2509ss01

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NESHAP for Brick and Structural Clay Products Manufacturing (40 CFR part 63, subpart JJJJJ) (Proposed Rule)

OMB: 2030-0047

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2020-08-27 - New collection (Request for a new OMB Control Number)

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SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay
Products Manufacturing
(40 CFR Part 63, Subpart JJJJJ)
July 2014
Part A of the Supporting Statement
1.0

Identification of the Information Collection
1(a)

Title and Number of the Information Collection

“National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay
Products Manufacturing (40 CFR Part 63, Subpart JJJJJ).” This is a new information collection
request (ICR). The EPA ICR tracking number is 2509.01.
1(b)

Short Characterization

Potential respondents are owners or operators of new and existing sources at brick and/or
structural clay products (BSCP) manufacturing facilities. A BSCP facility manufactures brick,
including face brick, structural brick, brick pavers, or other brick and/or structural clay products
including clay pipe; roof tile; extruded floor and wall tile; or other extruded, dimensional clay
products. The BSCP facilities typically form, dry and fire bricks and shapes that are composed
primarily of clay and shale. Kilns are used to fire BSCP. The rule applies to all new and existing
tunnel and periodic kilns at BSCP facilities.
Consistent with the General Provisions for NESHAP for Source Categories (40 CFR
part 63, subpart A), respondents do not include the owner or operator of any facility that is not a
major source of hazardous air pollutant (HAP) emissions (i.e., an area source). A major source of
HAP is a plant site that emits or has the potential to emit any single HAP at a rate of 10 tons or
more per year or any combination of HAP at a rate of 25 tons or more per year. There are
92 existing BSCP facilities that are currently major sources of HAP. An estimated 25 of these
facilities are projected to become synthetic area sources (i.e., obtain a federally enforceable limit
reducing emissions below major source thresholds) by the effective date of the rule rather than
comply with subpart JJJJJ. The remaining 67 existing BSCP facilities are expected to be subject
to the rule. Based on the latest BSCP industry profile, no new BSCP facilities or kilns are
expected to be constructed in the near future, and existing capacity is assumed to be sufficient to
cover any short-term increases in production.
Respondents must submit one-time notifications of applicability and reports on initial
performance test results. Respondents must also develop and implement an operation,
maintenance and monitoring (OM&M) plan covering each affected source and each emission
control device used for compliance with the rule. Semiannual reports for periods of emission
limitation deviations (or reports certifying that no deviations have occurred) also are required.
General requirements applicable to all NESHAP include records of applicability determinations,

performance test results, deviations, monitoring records and all other information needed to
determine compliance with the applicable standard. Records and reports must be retained for a
minimum of 5 years. The most recent 2 years of data must be retained onsite. The remaining
3 years of data may be retained offsite.
Subpart JJJJJ requires respondents to monitor control device operating parameters to
assure continuous compliance with the rule. Parameter monitoring requirements for dry injection
fabric filter (DIFF) or dry lime scrubber/fabric filter (DLS) include lime injection rate
monitoring and either periodic visible emissions (VE) determinations or bag leak detectors.
Parameter monitoring requirements for dry limestone adsorbers (DLA) include limestone feed
rate monitoring, periodic VE determinations and either pressure drop monitoring or bypass stack
damper position monitoring. Facilities using a DLA must also record the source of limestone
used in the DLA. The rule also includes monitoring requirements for wet scrubbers, including
monitoring of pressure drop, scrubber liquid pH, scrubber liquid flow rate and chemical addition
rate (if applicable), as well as monitoring of carbon flow rate for activated carbon injection.
Respondents with no control device must conduct periodic VE determinations and monitor the
process rate of the kiln (if their last calculated total facility maximum potential hydrogen
chloride-equivalent was above the proposed acid gas emission limitation). Respondents also
must maintain records of specific information needed to determine that the standards are being
achieved and maintained.
2.

Need For and Use of the Collection
2(a)

Need/Authority for the Collection

The EPA is required under section 112(d) of the Clean Air Act (CAA), as amended, to
establish emission standards for each category or subcategory of major and area sources of HAP
listed for regulation in section 112(b). These standards are applicable to new or existing sources
of HAP and shall require the maximum degree of emission reduction. In addition, section 114 of
the CAA allows the Administrator to require inspections, monitoring and entry into facilities to
ensure compliance with a section 112 emission standard. Section 114(a)(1) specifically states
that the Administrator may require any owner or operator subject to any requirement of the CAA
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; (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.
The predominant HAP emitted from BSCP manufacturing facilities include hydrogen
fluoride (HF), hydrogen chloride (HCl), chlorine (Cl 2 ) and metals (antimony, arsenic, beryllium,
cadmium, chromium, cobalt, mercury, manganese, nickel, lead and selenium). In the
Administrator’s judgment, the pollutants emitted from BSCP manufacturing facilities cause or
contribute significantly to air pollution that may reasonably be anticipated to endanger public

health. Consequently, NESHAP for this source category were promulgated at 40 CFR part 63,
subpart JJJJJ on May 16, 2003. (Note: The BSCP manufacturing source category was originally
included in the clay products manufacturing industry source category in the initial list of source
categories published on July 16, 1992 (57 FR 31576). The BSCP manufacturing source category
was subsequently identified as a separate and distinct source category and was added to the list
of source categories on July 22, 2002 (67 FR 47894).)
The BSCP standards were challenged by the Sierra Club and subsequently vacated by the
United States Circuit Court for the District of Columbia on March 13, 2007, due to issues
associated with the methodology used to determine the minimum regulatory “floors” for new and
existing units. The EPA and Sierra Club later negotiated a consent decree to settle the litigation
and set forth proposal and promulgation deadlines for reestablishing standards for this source
category. Consequently, new NESHAP for this source category are being proposed.
2(b)

