAN Proposed Rule

TABLES 5, 6, and 7

Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Lime Manufacturing NESHAP LEAN Proposed Rule - Year 1-3

TABLE 8

Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Lime Manufacturing NESHAP LEAN Proposed Rule

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Sheet 2: Inputs

Respondent Wages ($2021)
Category (1)	Hourly Mean Wage (2)	Loaded Wage (3)
Managerial	$56.06	$117.73
Technical	$50.74	$106.56
Clerical	$20.70	$43.47
Footnotes:
(1) The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2021 National Industry-Specific Occupational Employment and Wage Estimates NAICS 327000 - Nonmetallic Mineral Product Manufacturing," found here:
https://www.bls.gov/oes/current/naics3_327000.htm
(2) Loaded Wage is the 2021 Wage increased by 110 percent to account for the benefit packages available to those employed by private industry.
EPA Wages ($2016)
Category (1)	Hourly Mean Wage (2)	Wage With Fringe & Overhead (3)
(GS- 12, step 1) - Technical	$32.02	$51.24
(GS- 13, step 5) - Managerial	$43.15	$69.04
(GS-6, step 3) - Clerical	$17.33	$27.73
Footnotes:
(1) The hourly mean wage for each category is based on 2021 wages, and are found here:
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/21Tables/html/GS_h.aspx
(2) Wage with fringe and overhead is the hourly mean wage increased by 60 percent to account for the benefit packages available to government employees.

