1

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

National Emission Standards for Hazardous Air Pollutants for Clay Ceramics

Manufacturing

(40 CFR Part 63, Subpart KKKKK)

September 2015

Part A of the Supporting Statement

1.0 Identification of the Information Collection

1(a) Title and Number of the Information Collection

“National Emission Standards for Hazardous Air Pollutants for Clay Ceramics

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

request (ICR). The EPA ICR tracking number is 2510.01.

1(b) Short Characterization

Potential respondents are owners or operators of new and existing sources at clay ceramic 

manufacturing facilities. A clay ceramics facility manufactures pressed floor tile, pressed wall 

tile, or sanitaryware (e.g., sinks and toilets). Clay ceramics facilities typically form, dry and fire 

tile or sanitaryware products that are composed of clay, shale and various additives. Spray dryers 

are used during the forming process at tile facilities to process the ceramic mix into a powder to 

allow tile pressing. Dryers are used to reduce the moisture content of the ceramic products prior 

to firing. Glazes are applied to some tile and sanitaryware products, with glaze spraying 

accounting for all glazing emissions. Kilns are used to fire the ceramic products and include 

ceramic tile roller kilns and sanitaryware tunnel and shuttle kilns. The rule applies to all existing, 

new and reconstructed affected sources, which include the kilns, glaze spray operations, ceramic 

tile spray dryers and floor tile press dryers. (Wall tile press dryers and sanitaryware ware dryers, 

with no measurable emissions, are not covered.)

Consistent with the General Provisions for NESHAP for Source Categories (40 CFR 

part 63, subpart A), respondents do not include the owner or operator of any facility that is not a 

major source of hazardous air pollutant (HAP) emissions (i.e., an area source). A major source of 

HAP is a plant site that emits or has the potential to emit any single HAP at a rate of 10 tons or 

more per year or any combination of HAP at a rate of 25 tons or more per year. There are three

clay ceramics facilities that are currently major sources of HAP. No new clay ceramics facilities 

or affected sources are expected to be constructed in the near future, and existing capacity is 

assumed to be sufficient to cover any short-term increases in production.

Respondents must submit one-time notifications of applicability and reports on initial 

performance test results. Respondents must also develop and implement an operation, 

maintenance and monitoring (OM&M) plan covering each affected source and each emission 

control device used for compliance with the rule. Semiannual reports for periods of emission 

limitation deviations (or reports certifying that no deviations have occurred) also are required.
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General requirements applicable to all NESHAP include records of applicability determinations,

performance test results, deviations, monitoring records and all other information needed to 

determine compliance with the applicable standard. Records and reports must be retained for a 

minimum of 5 years. The most recent 2 years of data must be retained onsite. The remaining 

3 years of data may be retained offsite.

Subpart KKKKK requires respondents to monitor the type of fuel used and maintain 

records. Respondents also must monitor control device operating parameters to assure 

continuous compliance with the rule. The rule includes the following parameter monitoring 

requirements:

• Tunnel or roller kilns:

• Dry injection fabric filter (DIFF)/dry lime scrubber/fabric filter (DLS): Lime injection 

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

• Wet scrubbers: Pressure drop, scrubber liquid pH, scrubber liquid flow rate and

chemical addition rate (if applicable)

• Activated carbon injection: Carbon flow rate

• No control device: Periodic VE determinations, kiln stack temperature, and kiln 

process rate monitoring (if their last calculated total facility maximum potential 

hydrogen chloride-equivalent emissions were above the proposed acid gas healthbased emission limit)

• Glaze spray operations:

• Fabric filters: Either periodic VE determinations or bag leak detectors

• Wet scrubbers: Pressure drop and scrubber liquid flow rate

• Water curtains: Daily inspections to verify the presence of water flow to the wet 

control system; weekly visual inspections of the system ductwork and control 

equipment for leaks and annual inspections of the interior of the control equipment (if 

applicable) to determine the structural integrity and condition of the control 

equipment

• Baffles: Annual visual inspection of the baffles to confirm the baffles are in place

• Spray dryers/floor tile press dryers: Operating temperature

Respondents also must maintain records of specific information needed to determine that the 

standards are being achieved and maintained.

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is required under section 112(d) of the Clean Air Act (CAA), as amended, to 

establish emission standards for each category or subcategory of major and area sources of HAP 

listed for regulation in section 112(b). These standards are applicable to new or existing sources 

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

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

ensure compliance with a section 112 emission standard. Section 114(a)(1) specifically states 
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that the Administrator may require any owner or operator subject to any requirement of the CAA 

to:

(A) establish and maintain such records; (B) make such reports; (C) install, 

use, and maintain such monitoring equipment, and use such audit procedures, 

or methods; (D) sample such emissions; (E) keep records on control equipment 

parameters, production variables or other indirect data when direct monitoring 

of emissions is impractical; (F) submit compliance certifications in accordance 

with section 114(a)(3); and (G) provide such other information as the 

Administrator may reasonably require.