Practical Utility/Users of the Data

The information collected from respondents will be used by EPA enforcement personnel
to: (1) identify new, modified, reconstructed and existing sources subject to the standards;
(2) ensure that maximum achievable control technology (MACT) is being properly applied; and
(3) ensure that the emission control devices are being properly operated and maintained on a
continuous basis. In addition, records and reports are necessary to enable the EPA to identify
facilities that may not be in compliance with the standards. Based on the reported information,
the EPA can decide which facilities should be inspected and what records or processes should be
inspected at these facilities. The records that facilities maintain will indicate to the EPA whether
the owners or operators are in compliance with the emission limitations (including emission
limits, operating limits) and work practice standards. Much of the information the EPA would
need to determine compliance would be recorded and retained onsite at the facility. Such
information would be reviewed by enforcement personnel during an inspection and would not
need to be routinely reported to the EPA.
3.

Nonduplication, Consultations and Other Collection Criteria
3(a)

Nonduplication

The information required by the BSCP manufacturing NESHAP is not duplicated by
existing EPA regulations and is not expected to be required by any other EPA rulemaking
currently in progress. However, certain reports required by state or local agencies may duplicate
information required by the standards. In such cases, a copy of the report submitted to the state
or local agency may be provided to the Administrator in lieu of the report required by the
standards.
3(b)

Public Notice Required Prior to ICR Submission to OMB

This section is not applicable because this is a rule-related ICR. Nevertheless, the ICR
will be available for public review during the public comment period following publication of
the proposed rule in the Federal Register.

3(c)

Consultations

Specific comments on the burden associated with the information collection requirements
were received from the Brick Industry Association (BIA) and companies in the BSCP industry
for the 2003 rulemaking and have been incorporated in the burden estimates for this rule.
Representatives of BIA and its member companies have also been consulted during development
of this rule, and several meetings and teleconferences have been held with them during this time.
During these meetings, the representatives were given the opportunity to comment on the
regulatory approach. The major topics of these discussions included rule applicability,
subcategories, emissions data, MACT floor approach and alternative standards. No specific
information was provided to the representatives with respect to burden estimates prior to
proposal of the rule. Others consulted for information during the development process for the
proposed standards included air pollution control device vendors (Encertec, McGill AirClean,
Solios Environment, W.L. Gore and Associates and Cabot Norit Activated Carbon) and small
business owners in the BSCP industry.
The EPA is providing a 60-day public comment period following proposal of the BSCP
manufacturing NESHAP, during which all affected parties will be given the opportunity to
comment on the proposed rule. The EPA will consider the comments received and, as
appropriate, incorporate them into the final rule. This ICR will also be revised to incorporate the
comments received.
3(d)

Effects of Less Frequent Collection

If the relevant information was collected less frequently, the EPA would not be
reasonably assured that the facilities are applying good operation and maintenance practices and
meeting the emission limitations and work practice standards in the rule. In addition, our
authority to take administrative action would be significantly reduced. Section 113(d) of the
CAA limits the assessment of administrative penalties to violations which occur no more than
12 months before initiation of the administrative proceeding. Since administrative proceedings
are less costly and require use of fewer resources than judicial proceedings, both we and the
regulated community benefit from preservation of our administrative powers. Also, the reporting
frequency in the rule is consistent with the requirements of title V permit programs.
Consequently, less frequent reports would not result in a reduced burden.
3(e)

General Guidelines

The BSCP manufacturing NESHAP requires that facilities retain records for a period of
5 years, which exceeds the 3-year retention period specified in the general information collection
guidelines in 5 CFR 1320.6(f) of OMB regulations implementing the Paperwork Reduction Act.
However, the 5-year retention period is consistent with the retention requirement in the General
Provisions in subpart A of 40 CFR part 63 and the retention requirement in the operating permit
program under 40 CFR part 70. All facilities subject to this rule will be required to obtain
operating permits either through the state-approved permitting program or, if one does not exist,
in accordance with the provisions of 40 CFR part 71. Thus, the 5-year record retention
requirement of the rule adds no additional burden. At a minimum, respondents will be required
to retain onsite the most recent 2 years of data. The remaining 3 years of data could be retained at

a readily accessible onsite or offsite storage facility. None of the other guidelines in 5 CFR
1320.6 are being exceeded.
3(f)

Confidentiality

All information submitted to the EPA for which a claim of confidentiality is made will be
safeguarded according to EPA 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 39999, September 28, 1978; 43 FR 42251, September 28, 1978; and 44 FR
17674, March 23, 1979.)
3(g)

Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.
4.

The Respondents and the Information Requested
4(a)

Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are owners or operators
of BSCP manufacturing facilities that are major sources of HAP emissions. The North American
Industry Classification System (NAICS) code for respondents affected by the standards is
327120—Clay Building Material and Refractories Manufacturing. Not all processes classified in
this NAICS code are regulated by the standards.
4(b)

Information Requested
(i)

Data Items, Including Recordkeeping Requirements

All data in this ICR that are recorded and/or reported are required by the NESHAP for
Brick and Structural Clay Products Manufacturing (40 CFR part 63, subpart JJJJJ). The
following table summarizes the recordkeeping and reporting requirements under the rule.
Requirements

Rule Citation by Section

Notifications
Initial notifications (including construction/reconstruction)

63.5, 63.9(b) and
63.8480(a)-(c)

Notification of performance test

63.7(b)-(c), 63.9(e) and
63.8480(d)

Notification of compliance status (including performance test
results, operating parameter values, bag leak detection system
documentation and OM&M plan)