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Sheet 3: Current ICR

Table A: 2020 ICR (OMB Control No. 2060-0544) Annual Respondent Burden and Cost – Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
1. Applications	N/A									2020 ICR Hourly Wages
2. Survey and Studies	N/A									Managerial	$141.06
3. Acquisition, Installation, And Utilization of Technology and Systems c	40	1	40	1	40	2	4	$5,327.60		Technical	$120.27
4. Reporting Requirements										Clerical	$58.67
a. Familiarization with Regulatory Requirements	2	1	2	37	74	4	7	$9,856.06
b. Required Activities
Repeat performance tests for existing kilns and material handling d, e, f	40	1	40	22.6	904	45	90	$120,403.76
Visible emission (VE) report for material handling g	8	1	8	37	296	15	30	$39,424.24
Annual inspection of capture, collection, and transport system h	8	1	8	37	296	15	30	$39,424.24
Inspection and maintenance of affected sources, control devices, and monitoring systems according to operation, maintenance, and monitoring plan i	4	1	4	37	148	7	15	$19,712.12
c. Create Information	See 4B
d. Gather Existing Information	See 4B
e. Write Report
Notification of Applicability c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Construction/Reconstruction c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Anticipated Startup c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Actual Startup c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Special Compliance Requirements	N/A
Compliance Extension Request c	2	1	2	1	2	0.1	0.2	$266.38
Notification of Initial and Repeat Performance Tests d, e, f	2	1	2	23.6	47	2	5	$6,286.57
Notification of Opacity/VE Observations	2	1	2	37	74	4	7	$9,856.06
Operation, Maintenance, and Monitoring Plan c	40	1	40	1	40	2	4	$5,327.60
Startup, Shutdown, and Malfunction Plan c	40	1	40	1	40	2	4	$5,327.60
Site-Specific Test Plan c	40	1	40	1	40	2	4	$5,327.60
Notification of Compliance Status c	8	1	8	1	8	0.4	0.8	$1,065.52
Waiver Application	N/A
Semiannual Compliance Reports j	8	2	16	37	592	30	59	$78,848.48
Emergency Startup, Shutdown, and Malfunction Reports k,l	8	1	8	1.9	15	0.7	1	$1,971.21
Subtotal for Reporting Requirements					3,018			$349,491
5. Recordkeeping Requirements
a. Familiarization with Regulatory Requirements	See 4A
b. Plan Activities	3	1	3	1	3	0.2	0.3	$399.57
c. Implement Activities m	12	1	12	1	12	0.6	1.2	$1,598.28
d. Develop Record System	3	1	3	1	3	0.2	0.3	$399.57
e. Time to Enter Information
Record of All Information Required by Standards n	3	52	156	37	5,772	289	577	$768,772.68
f. Train Personnel o	3	1	3	1	3	0.2	0.3	$399.57
g. Time to Adjust Existing Waste to Comply with Previously Applicable Requirements p	3	1	3	1	3	0.2	0.3	$399.57
h. Time to Transmit or Disclose Information q	0.25	2	0.5	37	19	0.9	1.9	$2,464.02
g. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					6,687			$774,433
Total Labor Burden and Costs (rounded) r					9,700			$1,120,000
Capital and O&M Cost (rounded) r								$335,000
Grand Total (rounded) r								$1,460,000
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 36 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 37 existing and new respondents per year.
b. This ICR uses the following labor rates: $141.06 per hour for Executive, Administrative, and Managerial labor; $120.27 per hour for Technical labor, and $58.67 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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. This is a one-time only activity. New facilities install kilns and material handling equipment. New facilities submit notifications and plans.
d. Assumed that there will be a total of three new kilns brought into production (installed) over the three year period of the ICR. This averages out to one unit per year. One new kiln per year is expected to conduct an initial Method 5 test. The performance testing costs are covered in Section 6(b)(iii) of the Supporting Statement.
e. Respondents must conduct repeat performance tests on existing kilns every 5 years to demonstrate continuous compliance. There are 102 existing affected kilns. The number of respondents to repeat a performance test is 20.4 performance tests per year (102 affected kilns/5years).
f. Respondents must conduct repeat performance tests on existing materials handling operations whose emissions exit through stacks every 5 years to demonstrate continuous compliance. There are 11 existing affected materials handling operations with stacks that would conduct a Method 5 performance test every 5 years. The number of respondents to repeat a performance test is 2.2 performance tests per year (11 affected materials handling operations/5years).
g. Assumed that each respondent will take 8 hours to complete the annual visible emission (VE) tests for material handling.
h. Assumed that each respondent will take 8 hours to complete the annual inspection of the capture, collection, and transport system.
i. 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.
j. Assumed that it will take 8 hours each and two times per year to complete semiannual compliance reports.
k. Assumed that it will take 8 hours once a year to write the emergency startup, shutdown, or malfunction reports.
l. Assumed that 5 percent of respondents will have to complete the emergency startup, shutdown, or malfunction reports.
m. Assumed that it will take 12 hours to record activities implemented.
n. Assumed that all respondents will take 3 hours each to enter records of all the required information 52 times a year.
o. Assumed that it will take 3 hours to train each personnel.
p. Assumed that it will take 3 hours for each respondent to adjust existing ways to comply with previously applicable requirements.
q. Assumed that respondents are required to transmit/disclose information twice per year.
r. Totals are rounded to three significant figures. Figures may not add up exactly due to rounding.
Table B: 2020 ICR (OMB Control No. 2060-0544) Average Annual EPA Burden and Cost – NESHAP for Lime Manufacturing (40 CFR Part 63, Subpart AAAAA)
Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per respondent per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
Initial Performance Tests c	40	1	40	1	40	2	4	$2,217.84		2020 ICR Labor Rates
Retesting Preparation for Repeat Performance Tests d	2	1	2	22.6	45	2.26	4.5	$2,506.16		Management	$66.62
Repeat Performance Tests d	40	1	40	22.6	904	45	90	$50,123.18		Technical	$49.44
Report Review										Clerical	$26.75
Notification of Applicability	1	1	1	1	1	0.05	0.1	$55.45
Notification of Construction/Reconstruction	1	1	1	1	1	0.05	0.1	$55.45
Notification of Anticipated Startup	1	1	1	1	1	0.05	0.1	$55.45
Notification of Actual Startup	1	1	1	1	1	0.05	0.1	$55.45
Notification of Special Compliance Requirements	N/A
Notification of Initial Performance Tests	1	1	1	1	1	0.05	0.1	$55.45
Notification of Compliance Status	4	1	4	1	4	0.2	0.4	$221.78
Review of Repeat Performance Test Report e	2	1	2	22.6	45	2.3	4.5	$2,506.16
Review of Semiannual Compliance Report	4	2	8	37	296	15	30	$16,412.02
Review of Waiver Application	N/A
Review of Emergency Startup, Shutdown, and Malfunction Report f	4	1	4	1.9	7.6	0.38	0.76	$421.39
Total (rounded) g					1,550			$74,700
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 36 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 37 existing and new respondents per year.
b. This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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.
c. One new source per year will conduct a performance test on their kiln and materials handling operations. The Agency will spend 40 hours to attend the test and review the performance test report.
d. To demonstrate continuous compliance, plants must conduct repeat performance tests every 5 years. The number of respondents to repeat performance test is 22.6 tests/year ((102 existing kilns + 11 existing materials handling operations)/5years = 22.6 performance tests per year). Assumed that it will take 40 hours for respondents to repeat performance tests.
e. Assumed that it will take 2 hours for respondents to review repeat performance test report.
f. Assumed five percent of sources will need to submit emergency startup, shutdown, and malfunction reports.
g. Totals have been rounded to three significant figures. Figures may not add together exactly due to rounding.

