2509ss02

2509ss02.pdf

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

OMB: 2030-0047

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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)
September 2015
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
90 existing BSCP facilities that are currently major sources of HAP. An estimated 21 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 69 existing BSCP facilities are expected to be subject
to the rule, of which 63 are equipped with tunnel kilns, 15 with periodic kilns, and 24 with air
pollution control devices (APCDs). 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 provided a 90-day public comment period following proposal of the BSCP
manufacturing NESHAP, during which all affected parties were given the opportunity to
comment on the proposed rule. The EPA has considered the comments received and, as
appropriate, incorporated them into the final rule. This ICR was also 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)(b)

Notification of performance test

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

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(a)-(c)

Request to use routine control device maintenance alternative
standard

63.8480(b)

Requirements

Rule Citation by Section

Records
Record retention

63.10(b)(1) and 63.8495

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 request

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
Electronic submittal of performance test results (using ERT)

63.8485(a)-(e)
63.8485(a)-(e)
63.8485(c)(6)-(7)
63.8485(c)(9), (d)-(e)
63.8485(f)

(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 were addressed in the BSCP proposed rule. As required by section
604 of the RFA, the EPA prepared a Final Regulatory Flexibility Analysis (FRFA) for the BSCP
final rule. The FRFA addresses the issues raised by public comments on the IRFA for 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 to use the routine control device maintenance alternative standard no
later than 120 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 knowledge and experience with part 63 and other
regulations, and BSCP industry comments on the proposed rule, including burden estimates from
a recent BIA survey of the BSCP industry.
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

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).

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 15minute 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. No capital/startup costs
were expected to be incurred during the first 3 years after the effective date of the rule.
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 69 existing BSCP major source
facilities will be subject to the BSCP rule, assuming that 22 BSCP facilities will become
synthetic area sources rather than comply with the rule. Of these 69 facilities, 63 are equipped
with tunnel kilns, 15 with periodic kilns, and 24 with APCDs. 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 93, with
an average of 31 responses per year. The estimated total burden for the 3-year period is 62,890
labor hours at a labor cost of $3,339,316. The average bottom line annual burden over the 3-year
period is 20,963 labor hours at a labor cost of $1,113,105. 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 $2,046, with an average of $682 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
214, with an average of 71 hours per year. The total cost over the 3-year period is $11,095. The
average annual cost incurred during each year is $3,698.
(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 to use the routine control device maintenance alternative standard
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 and no new BSCP kilns are anticipated to be
constructed in the near future, 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 676 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

Personhours per
occurrence a

(B)
(C)
No. of
Personoccurrences per hours per
respondent per respondent
year
per year

(D)

Respondents
per year b

(C=A×B)
1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Read and understand rule requirements d
B. Required activities
Develop OM&M plan e
Update OM&M plan
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 e
Notification of constr./reconstr. e
Notification of anticipated startup e
Notification of actual startup e
Request to use APCD maintenance
alternative standard e
Notification of performance test
Notification of compliance status e,f
Report of performance test (through ERT)
First compliance report
Semi-annual compliance reports
Deviations g
No deviations g

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

N/A
N/A
12

414

$58,676

200
10
30
160

1
1
1
1

200
10
30
160

0
0
0
0

$0
$0
$0
$0

40
See 3B
See 3B

6
28
3
3
4

1
1
1
1
1

6
28
3
3
4

69
0
0
0
0

414
0
0
0
0

21
0
0
0
0

41
0
0
0
0

$25,167
$0
$0
$0
$0

6
24
20
30

1
1
1
1

6
24
20
30

0
0
0
0

$0
$0
$0
$0

30
12

2
2

60
24

0
0

$0
$0

(A)
Burden item

Personhours per
occurrence a

(B)
(C)
No. of
Personoccurrences per hours per
respondent per respondent
year
per year

(D)