63.9(h), 63.10(d)(2) and
63.8480(e)

Request for routine control device maintenance exemption

63.8480(f)

Records
Record retention

63.10(b)(1) and 63.8495

Requirements

Rule Citation by Section

Documentation supporting initial notifications and notifications
of compliance status

63.10(b)(2)(xiv) and
63.8490(a)(1)

Records of performance tests

63.10(b)(2)(viii) and
63.8490(a)(2)

Records of control device maintenance and documentation of
approved routine control device maintenance exemption

63.8490(a)(3)

Records for each continuous monitoring system (CMS),
production records, bag leak detection system records, records of
operating limit deviations and corrective actions, maintenance
and inspection records, records used to demonstrate compliance
with work practice standards and malfunction records

63.8(d)(3), 63.8(g),
63.10(b)(2)(iii),(vi)-(xi) and
63.8490(b)-(c)

OM&M plan

63.8490(c)(6)

Reports
First compliance report
Semi-annual compliance report:
-No deviations/no out-of-control CMS
-Deviations/out-of-control CMS

63.8485(b)-(f)
63.8485(b)-(f)
63.8485(c)(6)-(7)
63.8485(d)-(e)

Electronic submittal of performance test results (using ERT)

63.8485(g)

(ii)

Respondent Activities

The respondent activities required by the standards in the first 3 years following the
effective date are identified in Tables 1 through 3 and are introduced in Section 6(a).
5.

The Information Collected--Agency Activities, Collection Methodology and
Information Management
5(a)

Agency Activities

The Agency activities in the first 3 years following the effective date of the rule are
identified in Tables 5 through 7 and are introduced in Section 6(c).
5(b)

Collection Methodology and Management

Following initial notification, the reviewing authority may 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 and ongoing 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 will be entered into the Air Facility System (AFS),
which is operated and maintained by the EPA’s Office of Compliance. The AFS is the EPA’s
database for the collection, maintenance and retrieval of air compliance data for over 125,000
industrial and government-owned facilities. The EPA uses the AFS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA Regional offices and
EPA headquarters. The 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 or operator for
5 years.
5(c)

Small Entity Flexibility

The EPA is concerned about the proposed rule’s potential impacts on small entities,
because 36 of 44 firms owning BSCP facilities have 750 or fewer employees and thus meet the
Small Business Administration’s (SBA’s) criterion for a small entity in this industry (NAICS
code 327120). Consequently, the EPA conducted a screening analysis of the potential impacts,
by computing the ratio of control costs to firm sales revenues. Based on the results of the
screening analysis, the EPA concluded that it is not able to certify that the rule will not have a
Significant Impact on a Substantial Number of Small Entities (SISNOSE). Pursuant to section
603 of the Regulatory Flexibility Act (RFA), the EPA undertook an Initial Regulatory Flexibility
Analysis (IRFA) that examined the impact of the BSCP proposed rule on small entities along
with regulatory alternatives that could reduce that impact. The EPA also convened a Small
Business Advisory Review panel to obtain advice and recommendations of representatives of the
small entities that potentially would be subject to the BSCP proposed rule’s requirements. All of
the panel’s recommendations have been addressed in the BSCP proposed rule.
The BSCP rule will allow the affected facilities up to 3 years from the effective date of
the rule to comply. Under CAA section 112(i), the Administrator or the applicable regulatory
authority also may grant 1 additional year if the owner or operator demonstrates that more time is
needed to install controls for a source. This additional time will ease capital availability problems
for plants in marginal economic condition that need to purchase and install new or upgraded
emission controls.
5(d)

Collection Schedule

Collection of data will begin after the effective date of the final BSCP manufacturing
NESHAP. The compliance date for existing sources is 3 years after the effective date. The
compliance date for new or reconstructed sources is the effective date if the source startup date is
before the effective date, or upon startup if the startup date is on or after the effective date. The
schedule for notifications and reports required by the rule is summarized below.
For facilities with existing affected kilns, the initial notification stating that the facility is
subject to the rule must be submitted no later than 120 days after the effective date of the rule.
Facilities with new or reconstructed affected kilns for which startup occurs on or after the
effective date must submit the initial notification no later than 120 days after the source becomes
subject to the rule (although we are projecting no new kilns in the short term). Facilities may

choose to submit a request for a routine control device maintenance exemption 30 days prior to
the compliance date. Facilities required to conduct a performance test must submit a notification
of intent to conduct a performance test at least 60 days before the performance test is scheduled
to begin. For each initial compliance demonstration that includes a performance test, facilities
must submit an initial notification of compliance status no later than 60 days following the
completion of the performance test. For each initial compliance demonstration that does not
involve a performance test, facilities must submit an initial notification within 30 days of
completing the initial compliance demonstration. Records necessary to determine compliance
with the emission limitations and work practice standards must be compiled on a daily basis and
compliance reports must be submitted to the Administrator on a semi-annual basis. Repeat
performance tests are to be conducted every 5 years to ensure ongoing compliance.
6.

