SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal), 

EPA ICR Number 2040.06, OMB Control Number 2060-0515.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Refractory

Products Manufacturing were proposed on June 20, 2002, and promulgated on April 16, 2003. 

These regulations apply to each existing refractory products manufacturing which produces 

refractory bricks, refractory shapes, kiln furniture, crucibles, and other materials used as linings 

for boilers, kilns, and other processing units and equipment where extreme temperature, 

corrosions, and abrasion would destroy other materials. The rule applies to facilities that 

manufacture refractory products and use organic hazardous air pollutant (HAP), chromium 

refractory, and clay refractory products. The new or reconstructed affected sources are shape 

dryers, curing ovens, and kilns that are used to manufacture refractory products and that use 

organic HAP; shape preheaters, pitch working tanks, defumers, and coking ovens used to 

produce pitch-impregnated refractory products; kilns that are used to manufacture chromium 

refractory products; and kilns that are used to manufacture clay refractory products. New 

facilities include those that commenced construction or reconstruction after the date of proposal. 

This information is being collected to assure compliance with 40 CFR Part 63, Subpart SSSSS.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

 Based on our consultations with industry representatives, there is an average of one

affected facilities at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).
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The burden to the “Affected Public” may be found in Table 1: Annual Respondent 

Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart 

SSSSS) (Renewal). The “Federal Government” burden is attributed entirely to work performed 

by federal employees or government contractors and may be found in Table 2: Average Annual 

EPA Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, 

Subpart SSSSS) (Renewal).

Over the next three years, we estimate eight respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. This 

estimate was obtained from the previous ICR, and has been verified during the current renewal 

through an online search of company websites. We assume only companies with more than 500 

employees (i.e. large businesses) are major sources subject to the rule. Based on this assumption, 

we determine that the current estimate of eight respondent is a reasonable value. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.” 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, particulate matter emissions from refractory products 

manufacturing cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health or welfare. Therefore, the NESHAP were promulgated for this source 

category at 40 CFR Part 63, Subpart SSSSS.
3

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the

applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard are being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart

SSSSS.

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no 

duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations
4

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted both the Refractories Institute at (216) 241-7333 and the Allied Mineral 

Products at (614) 876-0244. EPA did not receive comments from the consultation. 

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with 

the Part 70 permit program and the five year statute of limitations on which the permit program 

is based. The retention of records for five years allows EPA to establish the compliance history 

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency 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, 
5

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are refractory products 

manufacturing facilities. The United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards and the corresponding North American Industry

Classification System (NAICS) codes are listed in the table below.

Standard (40 CFR Part 63, Subpart SSSSS) SIC Codes NAICS Codes

Clay refractory manufacturing 3255 327124

Nonclay refractory manufacturing 3297 327125

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS). 

A source must make the following reports:

Notifications/Reports

Initial notification 63.9(b)(2) and (3), 

63.5, 63.9812(b)-(c)

Notification of performance test 63.7(b)-(c), 63.9(e), 

and 63.9812(d)

Notification of compliance status 63.9(h), 63.10(d)(2), 

and 63.9812(e)

Notification of alternative fuel use 63.9812(f)

Startup, shutdown, malfunction 63.10(d)(5), 
6

Notifications/Reports

63.9814(c)(4)

No deviations/no continuous monitoring system (CMS) out of control 63.9814(c)(5)-(6)

Deviations/out of control CMS 63.9814(d)-(f)

Report of alternative fuel use 63.9814(g)

A source must keep the following records:

Recordkeeping

Record of startup, shutdown, and malfunctions 63.6(e)(3),63.10(b)(

2),63.9816(a)(2)

Records of performance tests 63.10(b)(2)(viii), 

63.9816(a)(3)

Initial notification or notification of compliance status 63.10(b)(2)(xiv), 

63.9816(a)(1)

Record of each CMS

63.8(d)(3), 

63.8(f)(6)(i), 

63.8(g), 

63.10(b)(2)(vi)-(xi), 

and 63.9816(c)

Records are required to be retained for five years 63.10(b)(1)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

Perform initial performance test, Reference Method 25A test, and repeat performance tests if 
7

Respondent Activities

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could 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 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 
8

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

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/operator for five

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Refractory

Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The 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.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 
9

and reporting requirements is estimated to be 343 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)1

Continuous 

parameter 

monitoring 

system

$16,820 0 $0 $380 8 $3,040

Total $3,040

1 Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 
10

The total operation and maintenance (O&M) costs for this ICR are $3,040. This is the 

total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $3,040. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$8,170. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2015 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for 

Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

eight existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is eight per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
11

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1

0 8 0 0 8

2

0 8 0 0 8

3

0 8 0 0 8

Average 0 8 0 0 8

1

New respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is eight. 

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of applicability 0 1 0 0

Notification of 

construction/reconstruction 0 1 0 0

Notification of anticipated 

startup 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of performance 

test 0 1 0 0

Notification of compliance 

status 0 1 0 0

Notification of intent to use 

alternative fuel 3 1 0 3

Report of deviations 1 1 0 1

Report of no deviations 7 2 0 14
12

Total Annual Responses

Startup, shutdown, 

malfunction report 1 1 0 1

Report of alternative fuel use 3 1 0 3

Total 22

The number of Total Annual Responses is 22. 

The total annual labor costs are $34,000. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NESHAP for Refractory Products 

Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 343. Details regarding these estimates may be found in 

Table 1: Annual Respondent Burden and Cost – NESHAP for Refractory Products 

Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 16 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $3,040. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 179

labor hours at a cost of $8,170. See Table 2: Average Annual EPA Burden and Cost – NESHAP 

for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 
13

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

The increase in burden from the most recently approved ICR is due to an adjustment in 

the labor rates and updates to assumptions in the burden estimates. This ICR uses updated labor 

rates from the Bureau of Labor Statistics to calculate all burden costs.

The additional assumptions in the burden estimates included in this ICR are that all 

respondents will have to read and re-familiarize with the rule requirements annually, and total 

annual burdens and costs have been rounded to 3 significant values.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 16 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 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, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2014-0088. 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 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., 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) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 
14

Number EPA-HQ-OECA-2014-0088 and OMB Control Number 2060-0515 in any

correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart 

SSSSS) (Renewal)

Burden item

(A)

Person-hours 

per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year 

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year 

(E=CxD)

(F)

Management 

personhours per 

year 

(Ex0.05)

(G)

Clerical 

personhours per 

year 

(Ex0.1)

(H)

Cost, $ b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Familiarize with rule requirement 0.5 1 0.5 8 4 0.2 0.4 $462.58 

B. Required activities

Startup, shutdown, malfunction plan 32 1 32 0 0 0 0 $0 

Operation, maintenance, monitoring 

plan 32 1 32 00 0 0 $0 

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Notification of applicability 2 1 2 0 0 0 0 $0 

Notification of construction/ 

reconstruction 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 

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

Notification of compliance status 16 1 16 0 0 0 0 $0 

Notification of intent to use alternative fuel 

c

 2 1 2

3

6 0.3 0.6 $693.87

Report of deviations d

16 1 16 1 16 0.8 1.6 $1,850.33
16

Burden item

(A)

Person-hours 

per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year 

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year 

(E=CxD)

(F)

Management 

personhours per 

year 

(Ex0.05)

(G)

Clerical 

personhours per 

year 

(Ex0.1)

(H)

