### 1 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

National Emission Standards f or Haza rdous Air Pollutants for Clay Ceramics

Manufacturing

(40 C FR Part 63, Subpart KKKKK )

October 2014

Part A o f t he 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

Manufactur ing (40 CFR Part 63, Subpart KKKKK ). ” This is a new information collection

request (ICR). The E PA 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 pr ocess the ceramic mix into a powder to

allow tile pressing

. Dry ers are used to reduce the moist ure 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 fir e 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 operation s

, 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, s ubpart 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 construct ed 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 notification s 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.

### 2 General requirements applicable to all NESHAP include records of applicability determinations

, performance te st 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 re maining

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 p arameter monitoring

requirements :

• Tunnel or roller kilns:

• D ry injection fabric filter (DIFF) / dry lime scrubber/fabric filter (DLS) : L ime injection

rate and either periodic visible emissions ( VE ) determinations or bag leak detec tors

• W et scrubbers : P ressure drop, scrubber liquid pH, scrubber liquid flow rate and

chemical addition rate (if applicable)

• A ctivated carbon injection : C arbon flow rate

• No control device: Periodic VE determinations and kiln process rate monitoring ( if

thei r 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: E ither periodic VE determinations or bag leak detectors

• Wet scrubbers : Pressure drop and scrubber liquid flow rate

• W ater curtains : D aily inspection s 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 con dition of the control

equipment

• B affles : A nnual visual inspection of the baffles to c onfirm the baffles are in place

• Spray dryers /floor tile press dryer s : 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) Ne ed/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 existi ng sources

of HAP and shall require the maximum degree of emission reduction. In addition, s ection 114 of

the CAA allows the Administrator to require inspections, monitoring and entry into facilities to

ensure compliance with a section 112 emission standar d. Sectio n 114(a)(1) specifically states

### 3 that t he Administrator may require any own er or operat or 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 equip ment, 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 certificatio ns

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 judg ment, the pollutants emitted from clay ceramics manufacturing facilities

cause or contribute significantly to air p ollution 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 in cluded 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 sou rce

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 d eadlines for reestablishing standards for

this source category. Consequently, new NESHAP for this source category are being proposed.

2 (b) Prac tical 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 proper ly 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 faciliti es 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 inspectio n and would not

need to be routinely reported to the EPA

.

### 4 3. 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 an d is not expected to be required by any other EPA rulemaking

currently in progress. However, certain reports required by s tate or local agencies may duplicate

information required by the standards. In such cases, a copy of the report submitted to the s tate

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 co mment 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 spe cific 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, Sol ios 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 t o 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

inc orporate the comments received.

3 (d) Effects of Less Frequent Collection

If the relev ant 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 a dministrative 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

### 5 frequency in the rule is consistent with the requirements of t itle 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 ex ceeds 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

i n 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 s tate

- approved p ermitting 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 rece nt 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 w hich 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, Sep tember 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 r espondents 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) code s for respo ndents affected by the

standards are 3271 1 0

— Pottery, Ceramics, and Plumbing Fixture Manufacturing

— and

327120

— Clay Building Material and Refractories Manufacturing . Not all processes classified in

th e s e NAICS code s are regulated by the standards.

4(b) Infor mation 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 reco rdkeeping and reporting requirements under the rule.

### 6 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) 63.8 63 5( 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).

### 7 5. The Information Collected

-- Agency Activities, Collection Methodology and

Infor mation Management

5 (a) Agency Activities

The Agency activities in the first 3 years following t he 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 initi al 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 u sed 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 loc al 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, t he EPA

does not expect that any faciliti es 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 da ta 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

s tartup 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.

### 8 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 t he

effect ive 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 i nitial 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 doe s 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 Bu rden 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 Table s 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 c lay c eramics rulemaking, In addition, comments and

information received from the Brick In dustry 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 require ments

.

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 3271 0 0

— 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 20 13 (the most recent rates available) are

$ 25.32 per hour ($ 25.32 /hr) for technical personnel, $ 42.17 /hr for manage ment personnel and

$ 15.19 /hr for clerical personnel. The base labor rates were adj usted 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).

### 9 110 percent. The final total labor rates are $ 53.17 for technical personnel, $ 88.56 for

management and $ 31.90 for clerical

.

(ii) Estimating Capital/St artup 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 mo nitoring. 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., l ime f eed 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) Es timating 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 f ederal g overnment. Publication and distribution of the information are part of the AFS

program , with the result that no f ederal costs can be directly attri buted 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 attr ibutable to the ICR. The only costs that the f ederal

government will incur are user costs associated with the analysis of the reported information, as

presented in Tables 5 through 7

.

Labor rates for f ederal employees are based on the January 20 1 2, 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 $ 29.5 2/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 comple te 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 ce ramics facilities or affected sources are expected to be

construct ed in the near future, and existing capacity is assumed to be sufficient to cover any

short

- term increases in production.