Estimating the Burden and Cost of the Collection
6(a)

Estimating Respondent Burden

The annual burden estimates for reporting and recordkeeping activities for the first
3 years after the effective date of the rule are presented in Tables 1 through 3. These numbers
were derived from estimates based on Agency studies and background documents from the
development of the regulation, Agency knowledge and experience with part 63 and other
regulations, and the ICR for the 2003 BSCP rulemaking. In addition, comments and information
received from the BIA and BSCP companies on the 2003 rulemaking were incorporated into the
burden estimates.
6(b)

Estimating Respondent Costs
(i)

Estimating Labor Costs

The information collection activities for sources subject to the standards are presented in
Tables 1 through 3. Labor costs for reporting and recordkeeping activities were estimated based
on the most recently available labor rate data from the U.S. Bureau of Labor Statistics (BLS) for
NAICS code 327100—Clay Product and Refractory Manufacturing
(http://www.bls.gov/oes/2013/may/naics4_327100.htm). 1 Labor costs are divided into the
following three categories: (1) technical; (2) management; and (3) clerical. The labor rates,
including fringe benefits, reported by BLS for May 2013 (the most recent rates available) are
$25.32 per hour ($25.32/hr) for technical personnel, $42.17/hr for management personnel and
$15.19/hr for clerical personnel. The base labor rates were adjusted by an overhead rate of
110 percent. The final total labor rates are $53.17 for technical personnel, $88.56 for
management and $31.90 for clerical.
(ii)

Estimating Capital/Startup and O&M Costs

Capital/startup costs include the costs of conducting initial and repeat performance tests.
Operation and maintenance (O&M) costs include photocopy and postage costs associated with
reporting requirements and costs associated with VE monitoring. The O&M costs for VE
1

Occupational employment statistics in BLS are provided at a higher NAICS code level (327100), compared to the
NAICS code (327120) specified in Sections 4(a) and 5(c).

monitoring include training for VE testing for two people every 5 years, conducting the
15-minute VE test and preparing for/documenting the VE test. The monitoring equipment
needed to monitor parameters other than VE (e.g., lime or limestone feed rate) is included as part
of the control system and, therefore, adds no additional capital or O&M cost. The capital/startup
costs were estimated and annualized as described in Tables 1 through 3.
6(c)

Estimating Agency Burden and Cost

No costs can be attributed to the development of the information collection requirements
because the information collection requirements were developed as an incidental part of
standards development. Because reporting and recordkeeping requirements on the part of the
respondents are required under section 112 of the CAA, no operational costs will be incurred by
the federal government. Publication and distribution of the information are part of the AFS
program, with the result that no federal costs can be directly attributed to the ICR. Examination
of records to be maintained by the respondents will occur incidentally as part of the periodic
inspection of sources that is part of the EPA’s overall compliance and enforcement program.
Therefore, this examination is not attributable to the ICR. The only costs that the federal
government will incur are user costs associated with the analysis of the reported information, as
presented in Tables 5 through 7.
Labor rates for federal employees are based on the January 2012, Office of Personnel
Management labor rates for General Schedule employees
(http://www.opm.gov/oca/12tables/pdf/gs_h.pdf). The base labor rates are $32.73/hr for
technical personnel (GS-12, step 5), $54.10/hr for management personnel (GS-15, step 5) and
$18.45/hr for clerical personnel (GS-7, step 5). The base labor rates were multiplied by the
standard government benefits multiplication factor of 1.6. The resulting average hourly labor
costs are $52.37/hr for technical personnel, $86.56/hr for management and $29.52/hr for clerical.
6(d)

Estimating the Respondent Universe and Total Burden and Costs

Once the burden and costs per activity have been established on a per respondent basis,
the total burden and cost must be calculated for all respondents and for the Agency. To calculate
the total burden and costs, the number of respondents needed to complete each information
collection activity must be estimated. The total number of respondents is also referred to as the
“respondent universe.” Based on analyses of information collected from industry surveys,
operating permits and test reports, the EPA is projecting that 67 existing BSCP facilities will be
subject to the BSCP rule, assuming that 25 BSCP facilities will become synthetic area sources
rather than comply with the rule. Based on the latest BSCP industry profile, no new BSCP
facilities or kilns are expected to be constructed in the near future, and existing capacity is
assumed to be sufficient to cover any short-term increases in production.
6(e)

Bottom Line Burden Hours and Costs/Master Tables
(i)

Respondent Tally

The bottom line annual respondent burden hours and costs, presented in Tables 1 through
3 (one table for each year), are calculated by adding person-hours per year down each column for
technical, managerial and clerical staff and by adding down the cost column. Table 4 summarizes

the respondent burden hours and costs for each of the 3 years and presents the total and average
burden over the 3-year period. The total number of responses over the 3-year period is 134, with
an average of 45 responses per year. The estimated total burden for the 3-year period is 45,190
labor hours at a labor cost of $2,388,764. The average bottom line annual burden over the 3-year
period is 15,063 labor hours at a labor cost of $796,255. There are no capital/startup costs that
would be incurred during the 3 years following the effective date of the rule. The total annual
O&M cost for the 3-year period is estimated to be $2,948, with an average of $983 incurred each
year in the 3 years following the effective date.
(ii)

The Agency Tally

The bottom line Agency burden hours and costs, presented in Tables 5 through 7, are
calculated as in the respondent table, by adding person-hours per year down each column for
technical, managerial and clerical staff and by adding down the cost column. In this case, total
cost is the sum of this total salary cost and total travel expenses for tests attended. Table 8
summarizes the Agency burden hours and costs for each of the 3 years and presents the total and
average burden over the 3-year period. The total hours during the 3-year ICR review period are
308, with an average of 103 hours per year. The total cost over the 3-year period is $15,986. The
average annual cost incurred during each year is $5,329.
(iii)