Respondents
per year b

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

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

See 3A
24
24

1
1

24
24

0
0

$0
$0

34
34
60

2.5
2.5
6

85
85
360

0
0
0

$0
$0
$0

8
See 3B

416

48
10
0.25

6
6
1

288
60
0.25

0
0
69

0
0
17
845

0
0
0.9
436

0
0
1.7
43

See 3B

$0
$0
$1,049
$84,891

$0
$0
$0

(A)
Personhours per
occurrence a

Burden item

(B)
(C)
No. of
Personoccurrences per hours per
respondent per respondent
year
per year
(C=A×B)

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

ANNUALIZED CAPITAL COSTS:
Initial performance tests l
$0
m
Repeat performance tests
$0
Total annualized capital cost
$0
o
ANNUAL O&M COSTS
Photocopy/postage
$1,518
Visible emissions tests l
$0
Total O&M cost
$1,518
TOTAL ANNUALIZED COSTS
$1,518
(Annualized capital + O&M costs)
a
Person-hours per occurrence were derived based on comments from industry.
b
A total of 69 existing major sources are expected to comply during the 3-year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic
kilns, and 24 with APCDs. 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.
c
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.
d
Assumes one-time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among
technical and management staff.
e
One-time only activities.
f
The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden
associated with developing the performance test report is included in the performance test capital cost at the bottom of the table.
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 industry, an average of 2.5 plant personnel attend performance
tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
i
Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel.
j
Time associated with transmitting reports. Equal to the number of respondents submitting reports.
k
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.
l
Based on estimates in BSCP Impacts Memo. Stack testing costs assume EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl, and Cl 2 . VE testing
costs assume EPA Method 22.
m
Assumes 10% of plants will fail an initial performance test for one kiln 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).

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

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(C=A×B)
1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Read and understand rule requirements d
B. Required activities
Develop OM&M plan e
Update OM&M plan
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 e
Notification of constr./reconstr. e
Notification of anticipated startup e
Notification of actual startup e
Request to use APCD maintenance
alternative standard e
Notification of performance test
Notification of compliance status e,f
Report of performance test (through
ERT)
First compliance report
Semi-annual compliance reports
Deviations g

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

N/A
N/A
12

200
10
30
160

200

1
1

30
160

0
0

$0
$0

40
See 3B
See 3B

6
28
3
3
4

1
1
1
1
1

6
28
3
3
4

0
0
0
0
0

$0
$0
$0
$0
$0

6
24
20

1
1
1

6
24
20

0
0
0

$0
$0
$0

(A)
Burden item

No deviations g
4. Recordkeeping Requirements
A. Read instructions
B. Plan activities
Prepare for initial performance test
Prepare for repeat performance test
C. Implement activities
Attend initial performance test h
Attend repeat performance test h
D. Develop record system
E. Time to enter information
Records of compliance data
Records of APCD maintenance/
inspections
Records of compliance with work
practices
Records of deviations
F. Time to train personnel i
Initial training
Annual training
G. Time to transmit/disclose information j
TOTAL ANNUAL BURDEN AND COST
(SALARY)
TOTAL ANNUAL NUMBER OF
RESPONSES k
CAPITAL COSTS:
Initial performance tests l
Repeat performance tests m
Total capital cost

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

24
24

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(H)