The predominant HAP emitted from clay ceramics manufacturing facilities include 

hydrogen fluoride (HF), hydrogen chloride (HCl) and metals (antimony, arsenic, beryllium, 

cadmium, chromium, cobalt, mercury, manganese, nickel, lead and selenium). In the 

Administrator’s judgment, the pollutants emitted from clay ceramics manufacturing facilities

cause or contribute significantly to air pollution that may reasonably be anticipated to endanger 

public health. Consequently, NESHAP for this source category were promulgated at 40 CFR 

part 63, subpart KKKKK on May 16, 2003. (Note: The clay ceramics manufacturing source 

category was originally included in the clay products manufacturing industry source category in 

the initial list of source categories published on July 16, 1992 (57 FR 31576). The clay ceramics 

manufacturing source category was subsequently identified as a separate and distinct source 

category and was added to the list of source categories on July 22, 2002 (67 FR 47894).)

The clay ceramics standards were challenged by the Sierra Club and subsequently 

vacated by the United States Circuit Court for the District of Columbia on March 13, 2007, due 

to issues associated with the methodology used to determine the minimum regulatory “floors” 

for new and existing units. The EPA and Sierra Club later negotiated a consent decree to settle 

the litigation and set forth proposal and promulgation deadlines for reestablishing standards for 

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

2(b) Practical Utility/Users of the Data

The information collected from respondents will be used by EPA enforcement personnel 

to: (1) identify new, modified, reconstructed and existing sources subject to the standards; 

(2) ensure that maximum achievable control technology (MACT) is being properly applied; and 

(3) ensure that the emission control devices are being properly operated and maintained on a 

continuous basis. In addition, records and reports are necessary to enable the EPA to identify 

facilities that may not be in compliance with the standards. Based on the reported information, 

the EPA can decide which facilities should be inspected and what records or processes should be 

inspected at these facilities. The records that facilities maintain will indicate to the EPA whether 

the owners or operators are in compliance with the emission limitations (including emission 

limits, operating limits) and work practice standards. Much of the information the EPA would 

need to determine compliance would be recorded and retained onsite at the facility. Such 

information would be reviewed by enforcement personnel during an inspection and would not 

need to be routinely reported to the EPA.
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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 and is not expected to be required by any other EPA rulemaking 

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

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

or local agency may be provided to the Administrator in lieu of the report required by the 

standards.

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

This section is not applicable because this is a rule-related ICR. Nevertheless, the ICR 

will be available for public review during the public comment period following publication of 

the proposed rule in the Federal Register.

3(c) Consultations

Representatives of an industry trade association (Tile Council of North America) and 

companies in the ceramic tile and sanitaryware industry were consulted during the development 

of the rule, and several meetings and teleconferences have been held with them during this time. 

During these meetings, the representatives were given the opportunity to comment on the 

regulatory approach. The major topics of these discussions included rule applicability, 

subcategories, testing approach, emissions data, MACT floor approach, confidentiality concerns, 

source category delisting and alternative standards. No specific information was provided to the 

representatives with respect to burden estimates. Others consulted for information during the 

development process for the proposed standards included air pollution control device vendors 

(Encertec, McGill AirClean, Solios Environment, W.L. Gore and Associates and Cabot Norit 

Activated Carbon).

The EPA provided a 90-day public comment period following proposal of the clay 

ceramics manufacturing NESHAP, during which all affected parties were given the opportunity 

to comment on the proposed rule. The EPA has considered the comments received and, as 

appropriate, incorporated them into the final rule. This ICR was also revised to incorporate the 

comments received.

3(d) Effects of Less Frequent Collection

If the relevant information was collected less frequently, the EPA would not be 

reasonably assured that the facilities are applying good operation and maintenance practices and 

meeting the emission limitations and work practice standards in the rule. In addition, our 

authority to take administrative action would be significantly reduced. Section 113(d) of the 

CAA limits the assessment of administrative penalties to violations which occur no more than 

12 months before initiation of the administrative proceeding. Since administrative proceedings 

are less costly and require use of fewer resources than judicial proceedings, both we and the 

regulated community benefit from preservation of our administrative powers. Also, the reporting 
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frequency in the rule is consistent with the requirements of title V permit programs. 