Variations in the Annual Bottom Line

Respondent and Agency costs and labor hours vary from year to year because:
(1) existing facilities are not required to come into full compliance with the BSCP standards until
3 years after the effective date of the rule and (2) different one-time activities would be
conducted during the first years following the effective date. During the first year, existing
sources are required to submit an initial notification. There are no monitoring, reporting and
recordkeeping activities during the second year for existing sources. In the third year, existing
facilities are likely to be conducting one-time activities such as developing their OM&M plans,
developing a record system and training personnel on how to record information. Facilities may
also choose to submit a request for a routine control device maintenance exemption during the
third year.
Because existing facilities are not required to come into full compliance with the BSCP
standards until 3 years after the effective date, much of the respondent burden does not occur
until the fourth year following the effective date. Attachment 1 contains tables showing
respondent and Agency burden estimates for the fourth, fifth and sixth years following the
effective date. During the fourth year when existing facilities are required to come into full
compliance, the facilities would conduct inspections, submit a notification of intent to conduct a
performance test, conduct an initial performance test (and, if necessary, a repeat performance
test), submit a notification of compliance status, submit their test data to the EPA through EPA’s
electronic reporting tool (ERT), submit their first compliance report and keep records of
compliance data and malfunctions. During subsequent years, existing facilities would continue to
keep records and submit semi-annual reports. After the fourth year, burden estimates are not
expected to vary considerably from year to year because facilities will be conducting ongoing
activities (e.g., semi-annual compliance reports, recordkeeping, inspecting every 3 years,

retesting every 5 years) as opposed to the one-time activities (e.g., developing OM&M plan,
submitting notifications) that occur in the first 4 years following the effective date.
6(f)

Reasons for Change in Burden

This section does not apply because this is a new collection.
6(g)

Burden Statement

The average annual public reporting and recordkeeping burden for this collection of
information is estimated to average 337 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 currently valid OMB control number. The OMB
control numbers for the EPA’s regulations are listed in 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, the EPA has established a public docket for this ICR
under Docket ID Number EPA-HQ-OAR-2013-0291. 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
content of the docket and to access those documents in the public docket that are available
electronically. When in the system, select “search” than key in the docket ID number identified
in this document. The documents are also available for public viewing at the EPA Docket
Center, Room 3334, EPA WJC West Building, 1301 Constitution Avenue, 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) 566-1742. Send comments to
the Office of Information and Regulatory Affairs, Office of Management and Budget, Attention:
Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503. Please include the EPA
Docket ID Number EPA-HQ-OAR-2013-0291 in any correspondence.
Part B of the Supporting Statement
This part is not applicable because statistical methods are not used in data collection
associated with the rule.

Table 1. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP - Year 1
(A)
Burden item

1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Read and understand rule requirements
B. Required activities
Develop OM&M plan c,d
Conduct APCD maintenance/inspections
Conduct periodic kiln
maintenance/inspections
Conduct burner inspection and tune-up
C. Create information
D. Gather existing information
E. Write report
Initial notification of applicability d
Notification of constr./reconstr. d
Notification of anticipated startup d
Notification of actual startup d
Request APCD maintenance exemption d
Notification of performance test
Notification of compliance status e
Report of performance test (through
ERT)
First compliance report
Semi-annual compliance reports
Deviations f
No deviations f

(B)
No. of
occurrences per
respondent per
year

134

6.7

$8,146

100
20
20

1
1
1

100
20
20

0
0
0

$0
$0
$0

20
See 3B
See 3B

2
2
2
2
2
2
16
4

1
1
1
1
1
1
1
1

2
2
2
2
2
2
16
4

67
0
0
0
0
0
0
0

134
0
0
0
0
0
0
0

6.7
0
0
0
0
0
0
0

13
0
0
0
0
0
0
0

$8,146
$0
$0
$0
$0
$0
$0
$0

20
8

2
2

40
16

0
0

$0
$0

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

N/A
N/A

(A)
Burden item

4. Recordkeeping Requirements
A. Read instructions
B. Plan activities
Prepare for initial performance test c
Prepare for repeat performance test c
C. Implement activities
Attend initial performance test c,g
Attend repeat performance test c,g
D. Develop record system
E. Time to enter information
Records of compliance data c
Records of APCD
maintenance/inspections
Records of compliance with work
practices
Records of malfunctions
F. Time to train personnel c,h
G. Time to transmit/disclose information i
TOTAL ANNUAL BURDEN AND COST
(SALARY)
TOTAL ANNUAL NUMBER OF
RESPONSES j
CAPITAL COSTS:
Initial performance tests k
Repeat performance tests l
Total capital cost
ANNUALIZED CAPITAL COSTS: m
Initial performance tests
Repeat performance tests

(B)
No. of
occurrences per
respondent per
year

24
24

1
1

24
24

0
0

$0
$0

24
24
40

2.5
2.5
6

60
60
240

0
0
0

$0
$0
$0

6
See 3B

312

12
6
1

24
240
0.25

0
0
67

0
0
17
285

0
0
0.8
14

0
0
1.7
28

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

See 3A

See 3B
2
40
0.25

$0
$0
$1,018
$17,310

$0
$0
$0
$0
$0

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

Total annualized capital cost
ANNUAL O&M COSTS n
Photocopy/postage
Visible emissions tests
Total O&M cost
TOTAL ANNUALIZED COSTS
(Annualized capital + O&M costs)

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b
$0
$1,474
$0
$1,474
$1,474

A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are
anticipated to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production.
b
Costs are based on the following hourly rates: technical at $53.17, management at $88.56 and clerical at $31.90. Management person-hours and clerical person-hours
are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
c
Person-hours per occurrence and number of occurrences per year were derived based on comments from BIA.
d
One-time only activities.
e
The notification of compliance status includes the performance test report. The cost burden associated with developing the performance test report is included in the
performance test capital cost at the bottom of the table.
f
Assumes 15% of respondents have deviations to report in semiannual compliance reports and 85% report no deviations.
g
Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from BIA, an average of 2.5 plant personnel attend performance tests.
Assume no travel for plant personnel. Assume testing takes 2, 12-hour days per plant. Repeat testing is also required 5 years following initial testing.
h
Based on comments from BIA, assumes 40 hours of training for 6 plant personnel.
i
Time associated with transmitting reports. Equal to the number of respondents submitting reports.
j
The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E.
k
Assumes EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl and Cl 2 .
l
Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it.
m
Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t =
equipment life (years). Performance testing costs annualized assuming a 5 year life and 7 percent interest.
n
O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g.,
limestone or lime feed rate) is included as part of the control system and therefore adds no additional capital or O&M cost. The O&M cost associated with VE
monitoring includes VE training for two people every 5 years, conducting the 15-minute VE test and preparing for/documenting the VE test (occurs after 3-year ICR
clearance period).
N/A = Not Applicable.