Cost, $ b

Report of no deviations e

8 2 16 7 112 5.6 11.2 $12,952.30

Startup, shutdown, malfunction report f 8 1 8 1 8 0.4 0.8 $925.16

Report of alternative fuel use g

4 1 4 3 12 0.6 1.2 $1,387.75

Subtotal for Reporting Requirements 182 $18,271.99

4. Recordkeeping Requirements

A. Familiarize with rule requirement h

4 1 4 8 32 1.6 3.2 $3,700.66

B. Plan activities See 4E

C. Implement activities See 4E

D. Develop record system See 4E

E. Time to enter information

Records of all information required by 

standards i

0.25 52 13 8 104 5.2 10.4 $12,027.13

F. Time to train personnel 20 1 20 0 0 0 0 $0 

G. Time to adjust existing ways to comply 

with previously applicable requirements N/A

H. Time to transmit or disclose information 

j

 0.25 2 0.5 8 4 0.2 0.4 $463 

I. Time for audits N/A

Subtotal for Recordkeeping 

Requirements 161 $16,190.37 

TOTAL ANNUAL BURDEN AND COSTS: k 343 $34,000 

Capital and O&M Cost (see Section 6(b)(iii)): k $3,040

TOTAL COST: k $37,000 
17

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be eight. There will be no additional new source per year that will 

become subject to the rule over the three-year period of this ICR. 

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and 

$51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2: Civilian 

Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the 

benefit packages available to those employed by private industry.

c

 We have assumed that three respondent will use alternative fuel once per year and will have to submit notification of intent to use alternative fuel.

d

 We have assumed that one respondent will report deviation once a year.

e

 We have assumed that seven respondents will report no deviation on a semiannual basis.

f

 It is assumed that one respondents will have a startup, shutdown, malfunction occur.

g We have assumed that three respondents will report on alternative fuel usage once a year.

h

 We have assumed that it will take 4 hours for each respondent to read and familiarize with the rule requirements.

i

 We have assumed that information will be recorded once per week for 52 weeks per year.

j

 We have assumed that it will take 0.25 hours for information to be transmitted or disclosed.

k

 Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.
18

Table 2: Average Annual EPA Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart 

SSSSS) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year 

(C=AxB)

(D)

Plants 

per 

year a

(E)

Technical 

personhours per 

year 

(E=CxD)

(F)

Management 

personhours per 

year 

(Ex0.05)

(G)

Clerical 

personhours per 

year 

(Ex0.1)

(H)

Cost, $ b

Attend initial performance test 40 1 40 0 0 0 0 $0 

Attend repeat performance test

Retesting preparation 8 1 8 0 0 0 0 $0 

Retesting 40 1 40 0 0 0 0 $0 

Report Review

Notification of applicability 2 1 2 0 0 0 0 $0 

Notification of 

construction/reconstruction 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 

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

Notification of compliance status 2 1 2 0 0 0 0 $0 

Notification of intent to use alternative 

fuel c

2 1 2 3 6 0.3 0.6 $314.04 

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

Semiannual compliance reports

Deviation d

16 1 16 1 16 0.8 1.6 $837.44 

No Deviation e

8 2 16 7 112 5.6 11.2 $5,862.08 

Startup, shutdown, malfunction report f

16 1 16 1 16 0.8 1.6 $837.44 

Notification of alternative fuel use g

2 1 2 3 6 0.3 0.6 $314.04 
19

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year 

(C=AxB)

(D)

Plants 

per 

year a

(E)

Technical 

personhours per 

year 

(E=CxD)

(F)

Management 

personhours per 

year 

(Ex0.05)

(G)

Clerical 

personhours per 

year 

(Ex0.1)

(H)

Cost, $ b

TOTAL ANNUAL BURDEN AND 

COST h179 $8,170 

Assumptions:

a We have assumed that the average number of respondents that will be subject to the rule will be eight. There will be no additional new source per year that will 

become subject to the rule over the three-year period of this ICR.

b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial 

rate of $62.90 (GS-13, Step 5, $39.31 x 1.6), Technical rate of $46.67 (GS-12, Step 1, $29.17 x 1.6), and Clerical rate of $25.25 (GS-6, Step 3, $15.78 x 1.6). 

These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.

c

 We have assumed that three respondent will use alternative fuel once per year and will have to submit notification of intent to use alternative fuel.

d

 We have assumed that one respondent will report deviation once a year.

e

 We have assumed that seven respondents will report no deviation on a semiannual basis.

f

 It is assumed that one respondents will have a startup, shutdown, malfunction occur.

g We have assumed that three respondents will report on alternative fuel usage once a year.

h

 Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.