(C=A×B)
24

(E=C×D)
0

(E×0.05)
0

(E×0.1)
0

1
1

24
24

0
0

$0
$0

34
34
60

2.5
2.5
6

85
85
360

0
0
0

$0
$0
$0

8
See 3B

416

48
10
0.25

6
6
1

288
60
0.25

0
0
0

0
0
0
0

$0
$0
$0
$0

Cost,$ c

See 3A

See 3B

$0
$0
$0

(A)
Personhours per
occurrence a

Burden item

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

ANNUALIZED CAPITAL COSTS:
Initial performance tests l
$0
m
Repeat performance tests
$0
Total annualized capital cost
$0
o
ANNUAL O&M COSTS
Photocopy/postage
$0
Visible emissions tests l
$0
Total O&M cost
$0
TOTAL ANNUALIZED COSTS
$0
(Annualized capital + O&M costs)
a
Person-hours per occurrence were derived based on comments from industry.
b
A total of 69 existing major sources are expected to comply during the 3-year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic
kilns, and 24 with APCDs. 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.
c
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.
d
Assumes one-time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among
technical and management staff.
e
One-time only activities.
f
The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden
associated with developing the performance test report is included in the performance test capital cost at the bottom of the table.
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 industry, an average of 2.5 plant personnel attend performance
tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
i
Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel.
j
Time associated with transmitting reports. Equal to the number of respondents submitting reports.
k
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.
l
Based on estimates in BSCP Impacts Memo. Stack testing costs assume EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl, and Cl 2 . VE testing
costs assume EPA Method 22.
m
Assumes 10% of plants will fail an initial performance test for one kiln 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).

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

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(C=A×B)
1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Read and understand rule requirements d
B. Required activities
Develop OM&M plan e
Update OM&M plan
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 e
Notification of constr./reconstr. e
Notification of anticipated startup e
Notification of actual startup e
Request to use APCD maintenance
alternative standard e
Notification of performance test
Notification of compliance status e,f
Report of performance test (through
ERT)
First compliance report
Semi-annual compliance reports
Deviations g

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours
per year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

N/A
N/A
12

200
10
30
160

1
1
1
1

200
10
30
160

63
0
0
0

12,600
0
0
0

630
0
0
0

1,260
0
0
0

40
See 3B
See 3B

6
28
3
3
4

1
1
1
1
1

6
28
3
3
4

0
0
0
0
24

0
0
0
0
96

0
0
0
0
4.8

0
0
0
0
10

$0
$0
$0
$0
$5,836

6
24
20

1
1
1

6
24
20

0
0
0

$0
$0
$0

$0
$765,951
$0
$0
$0

(A)
Burden item

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

24
24

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours
per year

(H)

(C=A×B)
24

(E=C×D)
0

(E×0.05)
0

(E×0.1)
0

1
1

24
24

0
0

$0
$0

34
34
60

2.5
2.5
6

85
85
360

0
0
63

0
0
22,680

0
0
1,134

0
0
2,268

8
See 3B

416

48
10
0.25

6
6
1

288
60
0.25

63
0
63

18,144
0
16
53,536

907
0
0.8
2,677

1,814
0
1.6
5,354

Cost,$ c

See 3A

$0
$0
$1,378,712

See 3B

$1,102,969
$0
$957
$3,254,425

$0
$0
$0

(A)
Personhours per
occurrence a

Burden item

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours
per year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

ANNUALIZED CAPITAL COSTS:
Initial performance tests l
$0
m
Repeat performance tests
$0
Total annualized capital cost
$0
o
ANNUAL O&M COSTS
Photocopy/postage
$528
Visible emissions tests l
$0
Total O&M cost
$528
TOTAL ANNUALIZED COSTS
$528
(Annualized capital + O&M costs)
a
Person-hours per occurrence were derived based on comments from industry.
b
A total of 69 existing major sources are expected to comply during the 3-year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic
kilns, and 24 with APCDs. 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.
c
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.
d
Assumes one-time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among
technical and management staff.
e
One-time only activities.
f
The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden
associated with developing the performance test report is included in the performance test capital cost at the bottom of the table.
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 industry, an average of 2.5 plant personnel attend performance
tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
i
Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel.
j
Time associated with transmitting reports. Equal to the number of respondents submitting reports.
k
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.
l
Based on estimates in BSCP Impacts Memo. Stack testing costs assume EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl, and Cl 2 . VE testing
costs assume EPA Method 22.
m
Assumes 10% of plants will fail an initial performance test for one kiln 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).