Table 2. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP - Year 2
(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

100
20
20

1
1
1

100
20
20

0
0
0

$0
$0
$0

20
See 3B
See 3B

2
2
2
2
2
2
16
4

1
1
1
1
1
1
1
1

2
2
2
2
2
2
16
4

0
0
0
0
0
0
0
0

$0
$0
$0
$0
$0
$0
$0
$0

20
8

2
2

40
16

0
0

$0
$0

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

N/A
N/A

(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

24
24

1
1

24
24

0
0

$0
$0

24
24
40

2.5
2.5
6

60
60
240

0
0
0

$0
$0
$0

6
See 3B

312

12
6
1

24
240
0.25

0
0
0

0
0
0
0

$0
$0
$0
$0

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

See 3A

See 3B
2
40
0.25

$0
$0
$0
$0
$0

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

Total annualized capital cost
ANNUAL O&M COSTS n
Photocopy/postage
Visible emissions tests
Total O&M cost
TOTAL ANNUALIZED COSTS
(Annualized capital + O&M costs)

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b
$0
$0
$0
$0
$0

Table 3. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP - Year 3
(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

100
20
20

1
1
1

100
20
20

67
0
0

6,700
0
0

335
0
0

670
0
0

20
See 3B
See 3B

2
2
2
2
2
2
16
4

1
1
1
1
1
1
1
1

2
2
2
2
2
2
16
4

0
0
0
0
67
0
0
0

0
0
0
0
134
0
0
0

0
0
0
0
6.7
0
0
0

0
0
0
0
13
0
0
0

$0
$0
$0
$0
$8,146
$0
$0
$0

20
8

2
2

40
16

0
0

$0
$0

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

N/A
N/A

$0
$407,291
$0
$0

(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

24
24

1
1

24
24

0
0

24
24
40

2.5
2.5
6

60
60
240

0
0
67

0
0
16,080

0
0
804

0
0
1,608

6
See 3B

312

12
6
1

24
240
0.25

0
67
67

0
16,080
17
39,011

0
804
0.8
1,951

0
1,608
1.7
3,901

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

See 3A
$0
$0
$0
$0
$977,499
$0

See 3B
2
40
0.25

$0
$977,499
$1,018
$2,371,454

$0
$0
$0
$0
$0

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

Total annualized capital cost
ANNUAL O&M COSTS n
Photocopy/postage
Visible emissions tests
Total O&M cost
TOTAL ANNUALIZED COSTS
(Annualized capital + O&M costs)

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b
$0
$1,474
$0
$1,474
$1,474

Table 4. Summary of Respondent Burden and Cost of the BSCP NESHAP - Years 1 to 3

Year
Year 1
Year 2
Year 3
Totals
Average

No.
responses
67
0
67
134
45

Technical
hours
285
0
39,011
39,296

Management
hours
14
0
1,951
1,965

Clerical
Hours
28
0
3,901
3,930

Total hours
327
0
44,862
45,190
15,063

Labor costs
$17,310
$0
$2,371,454
$2,388,764
$796,255

Capital
$0
$0
$0
$0
$0

Non-Labor Costs
Annualized
Annual
capital
O&M
$0
$1,474
$0
$0
$0
$1,474
$0
$2,948
$0
$983

Total annualized
cost
$1,474
$0
$1,474
$2,948
$983

Table 5. Annual Burden and Cost to the Federal Government of the BSCP NESHAP - Year 1

Activity

1. Attend initial performance test c
2. Attend repeat performance test c,d
Retesting preparation
Retesting
3. Litigation e
4. Excess emissions enforcement activities f
5. Report review
Initial notification of applicability
Notification of constr./reconstr.
Notification of anticipated startup
Notification of actual startup
Request for APCD maintenance exemption
Notification of performance test
Notification of compliance status g
Repeat performance test report d
First compliance report
Semi-annual compliance reports:
Deviations h
No deviations h
TOTAL BURDEN AND COST (SALARY)
Travel Expenses for Tests Attended i
TOTAL ANNUAL COST (SALARY +
EXPENSES)

(A)
EPA
personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

Plants
per year a

(E)
Technical
personhours per
year
(E=CxD)
0

Management
person-hours
per year
(E×0.05)
0

(G)
Clerical
personhours per
year
(E×0.1)
0

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0
0
0
0

$0
$0
$0
$0

2
2
2
2
2
2
60
40
4

1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
40
4

67
0
0
0
0
0
0
0
0

134
0
0
0
0
0
0
0
0

6.7
0
0
0
0
0
0
0
0

13
0
0
0
0
0
0
0
0

$7,993
$0
$0
$0
$0
$0
$0
$0
$0

8
2

2
2

16
4

0
0

0
0
134

0
0
6.7

0
0
13

$0
$0
$7,993
$0
$7,993

(D)

(F)

(H)