### 10 6 (e) Bottom Line Burd en Hours and Costs/Master Tables

(i) Respondent Tally

The bottom line annual respondent burden hours and costs, presented in Table s 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 effec tive date

.

(ii) The Agency Tally

The bottom line Agency burden hours and costs, presented in Table s 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 b y 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 burde n 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 A nnual 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 activitie s 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. Facil ities

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 t he 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 per formance

### 11 test) , submit notification s 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 f uel 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 y ears

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 p rovide

information to or for a f ederal agency. Thi s 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 inform ation; 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

transm it or other wise 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 regulatio ns 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

- 201 3

- 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, Of fic e 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

- 201 3

- 0290 in any correspondence.

### 12 Part B o f t he Supporting Statement

This part is not applicable because statistical methods are not used in data collection

associated with the rule

.

### 13 Table 1. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the Clay Ceramics NESHAP

- Year 1

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

1. Applications N/ A

2. Survey and Studies N /A

3. Reporting Requirements

A. Read and understand rule requirements 2 1 2 3 6.0 0.3 0.6 $365

B. Required activities

Develop OM&M plan c,d 100 1 100 0 0 0 0 $0

C onduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct shuttle kiln

maintenance/inspections 20 1 20 0 0 0 0 $0

C. Create information See 3 B

D. Gather existing information See 3 B

E. Write report

Initial notification of applicability d 2 1 2 3 6.0 0.3 0.6 $365

Notificat ion of constr./reconstr

. d 2 1 2 0 0 0 0 $0

Notific ation of anticipated startup d 2 1 2 0 0 0 0 $0

No tification of actual startup d 2 1 2 0 0 0 0 $0

R equest APCD maintenance exemption d 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Notif ication of compliance status e 16 1 16 0 0 0 0 $0

Report of performance test (through

ERT) 4 1 4 0 0 0 0 $0

Notification of alternative fuel use f 2 1 2 0 0 0 0 $0

First compliance report 16 1 16 0 0 0 0 $0

Semi

- annual compliance reports

D eviations g 20 2 40 0 0 0 0 $0

### 14 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

No deviations g 8 2 16 0 0 0 0 $0

Report of alternative fuel use f 4 2 8 0 0 0 0 $0

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

Prepare for initial performance test c 24 1 24 0 0 0 0 $0

Prepare for repeat performance test c 24 1 24 0 0 0 0 $0

C. Implement activities

Attend initial performance test c,h 24 2.5 60 0 0 0 0 $0

Attend repeat performance test c,h 24 2.5 60 0 0 0 0 $0

D. Develop record system 40 6 240 0 0 0 0 $0

E. Time to enter information

Records of compliance data c 6 52 312 0 0 0 0 $0

Records of alternative fuel use 1 12 12 0 0 0 0 $0

Records of APCD

maintenance/inspections See 3B

Records of compliance with work

practices See 3B

Records of malfunctions 2 12 24 0 0 0 0 $0

F. Time to train personnel c,i 40 6 240 0 0 0 0 $0

G. Time to transmit / disclose information j 0.25 1 0.25 3 0.8 0.04 0.08 $46

TOTAL ANNUAL BURDEN AND COST

(SALARY) 13 0.6 1.3 $775

TOTAL ANNUAL NUMBER OF

RESPONSES k 3

### 15 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

CAPITAL COSTS:

Initial performance tests l $0

Repeat performance tests m $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: n

Initial performance tests $0

Repeat performance tests $0

Total annualized capital cost $0

ANNUAL O&M COSTS o

Photocopy/postage $66

Visible emissions tests $0

Total O&M cost $66

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $66

a A total of three existing major sources ( all sanitaryware) are expected to comply during the 3

- year ICR clearance period. N o 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 notificati on 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 altern ative 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 tra ining for 6 plant personnel.

j Time associated with transmitting reports. Equal to the number of respondents submitting reports.

### 16 k The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed i n 3E.

l Assumes EPA Method 5 for PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl and E PA 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 multip lying 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 photoco pying 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

. T he 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.

### 17 Table 2 . Annual R espondent Burden and Cost of Reporting and Recordkeeping Requirements of the Clay Ceramics NESHAP

- Year 2

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

1. Applications N/ A

2. Survey and Studies N /A

3. Reporting Requirements

A. Read and understand rule requirements 2 1 2 0 0 0 0 $0

B. Required activities

Develop OM&M plan c,d 100 1 100 0 0 0 0 $0

C onduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct shuttle kiln

maintenance/inspections 20 1 20 0 0 0 0 $0

C. Create information See 3 B

D. Gather existing information See 3 B

E. Write report

Initial notification of applicability d 2 1 2 0 0 0 0 $0

Notificat ion of constr./reconstr. d 2 1 2 0 0 0 0 $0

Notific ation of anticipated startup d 2 1 2 0 0 0 0 $0

No tification of actual startup d 2 1 2 0 0 0 0 $0

R equest APCD maintenance exemption d 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Notif ication of compliance status e 16 1 16 0 0 0 0 $0