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
69
0
24
93
31

Technical
hours
845
0
53,536
54,381

Management
hours
436
0
2,677
3,112

Clerical
Hours
43
0
5,354
5,397

Total
hours
1,324
0
61,566
62,890
20,963

Labor costs
$84,891
$0
$3,254,425
$3,339,316
$1,113,105

Capital
$0
$0
$0
$0
$0

Non-Labor Costs
Annualized
Annual
capital
O&M
$0
$1,518
$0
$0
$0
$528
$0
$2,046
$0
$682

Total
annualized cost
$1,518
$0
$528
$2,046
$682

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 to use APCD maintenance alternative
standard
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

(A)

(B)

EPA
personhours per
occurrence

No. of
occurrences
per plant per
year

(D)

(E)

(F)

(G)

(H)

Plants
per year a

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

Clerical
personhours
per year
(E×0.1)
0

Cost,$ b

Technical
personhours per
year
(E=CxD)
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

1
1
1
1
1

2
2
2
2
2

69
0
0
0
0

138
0
0
0
0

6.9
0
0
0
0

14
0
0
0
0

$8,231
$0
$0
$0
$0

2
60
40
4

1
1
1
1

2
60
40
4

0
0
0
0

$0
$0
$0
$0

8
2

2
2

16
4

0
0

0
0
138

0
0
6.9

0
0
14

$0
$0
$8,231
$0
$8,231

A total of 69 existing major sources are expected to comply during the 3-year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic
kilns, and 24 with APCDs. 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.

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 personhours 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 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.

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

Activity

(A)

(B)

EPA
personhours per
occurrence

No. of
occurrences
per plant per
year

(D)

(E)

(F)

(G)

(H)

Plants
per year a

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

Clerical
personhours
per year
(E×0.1)
0

Cost,$ b

Technical
personhours per
year
(E=CxD)
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

1
1
1
1
1

2
2
2
2
2

0
0
0
0
0

$0
$0
$0
$0
$0

2
60
40
4

1
1
1
1

2
60
40
4

0
0
0
0

$0
$0
$0
$0

8
2

2
2

16
4

0
0

0
0
0

$0
$0
$0
$0
$0

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

Activity

(A)

(B)

EPA
personhours per
occurrence

No. of
occurrences
per plant per
year

(D)

(E)

(F)

(G)

(H)

Plants
per year a

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

Clerical
personhours
per year
(E×0.1)
0

Cost,$ b

Technical
personhours per
year
(E=CxD)
0

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0
0
0
0

2
2
2
2
2

1
1
1
1
1

2
2
2
2
2

0
0
0
0
24

0
0
0
0
48

0
0
0
0
2.4

0
0
0
0
4.8

2
60
40
4

1
1
1
1

2
60
40
4

0
0
0
0

8
2

2
2

16
4

0
0

0
0
48

0
0
2.4

0
0
4.8

$0
$0
$0
$0
$0
$0
$0
$0
$0
$2,863
$0
$0
$0
$0
$0
$0
$2,863
$0
$2,863

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
138
0
138
186

Management hours
6.9
0
2.4
9.3

Clerical Hours
14
0
4.8
19

Total hours
159
0
55
214
71

Labor costs
$8,231
$0
$2,863
$11,095
$3,698

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

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(C=A×B)
1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Read and understand rule requirements d
B. Required activities
Develop OM&M plan e
Update OM&M plan
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 e
Notification of constr./reconstr. e
Notification of anticipated startup e
Notification of actual startup e
Request to use APCD maintenance
alternative standard e
Notification of performance test
Notification of compliance status e,f
Report of performance test (through
ERT)
First compliance report
Semi-annual compliance reports
Deviations g

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

N/A
N/A
12

200
10
30
160

1
1
1
1

200
10
30
160

0
63
24
15

0
630
720
2,400

0
32
36
120

0
63
72
240

$0
$56,796
$43,769
$145,895

40
See 3B
See 3B

2,520

126

252

$153,190

6
28
3
3
4

1
1
1
1
1

6
28
3
3
4

0
0
0
0
0

6
24
20

1
1
1

6
24
20

63
69
63

378
1,656
1,260

18.9
83
63

38
166
126

$22,979
$100,668
$76,595

2,070

104

207

$125,835

1-2

$0
$0
$0
$0
$0

(A)
Burden item

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

24
24

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(H)