Consequently, less frequent reports would not result in a reduced burden.

3(e) General Guidelines

The clay ceramics manufacturing NESHAP requires that facilities retain records for a 

period of 5 years, which exceeds the 3-year retention period specified in the general information 

collection guidelines in 5 CFR 1320.6(f) of OMB regulations implementing the Paperwork 

Reduction Act. However, the 5-year retention period is consistent with the retention requirement 

in the General Provisions in subpart A of 40 CFR part 63 and the retention requirement in the 

operating permit program under 40 CFR part 70. All facilities subject to this rule will be required 

to obtain operating permits either through the state-approved permitting program or, if one does 

not exist, in accordance with the provisions of 40 CFR part 71. Thus, the 5-year record retention

requirement of the rule adds no additional burden. At a minimum, respondents will be required 

to retain onsite the most recent 2 years of data. The remaining 3 years of data could be retained at 

a readily accessible onsite or offsite storage facility. None of the other guidelines in 5 CFR 

1320.6 are being exceeded.

3(f) Confidentiality

All information submitted to the EPA for which a claim of confidentiality is made will be 

safeguarded according to EPA policies set forth in Title 40, Chapter 1, Part 2, Subpart B --

Confidentiality of Business Information. (See 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; and 44 FR 

17674, March 23, 1979.)

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are owners or operators 

of clay ceramics manufacturing facilities that are major sources of HAP emissions. The North 

American Industry Classification System (NAICS) codes for respondents affected by the 

standards are 327110—Pottery, Ceramics, and Plumbing Fixture Manufacturing—and 327120—

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

NAICS codes are regulated by the standards.

4(b) Information Requested

(i) Data Items, Including Recordkeeping Requirements

All data in this ICR that are recorded and/or reported are required by the NESHAP for 

Clay Ceramics Manufacturing (40 CFR part 63, subpart KKKKK). The following table

summarizes the recordkeeping and reporting requirements under the rule.
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Requirements Rule Citation by Section

Notifications

Initial notifications (including construction/reconstruction) 63.5, 63.9(b) and

63.8630(a)-(b)

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

63.8630(a)-(b)

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(a)-(c)

Request to use routine control device maintenance alternative 

standard

63.8630(b)

Notification of alternative fuel use 63.8630(d)

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 request

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(a)-(e)

63.8635(a)-(e)

63.8635(c)(5)-(6)

63.8635(c)(8), (d)-(e)

Report of alternative fuel use 63.8635(f)

Electronic submittal of performance test results (using ERT) 63.8635(g)

(ii) Respondent Activities

The respondent activities required by the standards in the first 3 years following the 

effective date are identified in Tables 1 through 3 and are introduced in Section 6(a).
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5. The Information Collected--Agency Activities, Collection Methodology and

Information Management

5(a) Agency Activities

The Agency activities in the first 3 years following the effective date of the rule are

identified in Tables 5 through 7 and are introduced in Section 6(c).

5(b) Collection Methodology and Management

Following initial notification, the reviewing authority may inspect the source to 

determine whether the pollution control devices are properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial and ongoing capability to comply 

with the emission standard and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

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

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

determinations.

Information contained in the reports will be entered into the Air Facility System (AFS), 

which is operated and maintained by the EPA’s Office of Compliance. The AFS is the EPA’s 

database for the collection, maintenance and retrieval of air compliance data for over 125,000 

industrial and government-owned facilities. The EPA uses the AFS for tracking air pollution 

compliance and enforcement by local and state regulatory agencies, EPA Regional offices and

EPA headquarters. The EPA and its delegated authorities can edit, store, retrieve and analyze the 

data.

The records required by this regulation must be retained by the owner or operator for 

5 years.

5(c) Small Entity Flexibility

None of the major source plants in the clay ceramics industry are owned by small 

businesses based on the definition used by the Small Business Administration for this industry 

(750 or fewer company employees for NAICS codes 327110 and 327120). Regardless, the EPA 

does not expect that any facilities in the clay ceramics industry will experience adverse impacts 

due to the cost of the reporting and recordkeeping requirements of the rule.

5(d) Collection Schedule

Collection of data will begin after the effective date of the final clay ceramics 

manufacturing NESHAP. The compliance date for existing sources is 3 years after the effective 

date. The compliance date for new or reconstructed sources is the effective date if the source 

startup date is before the effective date, or upon startup if the startup date is on or after the 

effective date. The schedule for notifications and reports required by the rule is summarized 

below.
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For facilities with existing affected sources, the initial notification stating that the facility 

is subject to the rule must be submitted no later than 120 days after the effective date of the rule. 