Report of performance test (through

ERT) 4 1 4 0 0 0 0 $0

Notification of alternative fuel use f 2 1 2 0 0 0 0 $0

First compliance report 16 1 16 0 0 0 0 $0

Semi

- annual compliance reports

D eviations g 20 2 40 0 0 0 0 $0

### 18 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

No deviations g 8 2 16 0 0 0 0 $0

Report of alternative fuel use f 4 2 8 0 0 0 0 $0

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

Prepare for initial performance test c 24 1 24 0 0 0 0 $0

Prepare for repeat performance test c 24 1 24 0 0 0 0 $0

C. Implement activities

Attend initial performance test c,h 24 2.5 60 0 0 0 0 $0

Attend repeat performance test c,h 24 2.5 60 0 0 0 0 $0

D. Develop record system 40 6 240 0 0 0 0 $0

E. Time to enter information

Records of compliance data c 6 52 312 0 0 0 0 $0

Records of alternative fuel use 1 12 12 0 0 0 0 $0

Records of APCD

maintenance/inspections See 3B

Records of compliance with work

practices See 3B

Records of malfunctions 2 12 24 0 0 0 0 $0

F. Time to train personnel c,i 40 6 240 0 0 0 0 $0

G. Time to transmit / disclose information j 0.25 1 0.25 0 0 0 0 $0

TOTAL ANNUAL BURDEN AND COST

(SALARY) 0 0 0 $0

TOTAL ANNUAL NUMBER OF

RESPONSES k 0

### 19 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

CAPITAL COSTS:

Initial performance tests l $0

Repeat performance tests m $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: n

Initial performance tests $0

Repeat performance tests $0

Total annualized capital cost $0

ANNUAL O&M COSTS o

Photocopy/postage $0

Visible emissions tests $0

Total O&M cost $0

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $0

a A total of three existing major sources ( all sanitaryware) are expected to comply during the 3

- year ICR clearance period. N o 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 Assum es 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.

### 20 k The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed i n 3E.

l Assumes EPA Method 5 f or PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl and E PA 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 fac tor (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. T he 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.

### 21 Table 3 . Annual Respondent Burden and Cost of R eporting and Recordkeeping Requirements of the Clay Ceramics NESHAP

- Year 3

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

1. Applications N/ A

2. Survey and Studies N /A

3. Reporting Requirements

A. Read and understand rule requirements 2 1 2 0 0 0 0 $0

B. Required activities

Develop OM&M plan c,d 100 1 100 3 300 15 30 $18,237

C onduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct shuttle kiln

maintenance/inspections 20 1 20 0 0 0 0 $0

C. Create information See 3 B

D. Gather existing information See 3 B

E. Write report

Initial notification of applicability d 2 1 2 0 0 0 0 $0

Notificat ion of constr./reconstr. d 2 1 2 0 0 0 0 $0

Notific ation of anticipated startup d 2 1 2 0 0 0 0 $0

No tification of actual startup d 2 1 2 0 0 0 0 $0

R equest APCD maintenance exemption d 2 1 2 3 6.0 0.3 0.6 $365

Notification of performance test 2 1 2 0 0 0 0 $0

Notif ication of compliance status e 16 1 16 0 0 0 0 $0

Report of performance test (through

ERT) 4 1 4 0 0 0 0 $0

Notification of alternative fuel use f 2 1 2 0 0 0 0 $0

First compliance report 16 1 16 0 0 0 0 $0

Semi

- annual compliance reports

D eviations g 20 2 40 0 0 0 0 $0

### 22 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

No deviations g 8 2 16 0 0 0 0 $0

Report of alternative fuel use f 4 2 8 0 0 0 0 $0

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

Prepare for initial performance test c 24 1 24 0 0 0 0 $0

Prepare for repeat performance test c 24 1 24 0 0 0 0 $0

C. Implement activities

Attend initial performance test c,h 24 2.5 60 0 0 0 0 $0

Attend repeat performance test c,h 24 2.5 60 0 0 0 0 $0

D. Develop record system 40 6 240 3 720 36 72 $43,769

E. Time to enter information

Records of compliance data c 6 52 312 0 0 0 0 $0

Records of alternative fuel use 1 12 12 0 0 0 0 $0

Records of APCD

maintenance/inspections See 3B

Records of compliance with work

practices See 3B

Records of malfunctions 2 12 24 0 0 0 0 $0

F. Time to train personnel c,i 40 6 240 3 720 36 72 $43,769

G. Time to transmit / disclose information j 0.25 1 0.25 3 0.8 0.04 0.08 $46

TOTAL ANNUAL BURDEN AND COST

(SALARY) 1,747 87 175 $106,184

TOTAL ANNUAL NUMBER OF

RESPONSES k 3

### 23 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

CAPITAL COSTS:

Initial performance tests l $0

Repeat performance tests m $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: n

Initial performance tests $0

Repeat performance tests $0

Total annualized capital cost $0

ANNUAL O&M COSTS o

Photocopy/postage $66

Visible emissions tests $0

Total O&M cost $66

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $66

a A total of three existing major sources ( all sanitaryware) are expected to comply during the 3

- year ICR clearance period. N o 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 perfo rmance 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.