(C=A×B)
24

(E=C×D)
0

(E×0.05)
0

(E×0.1)
0

1
1

24
24

63
6.3

1,512
151

76
7.6

151
15.1

$91,914
$9,191

34
34
60

2.5
2.5
6

85
85
360

63
6.3
0

5,355
536
0

268
27
0

536
54
0

$325,529
$32,553
$0

8
See 3B

416

28,704

1,435

2,870

1,656

166

48
10
0.25

6
6
1

288
60
0.25

0
63
69

0
3,780
17
53,345

0
189
0.9
2,667

0
378
1.7
5,334

Cost,$ c
$0

See 3A

$1,744,909

See 3B
$100,668
$0
$340,774
$1,049
$3,372,313

264

$2,262,000
$226,200
$2,488,200

1-3

(A)
Personhours per
occurrence a

Burden item

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

ANNUALIZED CAPITAL COSTS:
Initial performance tests l
$551,600
m
Repeat performance tests
$55,160
Total annualized capital cost
$606,760
ANNUAL O&M COSTS o
Photocopy/postage
$5,808
Visible emissions tests l
$202,912
Total O&M cost
$208,720
TOTAL ANNUALIZED COSTS
$815,480
(Annualized capital + O&M costs)
a
Person-hours per occurrence were derived based on comments from industry.
b
A total of 69 existing major sources are expected to comply during the 3-year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic
kilns, and 24 with APCDs. 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.
c
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.
d
Assumes one-time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among
technical and management staff.
e
One-time only activities.
f
The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden
associated with developing the performance test report is included in the performance test capital cost at the bottom of the table.
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 industry, an average of 2.5 plant personnel attend performance
tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
i
Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel.
j
Time associated with transmitting reports. Equal to the number of respondents submitting reports.
k
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.
l
Based on estimates in BSCP Impacts Memo. Stack testing costs assume EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl, and Cl 2 . VE testing
costs assume EPA Method 22.
m
Assumes 10% of plants will fail an initial performance test for one kiln 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).

1-4

1-5

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

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(C=A×B)
1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Read and understand rule requirements d
B. Required activities
Develop OM&M plan e
Update OM&M plan
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 e
Notification of constr./reconstr. e
Notification of anticipated startup e
Notification of actual startup e
Request to use APCD maintenance
alternative standard e
Notification of performance test
Notification of compliance status e,f
Report of performance test (through
ERT)
First compliance report
Semi-annual compliance reports

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

N/A
N/A
12

200
10
30

1
1
1

200
10
30

0
63
0

0
630
0

0
32
0

0
63
0

$0
$56,796
$0

160

40
See 3B
See 3B

6
28
3
3
4

1
1
1
1
1

6
28
3
3
4

0
0
0
0
0

$0
$0
$0
$0
$0

6
24
20

1
1
1

6
24
20

0
0
0

$0
$0
$0

1-6

(A)
Burden item

Deviations g
No deviations g
4. Recordkeeping Requirements
A. Read instructions
B. Plan activities
Prepare for initial performance test
Prepare for repeat performance test
C. Implement activities
Attend initial performance test h
Attend repeat performance test h
D. Develop record system
E. Time to enter information
Records of compliance data
Records of APCD maintenance/
inspections
Records of compliance with work
practices
Records of deviations
F. Time to train personnel i
Initial training
Annual training
G. Time to transmit/disclose information j
TOTAL ANNUAL BURDEN AND COST
(SALARY)
TOTAL ANNUAL NUMBER OF
RESPONSES k
CAPITAL COSTS:
Initial performance tests l
Repeat performance tests m

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

30
12

2
2

24
24

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(H)