Facilities with new or reconstructed affected sources for which startup occurs on or after the 

effective date must submit the initial notification no later than 120 days after the source becomes 

subject to the rule (although we are projecting no new affected sources in the short term). 

Facilities may choose to submit a request to use the routine control device maintenance 

alternative standard no later than 120 days prior to the compliance date. Facilities required to 

conduct a performance test must submit a notification of intent to conduct a performance test at 

least 60 days before the performance test is scheduled to begin. For each initial compliance 

demonstration that includes a performance test, facilities must submit an initial notification of 

compliance status no later than 60 days following the completion of the performance test. For 

each initial compliance demonstration that does not involve a performance test, facilities must 

submit an initial notification within 30 days of completing the initial compliance demonstration. 

Records necessary to determine compliance with the emission limitations and work practice 

standards must be compiled on a daily basis, and compliance reports must be submitted to the 

Administrator on a semi-annual basis. Repeat performance tests are to be conducted every 

5 years to ensure ongoing compliance.

6. Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden

The annual burden estimates for reporting and recordkeeping activities for the first 

3 years after the effective date of the rule are presented in Tables 1 through 3. These numbers 

were derived from estimates based on Agency knowledge and experience with part 63 and other 

regulations. In addition, comments received from the brick and structural clay products (BSCP) 

industry on the BSCP proposed rule, including burden estimates from a recent Brick Industry 

Association (BIA) survey of the BSCP industry, were incorporated into the burden estimates for 

clay ceramics, given the similarity of the manufacturing processes and regulatory requirements.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

The information collection activities for sources subject to the standards are presented in 

Tables 1 through 3. Labor costs for reporting and recordkeeping activities were estimated based 

on the most recently available labor rate data from the U.S. Bureau of Labor Statistics (BLS) for 

NAICS code 327100—Clay Product and Refractory Manufacturing 

(http://www.bls.gov/oes/2013/may/naics4_327100.htm).1 Labor costs are divided into the 

following three categories: (1) technical; (2) management; and (3) clerical. The labor rates, 

including fringe benefits, reported by BLS for May 2013 (the most recent rates available) are 

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

$15.19/hr for clerical personnel. The base labor rates were adjusted by an overhead rate of 

 1 Occupational employment statistics in BLS are provided at a higher NAICS code level (327100), compared to the 

NAICS codes (327110 and 327120) specified in Sections 4(a) and 5(c).
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110 percent. The final total labor rates are $53.17 for technical personnel, $88.56 for 

management and $31.90 for clerical.

(ii) Estimating Capital/Startup and O&M Costs

Capital/startup costs include the costs of conducting initial and repeat performance tests.

Operation and maintenance (O&M) costs include photocopy and postage costs associated with 

reporting requirements and costs associated with VE monitoring. The O&M costs for VE 

monitoring include training for VE testing for two people every 5 years, conducting the 15-

minute VE test and preparing for/documenting the VE test. The monitoring equipment needed to 

monitor parameters other than VE (e.g., lime feed rate) is included as part of the control system 

and, therefore, adds no additional capital or O&M cost. No capital/startup costs were expected to 

be incurred during the first 3 years after the effective date of the rule.

6(c) Estimating Agency Burden and Cost

No costs can be attributed to the development of the information collection requirements 

because the information collection requirements were developed as an incidental part of 

standards development. Because reporting and recordkeeping requirements on the part of the 

respondents are required under section 112 of the CAA, no operational costs will be incurred by 

the federal government. Publication and distribution of the information are part of the AFS

program, with the result that no federal costs can be directly attributed to the ICR. Examination 

of records to be maintained by the respondents will occur incidentally as part of the periodic 

inspection of sources that is part of the EPA’s overall compliance and enforcement program.

Therefore, this examination is not attributable to the ICR. The only costs that the federal 

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

presented in Tables 5 through 7.

Labor rates for federal employees are based on the January 2012, Office of Personnel 

Management labor rates for General Schedule employees 

(http://www.opm.gov/oca/12tables/pdf/gs_h.pdf). The base labor rates are $32.73/hr for 

technical personnel (GS-12, step 5), $54.10/hr for management personnel (GS-15, step 5) and

$18.45/hr for clerical personnel (GS-7, step 5). The base labor rates were multiplied by the 

standard government benefits multiplication factor of 1.6. The resulting average hourly labor 

costs are $52.37/hr for technical personnel, $86.56/hr for management and $29.52/hr for clerical.