### 24 k The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed i n 3E.

l Assumes EPA Method 5 f or PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl and E PA 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 fac tor (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. T he 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.

### 25 Table 4. Summary of Respondent Burden and Cost of the Clay Ceramics NESHAP

- Years 1 t o 3

Year No.

responses Total hours Labor costs Non

- Labor Costs

Technical

hours Management

hours Clerical

Hours Capital Annualized

capital Annual

O&M Total annualized

cost

Year 1 3 13 0.6 1.3 15 $775 $0 $0 $66 $66

Year 2 0 0 0 0 0 $0 $0 $0 $0 $0

Year 3 3 1,747 87 175 2,009 $106,184 $0 $0 $66 $66

Totals 6 1,760 88 176 2,023 $106, 960 $0 $0 $132 $132

Average 2.0 674 $35,653 $0 $0 $44 $44

### 26 Table 5. Annual Burden and Cost to the Federal Government of the Clay Ceramics NESHAP

- Year 1

Activity (A) (B) (C) (D) (E) (F) (G) ( H )

EPA

person

hours per

occurrence No. of

occurrences

per plant

per year EPA person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=AxB) ( E=CxD ) ( E× 0.05) ( E× 0.1)

1. Attend initial performance test c 24 1 24 0 0 0 0 $0

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

3. Litigation e 2,080 1 2,080 0 0 0 0 $0

4. Excess emissions enforcement activities f 48 1 48 0 0 0 0 $0

5. Report review

Initial notification of applicability 2 1 2 3 6.0 0.3 0.6 $358

Notification of constr./reconstr. 2 1 2 0 0 0 0 $0

Notification of anticipated startup 2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Request for APCD maintenance exemption 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Notification of compliance status g 60 1 60 0 0 0 0 $0

Notification of alternative fuel use 2 1 2 0 0 0 0 $0

Repeat performance test report d 40 1 40 0 0 0 0 $0

First compliance report 4 1 4 0 0 0 0 $0

Semi

- annual compliance reports:

Deviations h 8 2 16 0 0 0 0 $0

No deviations h 2 2 4 0 0 0 0 $0

Report of alternative fuel use i 1 1 1 0 0 0 0 $0

TOTAL BURDEN AND COST (SALARY) 6.0 0.3 0.6 $358

Travel Expenses for Tests Attended j $0

TOTAL ANNUAL COST (SALARY +

EXPENSES) $358

### 27 a 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 per sonnel 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 on ce 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 trans portation expense per round trip to attend

performance tests.

N/A = Not applicable.

### 28 Table 6

. Annual Burden and Cos t to the Federal Government of the BSCP NESHAP

- Year 2

Activity (A) (B) (C) (D) (E) (F) (G) ( H )

EPA

person

hours per

occurrence No. of

occurrences

per plant

per year EPA person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=AxB) ( E=CxD ) ( E× 0.05) ( E× 0.1)

1. Attend initial performance test c 24 1 24 0 0 0 0 $0

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

3. Litigation e 2,080 1 2,080 0 0 0 0 $0

4. Excess emissions enforcement activities f 48 1 48 0 0 0 0 $0

5. Report review

Initial notification of applicability 2 1 2 0 0 0 0 $0

Notification of constr./ reconstr. 2 1 2 0 0 0 0 $0

Notification of anticipated startup 2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Request for APCD maintenance exemption 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Notification of compliance status g 60 1 60 0 0 0 0 $0

Notification of alternative fuel use 2 1 2 0 0 0 0 $0

Repeat performance test report d 40 1 40 0 0 0 0 $0

First compliance report 4 1 4 0 0 0 0 $0

Semi

- annual compliance reports:

Deviations h 8 2 16 0 0 0 0 $0

No deviations h 2 2 4 0 0 0 0 $0

Report of alternative fuel use i 1 1 1 0 0 0 0 $0

TOTAL BURDEN AND COST (SALARY) 0 0 0 $0

Travel Expenses for Tests Attended j $0

TOTAL ANNUAL COST (SALARY +

EXPENSES) $0

### 29 a 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 techn ical 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 Assu mes 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 th e retests.

g Notification of compliance status includes the performance test rep ort.

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.

### 30 Table 7

. Annual Burden and Cost to the Federal Government of the BSCP NESHAP

- Year 3

Activity (A) (B) (C) (D) (E) (F) (G) ( H )

EPA

person

hours per

occurrence No. of

occurrences

per plant

per year EPA person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=AxB) ( E=CxD ) ( E× 0.05) ( E× 0.1)

1. Attend initial performance test c 24 1 24 0 0 0 0 $0

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

3. Litigation e 2,080 1 2,080 0 0 0 0 $0

4. Excess emissions enforcement activities f 48 1 48 0 0 0 0 $0

5. Report review

Initial notification of applicability 2 1 2 0 0 0 0 $0

Notification of constr./reconstr. 2 1 2 0 0 0 0 $0

Notification of anticipated startup 2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Request for APCD maintenance exemption 2 1 2 3 6.0 0.3 0.6 $358

Notification of performance test 2 1 2 0 0 0 0 $0

Notification of compliance status g 60 1 60 0 0 0 0 $0

Notification of alternative fuel use 2 1 2 0 0 0 0 $0

Repeat performance test report d 40 1 40 0 0 0 0 $0

First compliance report 4 1 4 0 0 0 0 $0

Semi

- annual compliance reports:

Deviations h 8 2 16 0 0 0 0 $0

No deviations h 2 2 4 0 0 0 0 $0

Report of alternative fuel use i 1 1 1 0 0 0 0 $0

TOTAL BURDEN AND COST (SALARY) 6.0 0.3 0.6 $358

Travel Expenses for Tests Attended j $0

TOTAL ANNUAL COST (SALARY +

EXPENSES) $358

### 31 a 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 rate s: 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 te sts 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 requir ed 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 devi ations.

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 trans portation expense per round trip to attend

perfor mance tests.

N/A = Not applicable.

### 32 Table 8 . Summary of Burden and Cost to the Federal Government of the Clay Ceramics NESHAP

- Years 1 t o 3

Year Technical hours Management hours Clerical Hours Total hours Labor costs

Year 1 6.0 0.3 0.6 6.9 $358

Year 2 0 0 0 0 $0

Year 3 6.0 0.3 0.6 6.9 $358

Totals 12 0.6 1.2 14 $716

Average 4.6 $239

### 1

- 1 Attachment 1

Annual Burden and Cost

– Years 4 to 6

### 1

- 2 Table 1

- 1. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the Clay Ceramics NESHAP

- Year 4

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

1. Applications N/ A

2. Survey and Studies N /A

3. Reporting Requirements

A. Read and understand rule requirements 2 1 2 0 0 0 0 $0

B. Required activities

Develop OM&M plan c,d 100 1 100 0 0 0 0 $0

C onduct APCD maintenance/inspections 20 1 20 3 60 3.0 6.0 $3,647

Conduct shuttle kiln

maintenance/inspections 20 1 20 3 60 3.0 6.0 $3,647

C. Create information See 3 B

D. Gather existing information See 3 B

E. Write report

Initial notification of applicability d 2 1 2 0 0 0 0 $0

Notificat ion of constr./ reconstr. d 2 1 2 0 0 0 0 $0

Notific ation of anticipated startup d 2 1 2 0 0 0 0 $0

No tification of actual startup d 2 1 2 0 0 0 0 $0

R equest APCD maintenance exemption d 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 3 6.0 0.3 0.6 $365

Notif ication of compliance status e 16 1 16 3 48 2.4 4.8 $2,918

Report of performance test (through

ERT) 4 1 4 3 12 0.6 1.2 $729

Notification of alternative fuel use f 2 1 2 3 6.0 0.3 0.6 $365

First compliance report 16 1 16 3 48 2.4 4.8 $2,918

Semi

- annual compliance reports

D eviations g 20 2 40 0 0 0 0 $0

### 1

- 3 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

No deviations g 8 2 16 0 0 0 0 $0

Report of alternative fuel use f 4 2 8 0.3 2.4 0.1 0.2 $146

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

Prepare for initial performance test c 24 1 24 3 72 3.6 7.2 $4,377

Prepare for repeat performance test c 24 1 24 0.3 7.2 0.4 0.7 $438

C. Implement activities

Attend initial performance test c,h 24 2.5 60 3 180 9.0 18 $10,942

Attend repeat performance test c,h 24 2.5 60 0.3 18 0.9 1.8 $1,094

D. Develop record system 40 6 240 0 0 0 0 $0

E. Time to enter information

Records of compliance data c 6 52 312 3 936 47 94 $56,899

Records of alternative fuel use 1 12 12 3 36 1.8 3.6 $2,188

Records of APCD

maintenance/inspections See 3B

Records of compliance with work

practices See 3B

Records of malfunctions 2 12 24 3 72 3.6 7.2 $4,377

F. Time to train personnel c,i 40 6 240 0 0 0 0 $0

G. Time to transmit / disclose information j 0.25 1 0.25 3 0.8 0.04 0.08 $46

TOTAL ANNUAL BURDEN AND COST

(SALARY) 1,564 78 156 $95,096

TOTAL ANNUAL NUMBER OF

RESPONSES k 16

### 1

- 4 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

CAPITAL COSTS:

Initial performance tests l $102,000

Repeat performance tests m $10,200

Total capital cost $112,200

ANNUALIZED CAPITAL COSTS: n

Initial performance tests $24,880

Repeat performance tests $2,488

Total annualized capital cost $27,368

ANNUAL O&M COSTS o

Photocopy/postage $343

Visible emissions tests $20,890

Total O&M cost $21,233

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $27,711

a A total of three existing major sources ( all sanitaryware) are expected to comply during the 3

- year ICR clearance period. N o 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

- hou rs, 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 person nel.

j Time associated with transmitting reports. Equal to the number of respondents submitting reports.