(C=A×B)
60
24

10
59

(E=C×D)
621
1,408

(E×0.05)
31
70

(E×0.1)
62
141

1
1

24
24

0
0

$0
$0

34
34
60

2.5
2.5
6

85
85
360

0
0
0

$0
$0
$0

8
See 3B

416

28,704

1,435

2,870

1,656

166

48
10
0.25

6
6
1

288
60
0.25

0
63
69

0
3,780
17
36,816

0
189
0.9
1,841

0
378
1.7
3,682

Cost,$ c
$37,750
$85,568

See 3A

$1,744,909

See 3B
$100,668
$0
$340,774
$1,049
$2,367,514

138

$0
$0

1-7

(A)
Burden item

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

Total capital cost
$0
ANNUALIZED CAPITAL COSTS: n
Initial performance tests l
$551,600
m
Repeat performance tests
$55,160
Total annualized capital cost
$606,760
ANNUAL O&M COSTS o
Photocopy/postage
$3,036
Visible emissions tests l
$202,912
Total O&M cost
$205,948
TOTAL ANNUALIZED COSTS
$812,708
(Annualized capital + O&M costs)
a
Person-hours per occurrence were derived based on comments from industry.
b
A total of 69 existing major sources are expected to comply during the 3-year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic
kilns, and 24 with APCDs. 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.
c
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.
d
Assumes one-time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among
technical and management staff.
e
One-time only activities.
f
The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden
associated with developing the performance test report is included in the performance test capital cost at the bottom of the table.
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 industry, an average of 2.5 plant personnel attend performance
tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
i
Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel.
j
Time associated with transmitting reports. Equal to the number of respondents submitting reports.
k
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.
l
Based on estimates in BSCP Impacts Memo. Stack testing costs assume EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl, and Cl 2 . VE testing
costs assume EPA Method 22.
m
Assumes 10% of plants will fail an initial performance test for one kiln 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).

1-8

1-9

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

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(C=A×B)
1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Read and understand rule requirements d
B. Required activities
Develop OM&M plan e
Update OM&M plan
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 e
Notification of constr./reconstr. e
Notification of anticipated startup e
Notification of actual startup e
Request to use APCD maintenance
alternative standard e
Notification of performance test
Notification of compliance status e,f
Report of performance test (through
ERT)
First compliance report
Semi-annual compliance reports

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

N/A
N/A
12

200
10
30

1
1
1

200
10
30

0
63
0

0
630
0

0
32
0

0
63
0

$0
$56,796
$0

160

40
See 3B
See 3B

6
28
3
3
4

1
1
1
1
1

6
28
3
3
4

0
0
0
0
0

$0
$0
$0
$0
$0

6
24
20

1
1
1

6
24
20

0
0
0

$0
$0
$0

1-10

(A)
Burden item

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

30
12

2
2

24
24

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(H)

(C=A×B)
60
24

10
59

(E=C×D)
621
1,408

(E×0.05)
31
70

(E×0.1)
62
141

1
1

24
24

0
0

$0
$0

34
34
60

2.5
2.5
6

85
85
360

0
0
0

$0
$0
$0

8
See 3B

416

28,704

1,435

2,870

1,656

166

48
10
0.25

6
6
1

288
60
0.25

0
63
69

0
3,780
17.3
36,816

0
189
0.9
1,841

0
378
1.7
3,682

Cost,$ c
$37,750
$85,568

See 3A

$1,744,909

See 3B
$100,668
$0
$340,774
$1,049
$2,367,514

138

$0
$0

1-11

(A)
Burden item

Personhours per
occurrence a

(B)
No. of
occurrences
per respondent
per year

(D)

Respondents
per year b

(E)
Technical
personhours per
year

(F)
Management
person-hours
per year

(G)
Clerical
personhours per
year

(E=C×D)

(E×0.05)

(E×0.1)

(H)