Cost,$ b
$0

Assumes Agency personnel will attend performance tests at 10% of plants.
Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests.
e
Assumes 1% of plants will be involved in litigation.
f
Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests.
g
Notification of compliance status includes the performance test report.
h
Assumes 15% of the plants report deviations semiannually and 85% report no deviations.
i
Assumes Agency personnel (1 person) will spend 2 days per plant plus time for travel, at $50 per diem per day, and $400 transportation expense per round trip to attend
performance tests.
N/A = Not applicable.
d

Table 6. Annual Burden and Cost to the Federal Government of the BSCP NESHAP - Year 2

Activity

(A)
EPA
personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

Plants
per year a

(E)
Technical
personhours per
year
(E=CxD)
0

Management
person-hours
per year
(E×0.05)
0

(G)
Clerical
personhours per
year
(E×0.1)
0

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0
0
0
0

$0
$0
$0
$0

2
2
2
2
2
2
60
40
4

1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
40
4

0
0
0
0
0
0
0
0
0

$0
$0
$0
$0
$0
$0
$0
$0
$0

8
2

2
2

16
4

0
0

0
0
0

$0
$0
$0
$0
$0

(D)

(F)

(H)

Cost,$ b
$0

Table 7. Annual Burden and Cost to the Federal Government of the BSCP NESHAP - Year 3

Activity

(A)
EPA
personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

Plants
per year a

(E)
Technical
personhours per
year
(E=CxD)
0

Management
person-hours
per year
(E×0.05)
0

(G)
Clerical
personhours per
year
(E×0.1)
0

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0
0
0
0

$0
$0
$0
$0

2
2
2
2
2
2
60
40
4

1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
40
4

0
0
0
0
67
0
0
0
0

0
0
0
0
134
0
0
0
0

0
0
0
0
6.7
0
0
0
0

0
0
0
0
13
0
0
0
0

$0
$0
$0
$0
$7,993
$0
$0
$0
$0

8
2

2
2

16
4

0
0

0
0
134

0
0
6.7

0
0
13

$0
$0
$7,993
$0
$7,993

(D)

(F)

(H)

Cost,$ b
$0

Table 8. Summary of Burden and Cost to the Federal Government of the BSCP NESHAP - Years 1 to 3
Year
Year 1
Year 2
Year 3
Totals
Average

Technical hours
134
0
134
268

Management hours
6.7
0
6.7
13

Clerical Hours
13
0
13
27

Total hours
154
0
154
308
103

Labor costs
$7,993
$0
$7,993
$15,986
$5,329

Attachment 1
Annual Burden and Cost – Years 4 to 6

1-1

Table 1-1. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP - Year 4
(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

100
20
20

1
1
1

100
20
20

0
67
67

0
1,340
1,340

0
67
67

0
134
134

$0
$81,458
$81,458

20
See 3B
See 3B

1,340

134

$81,458

2
2
2
2
2
2
16
4

1
1
1
1
1
1
1
1

2
2
2
2
2
2
16
4

0
0
0
0
0
67
67
67

0
0
0
0
0
134
1,072
268

0
0
0
0
0
6.7
54
13

0
0
0
0
0
13
107
27

$0
$0
$0
$0
$0
$8,146
$65,167
$16,292

1,072

107

$65,167

20
8

2
2

40
16

0
0

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

N/A
N/A

1-2

$0
$0

(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

24
24

1
1

24
24

67
6.7

1,608
161

80
8.0

161
16

$97,750
$9,775

24
24
40

2.5
2.5
6

60
60
240

67
6.7
0

4,020
402
0

201
20
0

402
40
0

$244,375
$24,437
$0

6
See 3B

312

20,904

1,045

2,090

$1,270,749

12
6
1

24
240
0.25

67
0
67

1,608
0
17
35,286

80
0
0.8
1,764

161
0
1.7
3,529

$97,750
$0
$1,018
$2,145,000

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

See 3A

See 3B
2
40
0.25

268

$977,420
$97,742
$1,075,162
$238,290
$23,829

1-3

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

Total annualized capital cost
ANNUAL O&M COSTS n
Photocopy/postage
Visible emissions tests
Total O&M cost
TOTAL ANNUALIZED COSTS
(Annualized capital + O&M costs)

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b
$262,119
$5,896
$346,144
$352,040
$614,159

1-4

Table 1-2. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP - Year 5
(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

100
20
20

1
1
1

100
20
20

0
0
0

$0
$0
$0

20
See 3B
See 3B

2
2
2
2
2
2
16
4

1
1
1
1
1
1
1
1

2
2
2
2
2
2
16
4

0
0
0
0
0
0
0
0

$0
$0
$0
$0
$0
$0
$0
$0

20
8

2
2

40
16

10
57

402
911

20
46

40
91

$24,437
$55,392

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

N/A
N/A

1-5

(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

24
24

1
1

24
24

0
0

$0
$0

24
24
40

2.5
2.5
6

60
60
240

0
0
0

$0
$0
$0

6
See 3B

312

20,904

1,045

2,090

$1,270,749

12
6
1

24
240
0.25

67
0
67

1,608
0
17
23,842

80
0
0.8
1,192

161
0
1.7
2,384

$97,750
$0
$1,018
$1,449,346

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

See 3A

See 3B
2
40
0.25

134

$0
$0
$0
$238,290
$23,829

1-6

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

Total annualized capital cost
ANNUAL O&M COSTS n
Photocopy/postage
Visible emissions tests
Total O&M cost
TOTAL ANNUALIZED COSTS
(Annualized capital + O&M costs)

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b
$262,119
$2,948
$346,144
$349,092
$611,211

1-7

Table 1-3. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP - Year 6
(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