### 1

- 5 k The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed i n 3E.

l Assumes EPA Meth od 5 for PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl and E PA 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 recove ry 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 estima ted 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. T he O&M cost associate d 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.

### 1

- 6 Table 1

- 2 . Annual Respondent Burden and C ost of Reporting and Recordkeeping Requirements of the Clay Ceramics NESHAP

- Year 5

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

1. Applications N/ A

2. Survey and Studies N /A

3. Reporting Requirements

A. Read and understand rule requirements 2 1 2 0 0 0 0 $0

B. Required activities

Develop OM&M plan c,d 100 1 100 0 0 0 0 $0

C onduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct shuttle kiln

maintenance/inspections 20 1 20 0 0 0 0 $0

C. Create information See 3 B

D. Gather existing information See 3 B

E. Write report

Initial notification of applicability d 2 1 2 0 0 0 0 $0

Notificat ion of constr./reconstr. d 2 1 2 0 0 0 0 $0

Notific ation of anticipated startup d 2 1 2 0 0 0 0 $0

No tification of actual startup d 2 1 2 0 0 0 0 $0

R equest APCD maintenance exemption d 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Notif ication of compliance status e 16 1 16 0 0 0 0 $0

Report of performance test (through

ERT) 4 1 4 0 0 0 0 $0

Notification of alternative fuel use f 2 1 2 0 0 0 0 $0

First compliance report 16 1 16 0 0 0 0 $0

Semi

- annual compliance reports

D eviations g 20 2 40 0.5 18 0.9 1.8 $1,094

### 1

- 7 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

No deviations g 8 2 16 2.6 41 2.0 4.1 $2,480

Report of alternative fuel use f 4 2 8 0.3 2.4 0.1 0.2 $146

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

Prepare for initial performance test c 24 1 24 0 0 0 0 $0

Prepare for repeat performance test c 24 1 24 0 0 0 0 $0

C. Implement activities

Attend initial performance test c,h 24 2.5 60 0 0 0 0 $0

Attend repeat performance test c,h 24 2.5 60 0 0 0 0 $0

D. Develop record system 40 6 240 0 0 0 0 $0

E. Time to enter information

Records of compliance data c 6 52 312 3 936 47 94 $56,899

Records of alternative fuel use 1 12 12 3 36 1.8 3.6 $2,188

Records of APCD

maintenance/inspections See 3B

Records of compliance with work

practices See 3B

Records of malfunctions 2 12 24 3 72 3.6 7.2 $4,377

F. Time to train personnel c,i 40 6 240 0 0 0 0 $0

G. Time to transmit / disclose information j 0.25 1 0.25 3 0.8 0.04 0.08 $46

TOTAL ANNUAL BURDEN AND COST

(SALARY) 1,106 55 111 $67,230

TOTAL ANNUAL NUMBER OF

RESPONSES k 7

### 1

- 8 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

CAPITAL COSTS:

Initial performance tests l $102,000

Repeat performance tests m $10,200

Total capital cost $112,200

ANNUALIZED CAPITAL COSTS: n

Initial performance tests $24,880

Repeat performance tests $2,488

Total annualized capital cost $27,368

ANNUAL O&M COSTS o

Photocopy/postage $145

Visible emissions tests $20,890

Total O&M cost $21,035

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $27,513

a A total of three existing major sources ( all sanitaryware) are expected to comply during the 3

- year ICR clearance period. N o 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 cl erical 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 te sting 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.

### 1

- 9 k The total annu al number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E.

l Assumes EPA Method 5 for PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl and E PA 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. T he 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.

### 1

- 10 Table 1

- 3 . Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the Clay Ceramics NES HAP

- Year 6

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

1. Applications N/ A

2. Survey and Studies N /A

3. Reporting Requirements

A. Read and understand rule requirements 2 1 2 0 0 0 0 $0

B. Required activities

Develop OM&M plan c,d 100 1 100 0 0 0 0 $0

C onduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct shuttle kiln

maintenance/inspections 20 1 20 0 0 0 0 $0

C. Create information See 3 B

D. Gather existing information See 3 B

E. Write report

Initial notification of applicability d 2 1 2 0 0 0 0 $0

Notificat ion of constr./reconstr. d 2 1 2 0 0 0 0 $0

Notific ation of anticipated startup d 2 1 2 0 0 0 0 $0

No tification of actual startup d 2 1 2 0 0 0 0 $0

R equest APCD maintenance exemption d 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Notif ication of compliance status e 16 1 16 0 0 0 0 $0