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Sheet 4: TBL1-ResY1

Table 1 : Annual Respondent Burden and Cost Year One – Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA) (2024 Final Rule)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
1. Applications	N/A									Hourly Wages
2. Survey and Studies	N/A									Managerial	$117.73
3. Acquisition, Installation, And Utilization of Technology and Systems c	N/A									Technical	$106.56
4. Reporting Requirements										Clerical	$43.47
a. Familiarization with Regulatory Requirements	2	1	2	35	70	4	7	$8,175.55
b. Required Activities
Initial performance tests for existing kilns d, e	40	1	40	35	1,400	70	140	$163,510.90
Visible emission (VE) report for material handling g	N/A
Annual inspection of capture, collection, and transport system h	N/A
Inspection and maintenance of affected sources, control devices, and monitoring systems according to operation, maintenance, and monitoring plan i	4	1	4	35	140	7	14	$16,351.09
c. Create Information	See 4B
d. Gather Existing Information	See 4B
e. Write Report
Notification of Applicability c	N/A
Notification of Construction/Reconstruction c	N/A
Notification of Anticipated Startup c	N/A
Notification of Actual Startup c	N/A
Notification of Special Compliance Requirements	N/A
Compliance Extension Request c	N/A
Notification of Initial and Repeat Performance Tests d, e	2	1	2	35	70	4	7	$8,175.55
Notification of Opacity/VE Observations	N/A
Operation, Maintenance, and Monitoring Plan c	N/A
Startup, Shutdown, and Malfunction Plan c	N/A
Site-Specific Test Plan c	N/A
Notification of Compliance Status c	N/A
Waiver Application	N/A
Semiannual Compliance Reports j	8	2	16	35	560	28	56	$65,404.36
Emergency Startup, Shutdown, and Malfunction Reports k,l	8	1	8	35	280	14.0	28	$32,702.18
Subtotal for Reporting Requirements					2,898			$294,320
5. Recordkeeping Requirements
a. Familiarization with Regulatory Requirements	See 4A
b. Plan Activities	3	1	3	35	105	5.3	10.5	$12,263.32
c. Implement Activities m	12	1	12	35	420	21.0	42.0	$49,053.27
d. Develop Record System	3	1	3	35	105	5.3	10.5	$12,263.32
e. Time to Enter Information
Record of All Information Required by Standards n	3	52	156	35	5,460	273	546	$637,692.51
f. Train Personnel o	3	1	3	35	105	5.3	10.5	$12,263.32
g. Time to Adjust Existing Ways to Comply with Previously Applicable Requirements p	3	1	3	35	105	5.3	10.5	$12,263.32
h. Time to Transmit or Disclose Information q	0.25	2	0.5	35	18	0.9	1.8	$2,043.89
g. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					7,265			$737,843
Total Labor Burden and Costs (rounded) r					10,160			$1,030,000
Capital and O&M Cost (rounded) r								$335,000
Grand Total (rounded) r								$1,370,000
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 35 existing respondents. There will be no new sources per year that will become subject to the rule.
b. This ICR uses the United States Department of Labor, Bureau of Labor Statistics, May 2021 National Industry-Specific Occupational Employment and Wages Estimates for NAICS 327000 - Nonmetallic Mineral Product Manufacturing. The mean hourly rate (column 8 of the table) for occupational codes 11-1021 General and Operational Managers, 11-3051 Industrial Production Managers, and 43-6010 Secretaries and Administrative Assistants were used for Managerial ($56.06), Technical ($50.74), and clerical ($20.70) respectively. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c. No new facilities are expected to be built in this time period..
d. All respondants are required to perform initial performance testing in the first year.
e. Respondents must conduct repeat performance tests on existing kilns every 5 years to demonstrate continuous compliance.
f. 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.
g. Assumed that it will take 8 hours each and two times per year to complete semiannual compliance reports.
h. Assumed that it will take 8 hours once a year to write the emergency startup, shutdown, or malfunction reports.
i. Assumed that it will take 12 hours to record activities implemented.
j. Assumed that all respondents will take 3 hours each to enter records of all the required information 52 times a year.
k. Assumed that it will take 3 hours to train each personnel.
l. Assumed that it will take 3 hours for each respondent to adjust existing ways to comply with previously applicable requirements.
m. Assumed that respondents are required to transmit/disclose information twice per year.
n. Totals are rounded to three significant figures. Figures may not add up exactly due to rounding.