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

Once the burden and costs per activity have been established on a per respondent basis, 

the total burden and cost must be calculated for all respondents and for the Agency. To calculate 

the total burden and costs, the number of respondents needed to complete each information 

collection activity must be estimated. The total number of respondents is also referred to as the 

“respondent universe.” The EPA has identified three major source facilities that will be subject 

to the clay ceramics rule. No new clay ceramics facilities or affected sources are expected to be 

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

short-term increases in production.
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6(e) Bottom Line Burden Hours and Costs/Master Tables

(i) Respondent Tally

The bottom line annual respondent burden hours and costs, presented in Tables 1 through 

3 (one table for each year), are calculated by adding person-hours per year down each column for 

technical, managerial and clerical staff, and by adding down the cost column. Table 4 

summarizes the respondent burden hours and costs for each of the 3 years and presents the total 

and average burden over the 3-year period. The total number of responses over the 3-year period 

is 6.0, with an average of 2.0 responses per year. The estimated total burden for the 3-year period 

is 2,989 labor hours at a labor cost of $158,023. The average bottom line annual burden over the 

3-year period is 996 labor hours at a labor cost of $52,674. There are no capital/startup costs that 

would be incurred during the 3 years following the effective date of the rule. The total annual 

O&M cost for the 3-year period is estimated to be $132, with an average of $44 incurred each 

year in the 3 years following the effective date.

(ii) The Agency Tally

The bottom line Agency burden hours and costs, presented in Tables 5 through 7, are 

calculated as in the respondent table, by adding person-hours per year down each column for 

technical, managerial and clerical staff, and by adding down the cost column. In this case, total 

cost is the sum of this total salary cost and total travel expenses for tests attended. Table 8 

summarizes the Agency burden hours and costs for each of the 3 years and presents the total and 

average burden over the 3-year period. The total hours during the 3-year ICR review period are 

14, with an average of 4.6 hours per year. The total cost over the 3-year period is $716. The 

average annual cost incurred during each year is $239.

(iii) Variations in the Annual Bottom Line

Respondent and Agency costs and labor hours vary from year to year because: 

(1) existing facilities are not required to come into full compliance with the clay ceramics

standards until 3 years after the effective date of the rule and (2) different one-time activities 

would be conducted during the first years following the effective date. During the first year, 

existing sources are required to submit an initial notification. There are no monitoring, reporting

and recordkeeping activities during the second year for existing sources. In the third year, 

existing facilities are likely to be conducting one-time activities such as developing their OM&M 

plans, developing a record system and training personnel on how to record information. Facilities 

may also choose to submit a request to use the routine control device maintenance alternative 

standard during the third year.

Because existing facilities are not required to come into full compliance with the clay 

ceramics standards until 3 years after the effective date and no new plants or affected sources are 

expected to be constructed in the near future, much of the respondent burden does not occur until 

the fourth year following the effective date. Attachment 1 contains tables showing respondent 

and Agency burden estimates for the fourth, fifth and sixth years following the effective date.

During the fourth year when existing facilities are required to come into full compliance, the 

facilities would conduct inspections, submit a notification of intent to conduct a performance 
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test, conduct an initial performance test (and, if necessary, a repeat performance test), submit 

notifications of compliance status and alternative fuel use, submit their test data to the EPA

through the EPA’s electronic reporting tool (ERT), submit their first compliance report and keep 

records of compliance data, alternative fuel use and malfunctions. During subsequent years,

existing facilities would continue to keep records and submit semi-annual reports. After the 

fourth year, burden estimates are not expected to vary considerably from year to year because 

facilities will be conducting ongoing activities (e.g., semi-annual compliance reports, 

recordkeeping, inspecting every 3 years, retesting every 5 years) as opposed to the one-time 

activities (e.g., developing OM&M plan, submitting notifications) that occur in the first 4 years 

following the effective date.

6(f) Reasons for Change in Burden

This section does not apply because this is a new collection.

6(g) Burden Statement

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

information is estimated to average 498 hours per response. Burden means the total time, effort, 

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

information to or for a federal agency. This includes the time needed to review instructions; 

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

validating and verifying information, processing and maintaining information and disclosing and 

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

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information.

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

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for the EPA’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency’s need for this information, the accuracy of the provided 

burden estimates and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, the EPA has established a public docket for this ICR 

under Docket ID Number EPA-HQ-OAR-2013-0290. An electronic version of the public docket 

is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

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

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

in this document. The documents are also available for public viewing at the EPA Docket 

Center, Room 3334, EPA WJC West Building, 1301 Constitution Avenue, NW, Washington, 

DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday 

through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 

566-1744, and the telephone number for the docket center is (202) 566-1742. Send comments to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, Attention: 
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Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503. Please include the EPA 

Docket ID Number EPA-HQ-OAR-2013-0290 in any correspondence.