Report of performance test (through

ERT) 4 1 4 0 0 0 0 $0

Notification of alternative fuel use f 2 1 2 0 0 0 0 $0

First compliance report 16 1 16 0 0 0 0 $0

Semi

- annual compliance reports

D eviations g 20 2 40 0.5 18 0.9 1.8 $1,094

### 1

- 11 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

No deviations g 8 2 16 2.6 41 2.0 4.1 $2,480

Report of alternative fuel use f 4 2 8 0.3 2.4 0.1 0.2 $146

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

Prepare for initial performance test c 24 1 24 0 0 0 0 $0

Prepare for repeat performance test c 24 1 24 0 0 0 0 $0

C. Implement activities

Attend initial performance test c,h 24 2.5 60 0 0 0 0 $0

Attend repeat performance test c,h 24 2.5 60 0 0 0 0 $0

D. Develop record system 40 6 240 0 0 0 0 $0

E. Time to enter information

Records of compliance data c 6 52 312 3 936 47 94 $56,899

Records of alternative fuel use 1 12 12 3 36 1.8 3.6 $2,188

Records of APCD

maintenance/inspections See 3B

Records of compliance with work

practices See 3B

Records of malfunctions 2 12 24 3 72 3.6 7.2 $4,377

F. Time to train personnel c,i 40 6 240 0 0 0 0 $0

G. Time to transmit / disclose information j 0.25 1 0.25 3 0.8 0.04 0.08 $46

TOTAL ANNUAL BURDEN AND COST

(SALARY) 1,106 55 111 $67,230

TOTAL ANNUAL NUMBER OF

RESPONSES k 7

### 1

- 12 Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

h our s per

occurrence No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year a Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=A × B) (E=C × D) (E × 0.05) (E × 0.1)

CAPITAL COSTS:

Initial performance tests l $102,000

Repeat performance tests m $10,200

Total capital cost $112,200

ANNUALIZED CAPITAL COSTS: n

Initial performance tests $24,880

Repeat performance tests $2,488

Total annualized capital cost $27,368

ANNUAL O&M COSTS o

Photocopy/postage $145

Visible emissions tests $20,890

Total O&M cost $21,035

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $27,513

a A total of three existing major sources ( all sanitaryware) are expected to comply during the 3

- year ICR clearance period. N o 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 cl erical 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 te sting 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.

### 1

- 13 k The total annu al number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E.

l Assumes EPA Method 5 for PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl and E PA 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 (year s) . 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. T he O&M cost associated with VE

monitoring includes VE training for two people every 5 years, conducting the 15

- minute VE test and preparing fo r/documenting the VE test (occurs after 3

- year ICR

clearance period).

N/A = Not Applicable.

### 1

- 14 Table 1

- 4. Summary of Respondent Burden and Cost of the Clay Ceramics NESHAP

- Years 4 t o 6

Year No.

responses Total hours Labor costs Non

- Labor Costs

Technical

hours Management

hours Clerical

Hours Capital Annualized

capital Annual

O&M Total annualized

cost

Year 4 16 1,564 78 156 1,799 $95,096 $112,200 $27,368 $21,233 $48,601

Year 5 7 1,106 55 111 1,272 $67,230 $112,200 $27,368 $21,035 $48,403

Year 6 7 1,106 55 111 1,272 $67,230 $112,200 $27,368 $21,035 $48,403

Totals 29 3,776 189 378 4,343 $229,557 $336,600 $82,104 $63,304 $145,408

Average 10 1,448 $76,519 $112,200 $27,368 $21,101 $48,469

### 1

- 15 Table 1

- 5. Annual Burden and Cost to the Federal Government of the Clay Ceramics NESHAP

- Year 4

Activity (A) (B) (C) (D) (E) (F) (G) ( H )

EPA

person

hours per

occurrence No. of

occurrences

per plant

per year EPA person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=AxB) ( E=CxD ) ( E× 0.05) ( E× 0.1)

1. Attend initial performance test c 24 1 24 0.3 7.2 0.4 0.7 $429

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0.03 0.2 0.01 0.02 $14

Retesting 24 1 24 0.03 0.7 0.04 0.07 $43

3. Litigation e 2,080 1 2,080 0.03 62 3.1 6.2 $3,722

4. Excess emissions enforcement activities f 48 1 48 0.2 7.2 0.4 0.7 $429

5. Report review

Initial notification of applicability 2 1 2 0 0 0 0 $0

Notification of constr./reconstr. 2 1 2 0 0 0 0 $0

Notification of anticipated startup 2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Request for APCD maintenance exemption 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 3 6.0 0.3 0.6 $358

Notification of compliance status g 60 1 60 3 180 9.0 18 $10,737

Notification of alternative fuel use 2 1 2 3 6.0 0.3 0.6 $358

Repeat performance test report d 40 1 40 0.3 12 0.6 1.2 $716

First compliance report 4 1 4 3 12 0.6 1.2 $716

Semi

- annual compliance reports:

Deviations h 8 2 16 0 0 0 0 $0

No deviations h 2 2 4 0 0 0 0 $0

Report of alternative fuel use i 1 1 1 0.3 0.3 0.02 0.03 $18

TOTAL BURDEN AND COST (SALARY) 294 15 29 $17,540

Travel Expenses for Tests Attended j $240

TOTAL ANNUAL COST (SALARY +

EXPENSES) $17,780

### 1

- 16 a 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 rate s: 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 te sts 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 requir ed 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 devi ations.