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Sheet 5: TBL2-ResY2

Table 2 : Annual Respondent Burden and Cost Year Two – Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA) (2024 Final Rule)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
1. Applications	N/A									Hourly Wages
2. Survey and Studies	N/A									Managerial	$117.73
3. Acquisition, Installation, And Utilization of Technology and Systems c	N/A									Technical	$106.56
4. Reporting Requirements										Clerical	$43.47
a. Familiarization with Regulatory Requirements	2	1	2	35	70	4	7	$8,175.55
b. Required Activities
Initial performance tests for existing kilns d, e	N/A
Visible emission (VE) report for material handling g	N/A
Annual inspection of capture, collection, and transport system h	N/A
Inspection and maintenance of affected sources, control devices, and monitoring systems according to operation, maintenance, and monitoring plan i	4	1	4	35	140	7	14	$16,351.09
c. Create Information	See 4B
d. Gather Existing Information	See 4B
e. Write Report
Notification of Applicability c	N/A
Notification of Construction/Reconstruction c	N/A
Notification of Anticipated Startup c	N/A
Notification of Actual Startup c	N/A
Notification of Special Compliance Requirements	N/A
Compliance Extension Request c	N/A
Notification of Initial and Repeat Performance Tests d, e	2	1	2	0	0	0	0	$0.00
Notification of Opacity/VE Observations	N/A
Operation, Maintenance, and Monitoring Plan c	N/A
Startup, Shutdown, and Malfunction Plan c	N/A
Site-Specific Test Plan c	N/A
Notification of Compliance Status c	N/A
Waiver Application	N/A
Semiannual Compliance Reports j	8	2	16	35	560	28	56	$65,404.36
Emergency Startup, Shutdown, and Malfunction Reports k,l	8	1	8	35	280	14.0	28	$32,702.18
Subtotal for Reporting Requirements					1,208			$122,633
5. Recordkeeping Requirements
a. Familiarization with Regulatory Requirements	See 4A
b. Plan Activities	N/A
c. Implement Activities m	N/A
d. Develop Record System	N/A
e. Time to Enter Information
Record of All Information Required by Standards n	3	52	156	35	5,460	273	546	$637,692.51
f. Train Personnel o	N/A
g. Time to Adjust Existing Ways to Comply with Previously Applicable Requirements p	N/A
h. Time to Transmit or Disclose Information q	0.25	2	0.5	35	18	0.9	1.8	$2,043.89
g. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					6,299			$639,736
Total Labor Burden and Costs (rounded) r					7,510			$760,000
Capital and O&M Cost (rounded) r								$335,000
Grand Total (rounded) r								$1,100,000
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 35 existing respondents. There will be no new sources per year that will become subject to the rule.
b. This ICR uses the United States Department of Labor, Bureau of Labor Statistics, May 2021 National Industry-Specific Occupational Employment and Wages Estiates for NAICS 327000 - Nonmetallic Mineral Product Manufacturing. The mean hourly rate (column 8 of the table) for occupational codes 11-1021 General and Operational Managers, 11-3051 Industrial Production Managers, and 43-6010 Secretaries and Administrative Assistants were used for Managerial ($56.06), Technical ($50.74), and clerical ($20.70) respectively. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c. No new facilities are expected to be built in this time period..
d. All respondants are required to perform initial performance testing in the first year.
e. Respondents must conduct repeat performance tests on existing kilns every 5 years to demonstrate continuous compliance.
f. 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.
g. Assumed that it will take 8 hours each and two times per year to complete semiannual compliance reports.
h. Assumed that it will take 8 hours once a year to write the emergency startup, shutdown, or malfunction reports.
i. Assumed that this action was acoomplished in year 1, and not required in years 2 and 3.
j. Assumed that all respondents will take 3 hours each to enter records of all the required information 52 times a year.
k. Assumed that this action was accomplished in year 1 and not required in years 2 and 3.
l. Assumed that this action was accomplished in year 1 and not required in years 2 and 3.
m. Assumed that respondents are required to transmit/disclose information twice per year.
n. Totals are rounded to three significant figures. Figures may not add up exactly due to rounding.