Part B of the Supporting Statement

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

associated with the rule.
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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)

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(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 d 8 1 8 3 24 1.2 2.4 $1,459

B. Required activities

Develop OM&M plan e 200 1 200 0 0 0 0 $0

Update OM&M plan 10 1 10 0 0 0 0 $0

Conduct APCD maintenance/

inspections

30 1 30 0 0 0 0 $0

Conduct shuttle kiln maintenance/

inspections

160 1 160 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Initial notification of applicability e 6 1 6 3 18 0.9 1.8 $1,094

Notification of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notification of anticipated startup e 3 1 3 0 0 0 0 $0

Notification of actual startup e 3 1 3 0 0 0 0 $0

Request to use APCD maintenance 

alternative standard e

4 1 4 0 0 0 0 $0

Notification of performance test 6 1 6 0 0 0 0 $0

Notification of compliance status e,f 24 1 24 0 0 0 0 $0

Report of performance test (through 

ERT)

20 1 20 0 0 0 0 $0

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

First compliance report 30 1 30 0 0 0 0 $0
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Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Semi-annual compliance reports

Deviations h 30 2 60 0 0 0 0 $0

No deviations h 12 2 24 0 0 0 0 $0

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

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

Attend initial performance test i 34 2.5 85 0 0 0 0 $0

Attend repeat performance test i 34 2.5 85 0 0 0 0 $0

D. Develop record system 60 6 360 0 0 0 0 $0

E. Time to enter information

Records of compliance data 8 52 416 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 deviations 2 12 24 0 0 0 0 $0

F. Time to train personnel j

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 0 0 0 0 $0

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

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

43 2.1 4.3 $2,599
15

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

TOTAL ANNUAL NUMBER OF 

RESPONSES l

3

CAPITAL COSTS:

Initial performance tests m $0

Repeat performance tests n $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: o

Initial performance tests m $0

Repeat performance tests n $0

Total annualized capital cost $0

ANNUAL O&M COSTS p

Photocopy/postage $66

Visible emissions tests m $0

Total O&M cost $66

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$66

a Person-hours per occurrence and number of occurrences per year were derived based on comments from industry. b A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR compliance period. No new plants or affected sources are 

expected to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. c Costs are based on the following hourly rates: technical at $53.17, management at $88.56, and clerical at $31.90. Management person-hours and clerical person 

hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. d Assumes one-time burden of 8 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among 

technical and management staff.

e One-time only activities. f The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden 

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table. g Assumes 10% of facilities will use an alternative fuel once per year.

h Assumes 15% of respondents have deviations to report in semiannual compliance reports, and 85% report no deviations.

i Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from industry, an average of 2.5 plant personnel attend performance 

tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
16

j Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel. 

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

l The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E. m Based on estimates in Clay Ceramics Monitoring and Testing Requirements and Costs Memo. Stack testing costs assume EPA Method 5 or 29 for PM, EPA 

Method 29 for metals, EPA Method 26A for HF and HCl, and EPA Method 23 for dioxins/furans. VE testing costs assume EPA Method 22. n Assumes 10% of plants will fail an initial performance test and must repeat it. o 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). p O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., lime 

feed rate) is included as part of the control system and therefore adds no additional capital or O&M cost. The O&M cost associated with VE monitoring includes 

VE training for two people every 5 years, conducting the 15-minute VE test, and preparing for/documenting the VE test (occurs after 3-year ICR clearance period).

N/A = Not Applicable.
17

Table 2. Annual Respondent 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)

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(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 d 8 1 8 0 0 0 0 $0

B. Required activities

Develop OM&M plan e 200 1 200 0 0 0 0 $0

Update OM&M plan 10 1 10 0 0 0 0 $0

Conduct APCD maintenance/

inspections

30 1 30 0 0 0 0 $0

Conduct shuttle kiln maintenance/

inspections

160 1 160 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Initial notification of applicability e 6 1 6 0 0 0 0 $0

Notification of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notification of anticipated startup e 3 1 3 0 0 0 0 $0

Notification of actual startup e 3 1 3 0 0 0 0 $0

Request to use APCD maintenance 

alternative standard e

4 1 4 0 0 0 0 $0

Notification of performance test 6 1 6 0 0 0 0 $0

Notification of compliance status e,f 24 1 24 0 0 0 0 $0

Report of performance test (through 

ERT)