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 trans portation expense per round trip to attend

perfor mance tests.

N/A = Not applicable.

### 1

- 17 Table 1

- 6

. Annual Burden and Cost to the Federal Government of the BSCP NESHAP

- Year 5

Activity (A) (B) (C) (D) (E) (F) (G) ( H )

EPA

person

hours per

occurrence No. of

occurrences

per plant

per year EPA person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=AxB) ( E=CxD ) ( E× 0.05) ( E× 0.1)

1. Attend initial performance test c 24 1 24 0 0 0 0 $0

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

3. Litigation e 2,080 1 2,080 0.03 62 3.1 6.2 $3,722

4. Excess emissions enforcement activities f 48 1 48 0.2 7.2 0.4 0.7 $429

5. Report review

Initial notification of applicability 2 1 2 0 0 0 0 $0

Notification of constr./reconstr. 2 1 2 0 0 0 0 $0

Notification of anticipated startup 2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Request for APCD maintenance exemption 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Notification of compliance status g 60 1 60 0 0 0 0 $0

Notification of alternative fuel use 2 1 2 0 0 0 0 $0

Repeat performance test report d 40 1 40 0 0 0 0 $0

First compliance report 4 1 4 0 0 0 0 $0

Semi

- annual compliance reports:

Deviations h 8 2 16 0.5 7.2 0.4 0.7 $429

No deviations h 2 2 4 2.6 10 0.5 1.0 $608

Report of alternative fuel use i 1 1 1 0.3 0.3 0.02 0.03 $18

TOTAL BURDEN AND COST (SALARY) 87 4.4 8.7 $5,207

Travel Expenses for Tests Attended j $75

TOTAL ANNUAL COST (SALARY +

EXPENSES) $5,282

### 1

- 18 a 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 rate s: 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 te sts 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 requir ed 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 devi ations.

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 trans portation expense per round trip to attend

perfor mance tests.

N/A = Not applicable.

### 1

- 19 Table 1

- 7

. Annual Burden and Cost to the Federal Government of the BSCP NESHAP

- Year 6

Activity (A) (B) (C) (D) (E) (F) (G) ( H )

EPA

person

hours per

occurrence No. of

occurrences

per plant

per year EPA person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ b

(C=AxB) ( E=CxD ) ( E× 0.05) ( E× 0.1)

1. Attend initial performance test c 24 1 24 0 0 0 0 $0

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

3. Litigation e 2,080 1 2,080 0.03 62 3.1 6.2 $3,722

4. Excess emissions enforcement activities f 48 1 48 0.2 7.2 0.4 0.7 $429

5. Report review

Initial notification of applicability 2 1 2 0 0 0 0 $0

Notification of constr./reconstr. 2 1 2 0 0 0 0 $0

Notification of anticipated startup 2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Request for APCD maintenance exemption 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Notification of compliance status g 60 1 60 0 0 0 0 $0

Notification of alternative fuel use 2 1 2 0 0 0 0 $0

Repeat performance test report d 40 1 40 0 0 0 0 $0

First compliance report 4 1 4 0 0 0 0 $0

Semi

- annual compliance reports:

Deviations h 8 2 16 0.5 7.2 0.4 0.7 $429

No deviations h 2 2 4 2.6 10 0.5 1.0 $608

Report of alternative fuel use i 1 1 1 0.3 0.3 0.02 0.03 $18

TOTAL BURDEN AND COST (SALARY) 87 4.4 8.7 $5,207

Travel Expenses for Tests Attended j $75

TOTAL ANNUAL COST (SALARY +

EXPENSES) $5,282

### 1

- 20 a 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 rate s: 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 te sts 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 requir ed 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 trans portation expense per round tr ip to attend

performance tests.

N/A = Not applicable.

### 1

- 21 Table 1

- 8 . Summary of Burden and Cost to the Federal Government of the Clay Ceramics NESHAP

- Years 4 t o 6

Year Technical hours Management hours Clerical Hours Total hours Labor costs

Year 4 294 15 29 338 $17,780

Year 5 87 4.4 8.7 100 $5,282

Year 6 87 4.4 8.7 100 $5,282

Totals 469 23 47 539 $28,345

Average 180 $9,448