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Sheet 6: TBL3-ResY3

Table 3 : Annual Respondent Burden and Cost Year Three – Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA) (2024 Final Rule)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
1. Applications	N/A									Hourly Wages
2. Survey and Studies	N/A									Managerial	$117.73
3. Acquisition, Installation, And Utilization of Technology and Systems c	N/A									Technical	$106.56
4. Reporting Requirements										Clerical	$43.47
a. Familiarization with Regulatory Requirements	2	1	2	35	70	4	7	$8,175.55
b. Required Activities
Initial performance tests for existing kilns d, e	N/A
Visible emission (VE) report for material handling g	N/A
Annual inspection of capture, collection, and transport system h	N/A
Inspection and maintenance of affected sources, control devices, and monitoring systems according to operation, maintenance, and monitoring plan i	4	1	4	35	140	7	14	$16,351.09
c. Create Information	See 4B
d. Gather Existing Information	See 4B
e. Write Report
Notification of Applicability c	N/A
Notification of Construction/Reconstruction c	N/A
Notification of Anticipated Startup c	N/A
Notification of Actual Startup c	N/A
Notification of Special Compliance Requirements	N/A
Compliance Extension Request c	N/A
Notification of Initial and Repeat Performance Tests d, e	2	1	2	0	0	0	0	$0.00
Notification of Opacity/VE Observations	N/A
Operation, Maintenance, and Monitoring Plan c	N/A
Startup, Shutdown, and Malfunction Plan c	N/A
Site-Specific Test Plan c	N/A
Notification of Compliance Status c	N/A
Waiver Application	N/A
Semiannual Compliance Reports j	8	2	16	35	560	28	56	$65,404.36
Emergency Startup, Shutdown, and Malfunction Reports k,l	8	1	8	35	280	14.0	28	$32,702.18
Subtotal for Reporting Requirements					1,208			$122,633
5. Recordkeeping Requirements
a. Familiarization with Regulatory Requirements	See 4A
b. Plan Activities	N/A
c. Implement Activities m	N/A
d. Develop Record System	N/A
e. Time to Enter Information
Record of All Information Required by Standards n	3	52	156	35	5,460	273	546	$637,692.51
f. Train Personnel o	N/A
g. Time to Adjust Existing Ways to Comply with Previously Applicable Requirements p	N/A
h. Time to Transmit or Disclose Information q	0.25	2	0.5	35	18	0.9	1.8	$2,043.89
g. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					6,299			$639,736
Total Labor Burden and Costs (rounded) r					7,510			$760,000
Capital and O&M Cost (rounded) r								$335,000
Grand Total (rounded) r								$1,100,000
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 35 existing respondents. There will be no new sources per year that will become subject to the rule.
b. This ICR uses the United States Department of Labor, Bureau of Labor Statistics, May 2021 National Industry-Specific Occupational Employment and Wages Estiates for NAICS 327000 - Nonmetallic Mineral Product Manufacturing. The mean hourly rate (column 8 of the table) for occupational codes 11-1021 General and Operational Managers, 11-3051 Industrial Production Managers, and 43-6010 Secretaries and Administrative Assistants were used for Managerial ($56.06), Technical ($50.74), and clerical ($20.70) respectively. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c. No new facilities are expected to be built in this time period..
d. All respondants are required to perform initial performance testing in the first year.
e. Respondents must conduct repeat performance tests on existing kilns every 5 years to demonstrate continuous compliance.
f. 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.
g. Assumed that it will take 8 hours each and two times per year to complete semiannual compliance reports.
h. Assumed that it will take 8 hours once a year to write the emergency startup, shutdown, or malfunction reports.
i. Assumed that this action was acoomplished in year 1, and not required in years 2 and 3.
j. Assumed that all respondents will take 3 hours each to enter records of all the required information 52 times a year.
k. Assumed that this action was accomplished in year 1 and not required in years 2 and 3.
l. Assumed that this action was accomplished in year 1 and not required in years 2 and 3.
m. Assumed that respondents are required to transmit/disclose information twice per year.
n. Totals are rounded to three significant figures. Figures may not add up exactly due to rounding.