20 1 20 0 0 0 0 $0

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

First compliance report 30 1 30 0 0 0 0 $0
18

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Semi-annual compliance reports

Deviations h 30 2 60 0 0 0 0 $0

No deviations h 12 2 24 0 0 0 0 $0

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

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

Attend initial performance test i 34 2.5 85 0 0 0 0 $0

Attend repeat performance test i 34 2.5 85 0 0 0 0 $0

D. Develop record system 60 6 360 0 0 0 0 $0

E. Time to enter information

Records of compliance data 8 52 416 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 deviations 2 12 24 0 0 0 0 $0

F. Time to train personnel j

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 0 0 0 0 $0

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

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

0 0 0 $0
19

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

TOTAL ANNUAL NUMBER OF 

RESPONSES l

0

CAPITAL COSTS:

Initial performance tests m $0

Repeat performance tests n $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: o

Initial performance tests m $0

Repeat performance tests n $0

Total annualized capital cost $0

ANNUAL O&M COSTS p

Photocopy/postage $0

Visible emissions tests m $0

Total O&M cost $0

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$0

a Person-hours per occurrence and number of occurrences per year were derived based on comments from industry. b A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR compliance period. No new plants or affected sources are 

expected to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. c Costs are based on the following hourly rates: technical at $53.17, management at $88.56, and clerical at $31.90. Management person-hours and clerical person 

hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. d Assumes one-time burden of 8 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among 

technical and management staff.

e One-time only activities. f The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden 

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table. g Assumes 10% of facilities will use an alternative fuel once per year. h Assumes 15% of respondents have deviations to report in semiannual compliance reports, and 85% report no deviations.

i Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from industry, an average of 2.5 plant personnel attend performance 

tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
20

j Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel. 

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

l The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E. m Based on estimates in Clay Ceramics Monitoring and Testing Requirements and Costs Memo. Stack testing costs assume EPA Method 5 or 29 for PM, EPA 

Method 29 for metals, EPA Method 26A for HF and HCl, and EPA Method 23 for dioxins/furans. VE testing costs assume EPA Method 22. n Assumes 10% of plants will fail an initial performance test and must repeat it. o 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). p O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., lime 

feed rate) is included as part of the control system and therefore adds no additional capital or O&M cost. The O&M cost associated with VE monitoring includes 

VE training for two people every 5 years, conducting the 15-minute VE test, and preparing for/documenting the VE test (occurs after 3-year ICR clearance period).

N/A = Not Applicable.
21

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

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(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 d 8 1 8 0 0 0 0 $0

B. Required activities

Develop OM&M plan e 200 1 200 3 600 30 60 $36,474

Update OM&M plan 10 1 10 0 0 0 0 $0

Conduct APCD maintenance/inspections 30 1 30 0 0 0 0 $0

Conduct shuttle kiln maintenance/

inspections

160 1 160 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Initial notification of applicability e 6 1 6 0 0 0 0 $0

Notification of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notification of anticipated startup e 3 1 3 0 0 0 0 $0

Notification of actual startup e 3 1 3 0 0 0 0 $0

Request to use APCD maintenance 

alternative standard e

4 1 4 3 12 0.6 1.2 $729

Notification of performance test 6 1 6 0 0 0 0 $0

Notification of compliance status e,f 24 1 24 0 0 0 0 $0

Report of performance test (through 

ERT)

20 1 20 0 0 0 0 $0

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

First compliance report 30 1 30 0 0 0 0 $0
22

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Semi-annual compliance reports

Deviations h 30 2 60 0 0 0 0 $0

No deviations h 12 2 24 0 0 0 0 $0

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

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

Attend initial performance test i 34 2.5 85 0 0 0 0 $0

Attend repeat performance test i 34 2.5 85 0 0 0 0 $0

D. Develop record system 60 6 360 3 1,080 54 108 $65,653

E. Time to enter information

Records of compliance data 8 52 416 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 deviations 2 12 24 0 0 0 0 $0

F. Time to train personnel j

Initial training 48 6 288 3 864 43 86 $52,522

Annual training 10 6 60 0 0 0 0 $0

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

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

2,557 128 256 $155,424
23

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

TOTAL ANNUAL NUMBER OF 

RESPONSES l

3

CAPITAL COSTS:

Initial performance tests m $0

Repeat performance tests n $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: o