Cost,$ c

1-12

1-13

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
264
138
138
540
180

Technical
hours
53,345
36,816
36,816
126,977

Management
hours
2,667
1,841
1,841
6,349

Clerical
Hours
5,334
3,682
3,682
12,698

Total
hours
61,347
42,338
42,338
146,023
48,674

1-14

Labor costs
$3,372,313
$2,367,514
$2,367,514
$8,107,341
$2,702,447

Capital
$2,488,200
$0
$0
$2,488,200
$829,400

Non-Labor Costs
Annualized
Annual
capital
O&M
$606,760
$208,720
$606,760
$205,948
$606,760
$205,948
$1,820,280
$620,616
$606,760
$206,872

Total
annualized cost
$815,480
$812,708
$812,708
$2,440,896
$813,632

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

Activity

(A)

(B)

EPA
personhours per
occurrence

No. of
occurrences
per plant per
year

(D)

(E)

(F)

(G)

(H)

Plants per
year a

Management
person-hours
per year
(E×0.05)
7.6

Clerical
personhours
per year
(E×0.1)
15

Cost,$ b

6.3

Technical
personhours per
year
(E=CxD)
151

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0.6
0.6
0.6
3.2

5.0
15
1,310
151

0.3
0.8
66
7.6

0.5
1.5
131
15

$301
$902
$78,163
$9,019

2
2
2
2
2

1
1
1
1
1

2
2
2
2
2

0
0
0
0
0

2
60
40
4

1
1
1
1

2
60
40
4

63
69
6.3
69

126
4,140
252
276

6.3
207
13
14

13
414
25
28

$7,516
$246,943
$15,031
$16,463

8
2

2
2

16
4

0
0

0
0
6,427

0
0
321

0
0
643

$0
$0
$383,355
$5,040
$388,395

$9,019

$0
$0
$0
$0
$0

1-15

1-16

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

Activity

(A)

(B)

EPA
personhours per
occurrence

No. of
occurrences
per plant per
year

(D)

(E)

(F)

(G)

(H)

Plants per
year a

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

Clerical
personhours
per year
(E×0.1)
0

Cost,$ b

Technical
personhours per
year
(E=CxD)
0

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0
0
0.6
3.2

0
0
1,310
151

0
0
66
7.6

0
0
131
15

$0
$0
$78,163
$9,019

2
2
2
2
2

1
1
1
1
1

2
2
2
2
2

0
0
0
0
0

$0
$0
$0
$0
$0

2
60
40
4

1
1
1
1

2
60
40
4

0
0
0
0

$0
$0
$0
$0

8
2

2
2

16
4

10
59

166
235
1,862

8.3
12
93

17
23
186

$9,878
$13,993
$111,053
$1,575
$112,628

1-17

1-18

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

Activity

(A)

(B)

EPA
personhours per
occurrence

No. of
occurrences
per plant per
year

(D)

(E)

(F)

(G)

(H)

Plants per
year a

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

Clerical
personhours
per year
(E×0.1)
0

Cost,$ b

Technical
personhours per
year
(E=CxD)
0

8
24
2,080
48

1
1
1
1

8
24
2,080
48

0
0
0.6
3.2

0
0
1,310
151

0
0
66
7.6

0
0
131
15

$0
$0
$78,163
$9,019

2
2
2
2
2

1
1
1
1
1

2
2
2
2
2

0
0
0
0
0

$0
$0
$0
$0
$0

2
60
40
4

1
1
1
1

2
60
40
4

0
0
0
0

$0
$0
$0
$0

8
2

2
2

16
4

10
59

166
235
1,862

8.3
12
93

17
23
186

$9,878
$13,993
$111,053
$1,575
$112,628

1-19

1-20

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
1,862
1,862
10,151

Management hours
321
93
93
508

Clerical Hours
643
186
186
1,015

1-21

Total hours
7,391
2,141
2,141
11,673
3,891

Labor costs
$388,395
$112,628
$112,628
$613,651
$204,550

File Type	application/pdf
File Modified	2019-11-22
File Created	2015-09-23