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Sheet 7: TBL4-ResSUM

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA) (2024 Final Rule)
Year	Technical Hours	Management Hours	Clerical Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	8,838	442	884	10,163	$1,030,000	$335,000	$1,370,000
2	6,528	326	653	7,507	$760,000	$335,000	$1,100,000
3	6,528	326	653	7,507	$760,000	$335,000	$1,100,000
Total	21,893	1,095	2,189	25,176	$2,550,000	$1,005,000	$3,570,000
Average	7,298	365	730	8,392	$850,000	$335,000	$1,190,000

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Sheet 8: TBL5-EPAY1

Table 5: Average Annual EPA Burden and Cost Year One – Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA) (2024 Final Rule)
Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per respondent per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
Initial Performance Tests c	40	1	40	35	1400	70	140	$80,451.00		Labor Rates
Retesting Preparation for Repeat Performance Tests d	N/A									Management	$69.04
Repeat Performance Tests d	N/A									Technical	$51.24
Report Review										Clerical	$27.73
Notification of Applicability	N/A
Notification of Construction/Reconstruction	N/A
Notification of Anticipated Startup	N/A
Notification of Actual Startup	N/A
Notification of Special Compliance Requirements	N/A
Notification of Initial Performance Tests	1	1	1	35	35	1.75	3.5	$2,011.28
Notification of Compliance Status	4	1	4	35	140	7	14	$8,045.10
Review of Repeat Performance Test Report e	N/A
Review of Semiannual Compliance Report	4	2	8	35	280	14	28	$16,090.20
Review of Waiver Application	N/A
Review of Emergency Startup, Shutdown, and Malfunction Report f	4	1	4	35.0	140	7	14	$8,045.10
Total (rounded) g					2,290			$114,600
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 35 existing respondents. There will be no new sources per year that will become subject to the rule over the three-year period of this ICR.
b. This ICR uses the following labor rates: $43.15for managerial, $32.02 for technical, and $17.33 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2020 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.
c. No new sources per year for this action.
d. To demonstrate continuous compliance, plants must conduct repeat performance tests every 5 years. Assumed that it will take 40 hours for respondents to repeat performance tests.
e. Assumed that it will take 2 hours for respondents to review repeat performance test report.
f. Totals have been rounded to three significant figures. Figures may not add together exactly due to rounding.

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Sheet 9: TBL6-EPAY2

Table 6: Average Annual EPA Burden and Cost Year Two – Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA) (2024 Final Rule)
Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per respondent per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
Initial Performance Tests c	N/A									Labor Rates
Retesting Preparation for Repeat Performance Tests d	N/A									Management	$69.04
Repeat Performance Tests d	N/A									Technical	$51.24
Report Review										Clerical	$27.73
Notification of Applicability	N/A
Notification of Construction/Reconstruction	N/A
Notification of Anticipated Startup	N/A
Notification of Actual Startup	N/A
Notification of Special Compliance Requirements	N/A
Notification of Initial Performance Tests	N/A
Notification of Compliance Status	4	1	4	35	140	7	14	$8,045.10
Review of Repeat Performance Test Report e	N/A
Review of Semiannual Compliance Report	4	2	8	35	280	14	28	$16,090.20
Review of Waiver Application	N/A
Review of Emergency Startup, Shutdown, and Malfunction Report f	4	1	4	35.0	140	7	14	$8,045.10
Total (rounded) g					640			$32,200
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 35 existing respondents. There will be no new sources per year that will become subject to the rule over the three-year period of this ICR.
b. This ICR uses the following labor rates: $43.15for managerial, $32.02 for technical, and $17.33 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2020 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.
c. No new sources per year for this action.
d. To demonstrate continuous compliance, plants must conduct repeat performance tests every 5 years. Assumed that it will take 40 hours for respondents to repeat performance tests.
e. Assumed that it will take 2 hours for respondents to review repeat performance test report.
f. Totals have been rounded to three significant figures. Figures may not add together exactly due to rounding.

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Sheet 10: TBL7-EPAY3

Table 7: Average Annual EPA Burden and Cost Year Three – Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA) (2024 Final Rule)
Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per respondent per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year ($) b
Initial Performance Tests c	N/A									Labor Rates
Retesting Preparation for Repeat Performance Tests d	N/A									Management	$69.04
Repeat Performance Tests d	N/A									Technical	$51.24
Report Review										Clerical	$27.73
Notification of Applicability	N/A
Notification of Construction/Reconstruction	N/A
Notification of Anticipated Startup	N/A
Notification of Actual Startup	N/A
Notification of Special Compliance Requirements	N/A
Notification of Initial Performance Tests	N/A
Notification of Compliance Status	4	1	4	35	140	7	14	$8,045.10
Review of Repeat Performance Test Report e	N/A
Review of Semiannual Compliance Report	4	2	8	35	280	14	28	$16,090.20
Review of Waiver Application	N/A
Review of Emergency Startup, Shutdown, and Malfunction Report f	4	1	4	35.0	140	7	14	$8,045.10
Total (rounded) g					640			$32,200
Assumptions:
a. Assumed that the average number of respondents that will be subject to the rule will be 35 existing respondents. There will be no new sources per year that will become subject to the rule over the three-year period of this ICR.
b. This ICR uses the following labor rates: $43.15for managerial, $32.02 for technical, and $17.33 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2020 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.
c. No new sources per year for this action.
d. To demonstrate continuous compliance, plants must conduct repeat performance tests every 5 years. Assumed that it will take 40 hours for respondents to repeat performance tests.
e. Assumed that it will take 2 hours for respondents to review repeat performance test report.
f. Totals have been rounded to three significant figures. Figures may not add together exactly due to rounding.

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Sheet 11: TBL8-EPA SUMMARY

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Lime Manufacturing Plants (40 CFR Part 63, Subpart AAAAA) (2024 Final Rule)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	1,995	100	200	2,294	$114,600	$0	$114,600
2	560	28	56	644	$32,200	$0	$32,200
3	560	28	56	644	$32,200	$0	$32,200
Total	3,115	156	312	3,582	$179,000	$0	$179,000
Average	1,038	52	104	1,194	$59,700	$0	$59,700