Initial performance tests m $0

Repeat performance tests n $0

Total annualized capital cost $0

ANNUAL O&M COSTS p

Photocopy/postage $66

Visible emissions tests m $0

Total O&M cost $66

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$66

a Person-hours per occurrence and number of occurrences per year were derived based on comments from industry. b A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR compliance period. No new plants or affected sources are 

expected to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. c Costs are based on the following hourly rates: technical at $53.17, management at $88.56, and clerical at $31.90. Management person-hours and clerical person 

hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. d Assumes one-time burden of 8 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among 

technical and management staff.

e One-time only activities. f The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden 

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table. g Assumes 10% of facilities will use an alternative fuel once per year.

h Assumes 15% of respondents have deviations to report in semiannual compliance reports, and 85% report no deviations.

i Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from industry, an average of 2.5 plant personnel attend performance 

tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
24

j Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel. k Time associated with transmitting reports. Equal to the number of respondents submitting reports.

l The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E. m Based on estimates in Clay Ceramics Monitoring and Testing Requirements and Costs Memo. Stack testing costs assume EPA Method 5 or 29 for PM, EPA 

Method 29 for metals, EPA Method 26A for HF and HCl, and EPA Method 23 for dioxins/furans. VE testing costs assume EPA Method 22. n Assumes 10% of plants will fail an initial performance test and must repeat it. o 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). p O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., lime 

feed rate) is included as part of the control system and therefore adds no additional capital or O&M cost. The O&M cost associated with VE monitoring includes 

VE training for two people every 5 years, conducting the 15-minute VE test, and preparing for/documenting the VE test (occurs after 3-year ICR clearance period).

N/A = Not Applicable.
25

Table 4. Summary of Respondent Burden and Cost of the Clay Ceramics NESHAP - Years 1 to 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 43 2.1 4.3 49 $2,599 $0 $0 $66 $66

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

Year 3 3 2,557 128 256 2,940 $155,424 $0 $0 $66 $66

Totals 6 2,600 130 260 2,989 $158,023 $0 $0 $132 $132

Average 2.0 996 $52,674 $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 personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants 

per year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

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 to use APCD maintenance 

alternative standard

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
27

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$358

a A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. No new plants or affected sources 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 personhours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Assumes Agency personnel will attend performance tests at 10% of plants.

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests. e Assumes 1% of plants will be involved in litigation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests. g Notification of compliance status includes the performance test report.

h Assumes 15% of the plants report deviations semiannually and 85% report no deviations. i Assumes 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.
28

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

Activity

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

EPA personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants 

per year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

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 to use APCD maintenance 

alternative standard

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
29

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$0

a A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. No new plants or affected sources 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 personhours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Assumes Agency personnel will attend performance tests at 10% of plants.

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests. e Assumes 1% of plants will be involved in litigation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests. g Notification of compliance status includes the performance test report.

h Assumes 15% of the plants report deviations semiannually and 85% report no deviations. i Assumes 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.
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 personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants 

per year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

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 to use APCD maintenance 

alternative standard

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
31

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$358

a A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. No new plants or affected sources 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 personhours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Assumes Agency personnel will attend performance tests at 10% of plants.

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests. e Assumes 1% of plants will be involved in litigation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests. g Notification of compliance status includes the performance test report.

h Assumes 15% of the plants report deviations semiannually and 85% report no deviations. i Assumes 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.
32

Table 8. Summary of Burden and Cost to the Federal Government of the Clay Ceramics NESHAP - Years 1 to 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)

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(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 d 8 1 8 0 0 0 0 $0

B. Required activities

Develop OM&M plan e 200 1 200 0 0 0 0 $0

Update OM&M plan 10 1 10 3 30 1.5 3.0 $1,824

Conduct APCD maintenance/inspections 30 1 30 3 90 4.5 9.0 $5,471

Conduct shuttle kiln maintenance/

inspections

160 1 160 3 480 24 48 $29,179

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Initial notification of applicability e 6 1 6 0 0 0 0 $0

Notification of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notification of anticipated startup e 3 1 3 0 0 0 0 $0

Notification of actual startup e 3 1 3 0 0 0 0 $0

Request to use APCD maintenance 

alternative standard e

4 1 4 0 0 0 0 $0

Notification of performance test 6 1 6 3 18 0.9 1.8 $1,094

Notification of compliance status e,f 24 1 24 3 72 3.6 7.2 $4,377

Report of performance test (through 

ERT)

20 1 20 3 60 3.0 6.0 $3,647

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

First compliance report 30 1 30 3 90 4.5 9.0 $5,471
1-3

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Semi-annual compliance reports

Deviations h 30 2 60 0 0 0 0 $0

No deviations h 12 2 24 0 0 0 0 $0

Report of alternative fuel use g 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 24 1 24 3 72 3.6 7.2 $4,377

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

C. