2510ss01

2510ss01.pdf

NESHAP for Clay Ceramics Manufacturing (40 CFR part 63, subpart KKKKK) (Proposed Rule)

OMB: 2030-0048

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2020-12-17 - 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 Clay Ceramics
Manufacturing
(40 CFR Part 63, Subpart KKKKK)
October 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 Clay Ceramics
Manufacturing (40 CFR Part 63, Subpart KKKKK).” This is a new information collection
request (ICR). The EPA ICR tracking number is 2510.01.
1(b)

Short Characterization

Potential respondents are owners or operators of new and existing sources at clay ceramic
manufacturing facilities. A clay ceramics facility manufactures pressed floor tile, pressed wall
tile, or sanitaryware (e.g., sinks and toilets). Clay ceramics facilities typically form, dry and fire
tile or sanitaryware products that are composed of clay, shale and various additives. Spray dryers
are used during the forming process at tile facilities to process the ceramic mix into a powder to
allow tile pressing. Dryers are used to reduce the moisture content of the ceramic products prior
to firing. Glazes are applied to some tile and sanitaryware products, with glaze spraying
accounting for all glazing emissions. Kilns are used to fire the ceramic products and include
ceramic tile roller kilns and sanitaryware tunnel and shuttle kilns. The rule applies to all existing,
new and reconstructed affected sources, which include the kilns, glaze spray operations, ceramic
tile spray dryers and floor tile press dryers. (Wall tile press dryers and sanitaryware ware dryers,
with no measurable emissions, are not covered.)
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 three
clay ceramics facilities that are currently major sources of HAP. No new clay ceramics facilities
or affected sources 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 KKKKK requires respondents to monitor the type of fuel used and maintain
records. Respondents also must monitor control device operating parameters to assure
continuous compliance with the rule. The rule includes the following parameter monitoring
requirements:
•

Tunnel or roller kilns:
• Dry injection fabric filter (DIFF)/dry lime scrubber/fabric filter (DLS): Lime injection
rate and either periodic visible emissions (VE) determinations or bag leak detectors
• Wet scrubbers: Pressure drop, scrubber liquid pH, scrubber liquid flow rate and
chemical addition rate (if applicable)
• Activated carbon injection: Carbon flow rate
• No control device: Periodic VE determinations and kiln process rate monitoring (if
their last calculated total facility maximum potential hydrogen chloride-equivalent
emissions were above the proposed acid gas health-based emission limit)

•

Glaze spray operations:
• Fabric filters: Either periodic VE determinations or bag leak detectors
• Wet scrubbers: Pressure drop and scrubber liquid flow rate
• Water curtains: Daily inspections to verify the presence of water flow to the wet
control system; weekly visual inspections of the system ductwork and control
equipment for leaks and annual inspections of the interior of the control equipment (if
applicable) to determine the structural integrity and condition of the control
equipment
• Baffles: Annual visual inspection of the baffles to confirm the baffles are in place

•

Spray dryers/floor tile press dryers: Operating temperature

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 clay ceramics manufacturing facilities include
hydrogen fluoride (HF), hydrogen chloride (HCl) and metals (antimony, arsenic, beryllium,
cadmium, chromium, cobalt, mercury, manganese, nickel, lead and selenium). In the
Administrator’s judgment, the pollutants emitted from clay ceramics 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 KKKKK on May 16, 2003. (Note: The clay ceramics 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 clay ceramics
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 clay ceramics 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.

Nonduplication, Consultations and Other Collection Criteria
3(a)

Nonduplication

The information required by the clay ceramics 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

Representatives of an industry trade association (Tile Council of North America) and
companies in the ceramic tile and sanitaryware industry were consulted during the development
of the 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, testing approach, emissions data, MACT floor approach, confidentiality concerns,
source category delisting and alternative standards. No specific information was provided to the
representatives with respect to burden estimates. 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).
The EPA is providing a 60-day public comment period following proposal of the clay
ceramics 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 clay ceramics 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 clay ceramics manufacturing facilities that are major sources of HAP emissions. The North
American Industry Classification System (NAICS) codes for respondents affected by the
standards are 327110—Pottery, Ceramics, and Plumbing Fixture Manufacturing—and
327120—Clay Building Material and Refractories Manufacturing. Not all processes classified in
these NAICS codes 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
Clay Ceramics Manufacturing (40 CFR part 63, subpart KKKKK). 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
63.8630(a)-(c)

Notification of performance test

63.7(b)-(c), 63.9(e) and
63.8630(d)

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

63.9(h), 63.10(d)(2) and
63.8630(e)

Request for routine control device maintenance exemption

63.8630(f)

Notification of alternative fuel use

63.8630(g)

Records
Record retention

63.10(b)(1) and 63.8645

Documentation supporting initial notifications and notifications
of compliance status

63.10(b)(2)(xiv) and
63.8640(a)(1)

Records of performance tests

63.10(b)(2)(viii) and
63.8640(a)(2)

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

63.8640(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 63.8640(b)-(c)

Records of fuel type used

63.8640(b)

OM&M plan

63.8640(c)(6)

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

63.8635(b)-(f)
63.8635(b)-(f)
63.8635(c)(5)-(6)
63.8635(d)-(e)

Report of alternative fuel use

63.8635(g)

Electronic submittal of performance test results (using ERT)

63.8635(h)

(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).

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

None of the major source plants in the clay ceramics industry are owned by small
businesses based on the definition used by the Small Business Administration for this industry
(750 or fewer company employees for NAICS codes 327110 and 327120). Regardless, the EPA
does not expect that any facilities in the clay ceramics industry will experience adverse impacts
due to the cost of the reporting and recordkeeping requirements of the rule.
5(d)

Collection Schedule

Collection of data will begin after the effective date of the final clay ceramics
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 sources, 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 sources 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 affected sources 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 clay ceramics rulemaking, In addition, comments and
information received from the Brick Industry Association (BIA) and brick and structural clay
products (BSCP) facilities on the 2003 BSCP rulemaking were incorporated into the burden
estimates for clay ceramics, given the similarity of the manufacturing processes and proposed
regulatory requirements.
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
1

Occupational employment statistics in BLS are provided at a higher NAICS code level (327100), compared to the
NAICS codes (327110 and 327120) specified in Sections 4(a) and 5(c).

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
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 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.” The EPA has identified three major source facilities that will be subject
to the clay ceramics rule. No new clay ceramics facilities or affected sources 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 6, with an average of 2.0 responses per year. The estimated total burden for the 3-year period
is 2,023 labor hours at a labor cost of $106,960. The average bottom line annual burden over the
3-year period is 674 labor hours at a labor cost of $35,653. 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 $132, with an average of $44 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
14, with an average of 4.6 hours per year. The total cost over the 3-year period is $716. The
average annual cost incurred during each year is $239.
(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 clay ceramics
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 clay
ceramics 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 notifications of compliance status and alternative fuel use, submit their test data to
the EPA through the EPA’s electronic reporting tool (ERT), submit their first compliance report
and keep records of compliance data, alternative fuel use 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-2013-0290. 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-2013-0290 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 Clay Ceramics 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 shuttle kiln
maintenance/inspections
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)
Notification of alternative fuel use f
First compliance report
Semi-annual compliance reports
Deviations g

(B)
No. of
occurrences per
respondent per
year

(E)
Technical
personhours per
year
(E=C×D)

Management
person-hours
per year
(E×0.05)

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

6.0

0.3

0.6

100
20
20

1
1
1

100
20
20

0
0
0

2
2
2
2
2
2
16
4

1
1
1
1
1
1
1
1

2
2
2
2
2
2
16
4

3
0
0
0
0
0
0
0

6.0
0
0
0
0
0
0
0

0.3
0
0
0
0
0
0
0

0.6
0
0
0
0
0
0
0

2
16

1
1

2
16

0
0

$0
$0

Personhours per
occurrence

(D)

Respondents
per year a

(F)

(H)

Cost,$ b

N/A
N/A
$365
$0
$0
$0

See 3B
See 3B

$365
$0
$0
$0
$0
$0
$0
$0

(A)
Burden item

No deviations g
Report of alternative fuel use f
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,h
Attend repeat performance test c,h
D. Develop record system
E. Time to enter information
Records of compliance data c
Records of alternative fuel use
Records of APCD
maintenance/inspections
Records of compliance with work
practices
Records of malfunctions
F. Time to train personnel c,i
G. Time to transmit/disclose information j
TOTAL ANNUAL BURDEN AND COST
(SALARY)
TOTAL ANNUAL NUMBER OF
RESPONSES k

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

8
4

2
2

(D)

0
0

(E)
Technical
personhours per
year
(E=C×D)
0
0

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

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

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
1
See 3B

52
12

312
12

0
0

$0
$0

12
6
1

24
240
0.25

0
0
3

0
0
0.8
13

0
0
0.04
0.6

0
0
0.08
1.3

Respondents
per year a

(F)

(H)

Cost,$ b
$0
$0

See 3A

See 3B
2
40
0.25

$0
$0
$46
$775

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

CAPITAL COSTS:
Initial performance tests l
Repeat performance tests m
Total capital cost
ANNUALIZED CAPITAL COSTS: n
Initial performance tests
Repeat performance tests
Total annualized capital cost
ANNUAL O&M COSTS o
Photocopy/postage
Visible emissions tests
Total O&M cost
TOTAL ANNUALIZED COSTS
(Annualized capital + O&M costs)

(D)

Respondents
per year a

(E)
Technical
personhours per
year
(E=C×D)

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

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

(H)

Cost,$ b

$0
$0
$0
$0
$0
$0
$66
$0
$66
$66

A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. 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 10% of facilities will use an alternative fuel once per year.
g
Assumes 15% of respondents have deviations to report in semiannual compliance reports and 85% report no deviations.
h
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.
i
Based on comments from BIA, assumes 40 hours of training for 6 plant personnel.
j
Time associated with transmitting reports. Equal to the number of respondents submitting reports.

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.
Assumes EPA Method 5 for PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl and EPA Method 23 for dioxins/furans.
m
Assumes 10% of plants will fail an initial performance test and must repeat it.
n
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.
o
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.
l

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

(B)
No. of
occurrences per
respondent per
year

(E)
Technical
personhours per
year
(E=C×D)

Management
person-hours
per year
(E×0.05)

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

100
20
20

1
1
1

100
20
20

0
0
0

$0
$0
$0

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

2
16

1
1

2
16

0
0

$0
$0

Personhours per
occurrence

(D)

Respondents
per year a

(F)

(H)

Cost,$ b

N/A
N/A

See 3B
See 3B

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

8
4

2
2

(D)

0
0

(E)
Technical
personhours per
year
(E=C×D)
0
0

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

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

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
1
See 3B

52
12

312
12

0
0

$0
$0

12
6
1

24
240
0.25

0
0
0

0
0
0
0

$0
$0
$0
$0

Respondents
per year a

(F)

(H)

Cost,$ b
$0
$0

See 3A

See 3B
2
40
0.25

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

(D)

Respondents
per year a

(E)
Technical
personhours per
year
(E=C×D)

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

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

(H)

Cost,$ b

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

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

(B)
No. of
occurrences per
respondent per
year

(E)
Technical
personhours per
year
(E=C×D)

Management
person-hours
per year
(E×0.05)

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

100
20
20

1
1
1

100
20
20

3
0
0

300
0
0

15
0
0

30
0
0

$18,237
$0
$0

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
3
0
0
0

0
0
0
0
6.0
0
0
0

0
0
0
0
0.3
0
0
0

0
0
0
0
0.6
0
0
0

$0
$0
$0
$0
$365
$0
$0
$0

2
16

1
1

2
16

0
0

$0
$0

Personhours per
occurrence

(D)

Respondents
per year a

(F)

(H)

Cost,$ b

N/A
N/A

See 3B
See 3B

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

8
4

2
2

(D)

0
0

(E)
Technical
personhours per
year
(E=C×D)
0
0

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

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

24
24

1
1

24
24

0
0

$0
$0

24
24
40

2.5
2.5
6

60
60
240

0
0
3

0
0
720

0
0
36

0
0
72

$0
$0
$43,769

6
1
See 3B

52
12

312
12

0
0

$0
$0

12
6
1

24
240
0.25

0
3
3

0
720
0.8
1,747

0
36
0.04
87

0
72
0.08
175

Respondents
per year a

(F)

(H)

Cost,$ b
$0
$0

See 3A

See 3B
2
40
0.25

$0
$43,769
$46
$106,184

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

(D)

Respondents
per year a

(E)
Technical
personhours per
year
(E=C×D)

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

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

(H)

Cost,$ b

$0
$0
$0
$0
$0
$0
$66
$0
$66
$66

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

Year
Year 1
Year 2
Year 3
Totals
Average

No.
responses
3
0
3
6
2.0

Technical
hours
13
0
1,747
1,760

Management
hours
0.6
0
87
88

Clerical
Hours
1.3
0
175
176

Total hours
15
0
2,009
2,023
674

Labor costs
$775
$0
$106,184
$106,960
$35,653

Capital
$0
$0
$0
$0
$0

Non-Labor Costs
Annualized
Annual
capital
O&M
$0
$66
$0
$0
$0
$66
$0
$132
$0
$44

Total annualized
cost
$66
$0
$66
$132
$44

Table 5. Annual Burden and Cost to the Federal Government of the Clay Ceramics 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
Notification of alternative fuel use
Repeat performance test report d
First compliance report
Semi-annual compliance reports:
Deviations h
No deviations h
Report of alternative fuel use i
TOTAL BURDEN AND COST (SALARY)
Travel Expenses for Tests Attended j
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

2
2
2
2
2
2
60
2
40
4

1
1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
2
40
4

3
0
0
0
0
0
0
0
0
0

6.0
0
0
0
0
0
0
0
0
0

0.3
0
0
0
0
0
0
0
0
0

0.6
0
0
0
0
0
0
0
0
0

$358
$0
$0
$0
$0
$0
$0
$0
$0
$0

8
2
1

2
2
1

16
4
1

0
0
0

0
0
0
6.0

0
0
0
0.3

0
0
0
0.6

$0
$0
$0
$358
$0
$358

(D)

(F)

(H)

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

A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. 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 $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours
are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
c
Assumes Agency personnel will attend performance tests at 10% of plants.
d
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 10% of facilities will use an alternative fuel once per year.
j
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.

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
2
40
4

1
1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
2
40
4

0
0
0
0
0
0
0
0
0
0

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

8
2
1

2
2
1

16
4
1

0
0
0

0
0
0
0

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

(D)

(F)

(H)

Cost,$ b
$0

A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. 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 $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours
are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
c
Assumes Agency personnel will attend performance tests at 10% of plants.
d
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 10% of facilities will use an alternative fuel once per year.
j
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.

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

2
2
2
2
2
2
60
2
40
4

1
1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
2
40
4

0
0
0
0
3
0
0
0
0
0

0
0
0
0
6.0
0
0
0
0
0

0
0
0
0
0.3
0
0
0
0
0

0
0
0
0
0.6
0
0
0
0
0

$0
$0
$0
$0
$358
$0
$0
$0
$0
$0

8
2
1

2
2
1

16
4
1

0
0
0

0
0
0
6.0

0
0
0
0.3

0
0
0
0.6

$0
$0
$0
$358
$0
$358

(D)

(F)

(H)

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

A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. 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 $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours
are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
c
Assumes Agency personnel will attend performance tests at 10% of plants.
d
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 10% of facilities will use an alternative fuel once per year.
j
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.

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

Technical hours
6.0
0
6.0
12

Management hours
0.3
0
0.3
0.6

Clerical Hours
0.6
0
0.6
1.2

Total hours
6.9
0
6.9
14
4.6

Labor costs
$358
$0
$358
$716
$239

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 Clay Ceramics NESHAP - Year 4
(A)
Burden item

(B)
No. of
occurrences per
respondent per
year

(E)
Technical
personhours per
year
(E=C×D)

Management
person-hours
per year
(E×0.05)

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

100
20
20

1
1
1

100
20
20

0
3
3

0
60
60

0
3.0
3.0

0
6.0
6.0

$0
$3,647
$3,647

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
3
3
3

0
0
0
0
0
6.0
48
12

0
0
0
0
0
0.3
2.4
0.6

0
0
0
0
0
0.6
4.8
1.2

$0
$0
$0
$0
$0
$365
$2,918
$729

2
16

1
1

2
16

3
3

6.0
48

0.3
2.4

0.6
4.8

$365
$2,918

Personhours per
occurrence

(D)

Respondents
per year a

(F)

(H)

Cost,$ b

N/A
N/A
$0

See 3B
See 3B

1-2

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

8
4

2
2

(D)

0
0.3

(E)
Technical
personhours per
year
(E=C×D)
0
2.4

Management
person-hours
per year
(E×0.05)
0
0.1

(G)
Clerical
personhours per
year
(E×0.1)
0
0.2

24
24

1
1

24
24

3
0.3

72
7.2

3.6
0.4

7.2
0.7

$4,377
$438

24
24
40

2.5
2.5
6

60
60
240

3
0.3
0

180
18
0

9.0
0.9
0

18
1.8
0

$10,942
$1,094
$0

6
1
See 3B

52
12

312
12

3
3

936
36

47
1.8

94
3.6

$56,899
$2,188

12
6
1

24
240
0.25

3
0
3

72
0
0.8
1,564

3.6
0
0.04
78

7.2
0
0.08
156

$4,377
$0
$46
$95,096

Respondents
per year a

(F)

(H)

Cost,$ b
$0
$146

See 3A

See 3B
2
40
0.25

1-3

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

(D)

Respondents
per year a

(E)
Technical
personhours per
year
(E=C×D)

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

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

(H)

Cost,$ b

$102,000
$10,200
$112,200
$24,880
$2,488
$27,368
$343
$20,890
$21,233
$27,711

1-4

1-5

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

(B)
No. of
occurrences per
respondent per
year

(E)
Technical
personhours per
year
(E=C×D)

Management
person-hours
per year
(E×0.05)

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

100
20
20

1
1
1

100
20
20

0
0
0

$0
$0
$0

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

2
16

1
1

2
16

0
0

$0
$0

0.5

0.9

1.8

Personhours per
occurrence

(D)

Respondents
per year a

(F)

(H)

Cost,$ b

N/A
N/A

See 3B
See 3B

1-6

$1,094

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

8
4

2
2

(D)

2.6
0.3

(E)
Technical
personhours per
year
(E=C×D)
41
2.4

Management
person-hours
per year
(E×0.05)
2.0
0.1

(G)
Clerical
personhours per
year
(E×0.1)
4.1
0.2

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
1
See 3B

52
12

312
12

3
3

936
36

47
1.8

94
3.6

$56,899
$2,188

12
6
1

24
240
0.25

3
0
3

72
0
0.8
1,106

3.6
0
0.04
55

7.2
0
0.08
111

$4,377
$0
$46
$67,230

Respondents
per year a

(F)

(H)

Cost,$ b
$2,480
$146

See 3A

See 3B
2
40
0.25

1-7

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

(D)

Respondents
per year a

(E)
Technical
personhours per
year
(E=C×D)

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

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

(H)

Cost,$ b

$102,000
$10,200
$112,200
$24,880
$2,488
$27,368
$145
$20,890
$21,035
$27,513

1-8

1-9

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

(B)
No. of
occurrences per
respondent per
year

(E)
Technical
personhours per
year
(E=C×D)

Management
person-hours
per year
(E×0.05)

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

100
20
20

1
1
1

100
20
20

0
0
0

$0
$0
$0

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

2
16

1
1

2
16

0
0

$0
$0

0.5

0.9

1.8

Personhours per
occurrence

(D)

Respondents
per year a

(F)

(H)

Cost,$ b

N/A
N/A

See 3B
See 3B

1-10

$1,094

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

8
4

2
2

(D)

2.6
0.3

(E)
Technical
personhours per
year
(E=C×D)
41
2.4

Management
person-hours
per year
(E×0.05)
2.0
0.1

(G)
Clerical
personhours per
year
(E×0.1)
4.1
0.2

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
1
See 3B

52
12

312
12

3
3

936
36

47
1.8

94
3.6

$56,899
$2,188

12
6
1

24
240
0.25

3
0
3

72
0
0.8
1,106

3.6
0
0.04
55

7.2
0
0.08
111

$4,377
$0
$46
$67,230

Respondents
per year a

(F)

(H)

Cost,$ b
$2,480
$146

See 3A

See 3B
2
40
0.25

1-11

(A)
Burden item

Personhours per
occurrence

(B)
No. of
occurrences per
respondent per
year

(D)

Respondents
per year a

(E)
Technical
personhours per
year
(E=C×D)

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

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

(H)

Cost,$ b

$102,000
$10,200
$112,200
$24,880
$2,488
$27,368
$145
$20,890
$21,035
$27,513

1-12

1-13

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

Year
Year 4
Year 5
Year 6
Totals
Average

No.
responses
16
7
7
29
10

Technical
hours
1,564
1,106
1,106
3,776

Management
hours
78
55
55
189

Clerical
Hours
156
111
111
378

Total hours
1,799
1,272
1,272
4,343
1,448

1-14

Labor costs
$95,096
$67,230
$67,230
$229,557
$76,519

Capital
$112,200
$112,200
$112,200
$336,600
$112,200

Non-Labor Costs
Annualized
Annual
capital
O&M
$27,368
$21,233
$27,368
$21,035
$27,368
$21,035
$82,104
$63,304
$27,368
$21,101

Total annualized
cost
$48,601
$48,403
$48,403
$145,408
$48,469

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

Activity

(A)
EPA
personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

Plants
per year a

0.3

(E)
Technical
personhours per
year
(E=CxD)
7.2

Management
person-hours
per year
(E×0.05)
0.4

(G)
Clerical
personhours per
year
(E×0.1)
0.7

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0.03
0.03
0.03
0.2

0.2
0.7
62
7.2

0.01
0.04
3.1
0.4

0.02
0.07
6.2
0.7

$14
$43
$3,722
$429

2
2
2
2
2
2
60
2
40
4

1
1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
2
40
4

0
0
0
0
0
3
3
3
0.3
3

0
0
0
0
0
6.0
180
6.0
12
12

0
0
0
0
0
0.3
9.0
0.3
0.6
0.6

0
0
0
0
0
0.6
18
0.6
1.2
1.2

$0
$0
$0
$0
$0
$358
$10,737
$358
$716
$716

8
2
1

2
2
1

16
4
1

0
0
0.3

0
0
0.3
294

0
0
0.02
15

0
0
0.03
29

$0
$0
$18
$17,540
$240
$17,780

1-15

(D)

(F)

(H)

Cost,$ b
$429

A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. 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 $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours
are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
c
Assumes Agency personnel will attend performance tests at 10% of plants.
d
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 10% of facilities will use an alternative fuel once per year.
j
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.

1-16

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
0.03
0.2

0
0
62
7.2

0
0
3.1
0.4

0
0
6.2
0.7

2
2
2
2
2
2
60
2
40
4

1
1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
2
40
4

0
0
0
0
0
0
0
0
0
0

8
2
1

2
2
1

16
4
1

0.5
2.6
0.3

7.2
10
0.3
87

0.4
0.5
0.02
4.4

0.7
1.0
0.03
8.7

1-17

(D)

(F)

(H)

Cost,$ b
$0
$0
$0
$3,722
$429
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$429
$608
$18
$5,207
$75
$5,282

A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. 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 $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours
are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
c
Assumes Agency personnel will attend performance tests at 10% of plants.
d
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 10% of facilities will use an alternative fuel once per year.
j
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.

1-18

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
0.03
0.2

0
0
62
7.2

0
0
3.1
0.4

0
0
6.2
0.7

2
2
2
2
2
2
60
2
40
4

1
1
1
1
1
1
1
1
1
1

2
2
2
2
2
2
60
2
40
4

0
0
0
0
0
0
0
0
0
0

8
2
1

2
2
1

16
4
1

0.5
2.6
0.3

7.2
10
0.3
87

0.4
0.5
0.02
4.4

0.7
1.0
0.03
8.7

1-19

(D)

(F)

(H)

Cost,$ b
$0
$0
$0
$3,722
$429
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$429
$608
$18
$5,207
$75
$5,282

A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. 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 $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours
are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
c
Assumes Agency personnel will attend performance tests at 10% of plants.
d
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 10% of facilities will use an alternative fuel once per year.
j
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.

1-20

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

Technical hours
294
87
87
469

Management hours
15
4.4
4.4
23

Clerical Hours
29
8.7
8.7
47

1-21

Total hours
338
100
100
539
180

Labor costs
$17,780
$5,282
$5,282
$28,345
$9,448

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