100
20
20

1
1
1

100
20
20

0
0
0

$0
$0
$0

20
See 3B
See 3B

2
2
2
2
2
2
16
4

1
1
1
1
1
1
1
1

2
2
2
2
2
2
16
4

0
0
0
0
0
0
0
0

$0
$0
$0
$0
$0
$0
$0
$0

20
8

2
2

40
16

10
57

402
911

20
46

40
91

$24,437
$55,392

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

N/A
N/A

1-8

(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

24
24

1
1

24
24

0
0

$0
$0

24
24
40

2.5
2.5
6

60
60
240

0
0
0

$0
$0
$0

6
See 3B

312

20,904

1,045

2,090

$1,270,749

12
6
1

24
240
0.25

67
0
67

1,608
0
17
23,842

80
0
0.8
1,192

161
0
1.7
2,384

$97,750
$0
$1,018
$1,449,346

Personhours per
occurrence

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b

See 3A

See 3B
2
40
0.25

134

$0
$0
$0
$238,290
$23,829

1-9

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

Total annualized capital cost
ANNUAL O&M COSTS n
Photocopy/postage
Visible emissions tests
Total O&M cost
TOTAL ANNUALIZED COSTS
(Annualized capital + O&M costs)

(D)

Respondents
per year a

(E)

(F)

Technical
Management
person- hours person-hours
per year
per year
(E=C×D)
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

(H)

Cost,$ b
$262,119
$2,948
$346,144
$349,092
$611,211

1-10

Table 1-4. Summary of Respondent Burden and Cost of the BSCP NESHAP - Years 4 to 6

Year
Year 4
Year 5
Year 6
Totals
Average

No.
responses
268
134
134
536
179

Technical
hours
35,286
23,842
23,842
82,969

Management
hours
1,764
1,192
1,192
4,148

Clerical
Hours
3,529
2,384
2,384
8,297

Total hours
40,578
27,418
27,418
95,415
31,805

1-11

Labor costs
$2,145,000
$1,449,346
$1,449,346
$5,043,692
$1,681,231

Capital
$1,075,162
$0
$0
$1,075,162
$358,387

Non-Labor Costs
Annualized
Annual
capital
O&M
$262,119
$352,040
$262,119
$349,092
$262,119
$349,092
$786,357
$1,050,224
$262,119
$350,075

Total annualized
cost
$614,159
$611,211
$611,211
$1,836,581
$612,194

Table 1-5. Annual Burden and Cost to the Federal Government of the BSCP NESHAP - Year 4

Activity

(A)
EPA
personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

Plants
per year a

6.7

(E)
Technical
personhours per
year
(E=CxD)
161

Management
person-hours
per year
(E×0.05)
8.0

(G)
Clerical
personhours per
year
(E×0.1)
16

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0.7
0.7
0.7
3.4

5
16
1,394
161

0.3
0.8
70
8

0.5
1.6
139
16

$320
$959
$83,125
$9,591

2
2
2
2
2
2
60
40
4

1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
40
4

0
0
0
0
0
67
67
6.7
67

0
0
0
0
0
134
4,020
268
268

0
0
0
0
0
6.7
201
13
13

0
0
0
0
0
13
402
27
27

$0
$0
$0
$0
$0
$7,993
$239,785
$15,986
$15,986

8
2

2
2

16
4

0
0

0
0
6,427

0
0
321

0
0
643

$0
$0
$383,336
$5,360
$388,696

(D)

(F)

(H)

Cost,$ b
$9,591

1-12

1-13

Table 1-6. Annual Burden and Cost to the Federal Government of the BSCP NESHAP - Year 5

Activity

(A)
EPA
personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

Plants
per year a

(E)
Technical
personhours per
year
(E=CxD)
0

Management
person-hours
per year
(E×0.05)
0

(G)
Clerical
personhours per
year
(E×0.1)
0

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0
0
0.7
3.4

0
0
1,394
161

0
0
70
8.0

0
0
139
16

2
2
2
2
2
2
60
40
4

1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
40
4

0
0
0
0
0
0
0
0
0

8
2

2
2

16
4

10
57

161
228
1,943

8.0
11
97

16
23
194

(D)

(F)

(H)

Cost,$ b
$0
$0
$0
$83,125
$9,591
$0
$0
$0
$0
$0
$0
$0
$0
$0
$9,591
$13,588
$115,896
$1,675
$117,571

1-14

1-15

Table 1-7. Annual Burden and Cost to the Federal Government of the BSCP NESHAP - Year 6

Activity

(A)
EPA
personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

Plants
per year a

(E)
Technical
personhours per
year
(E=CxD)
0

Management
person-hours
per year
(E×0.05)
0

(G)
Clerical
personhours per
year
(E×0.1)
0

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0
0
0.7
3.4

0
0
1,394
161

0
0
70
8.0

0
0
139
16

2
2
2
2
2
2
60
40
4

1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
40
4

0
0
0
0
0
0
0
0
0

8
2

2
2

16
4

10
57

161
228
1,943

8.0
11
97

16
23
194

(D)

(F)

(H)

Cost,$ b
$0
$0
$0
$83,125
$9,591
$0
$0
$0
$0
$0
$0
$0
$0
$0
$9,591
$13,588
$115,896
$1,675
$117,571

1-16

1-17

Table 1-8. Summary of Burden and Cost to the Federal Government of the BSCP NESHAP - Years 4 to 6
Year
Year 4
Year 5
Year 6
Totals
Average

Technical hours
6,427
1,943
1,943
10,313

Management hours
321
97
97
516

Clerical Hours
643
194
194
1,031

1-18

Total hours
7,391
2,234
2,234
11,860
3,953

Labor costs
$388,696
$117,571
$117,571
$623,838
$207,946

File Type	application/pdf
Author	EPA
File Modified	2019-11-22
File Created	2014-11-14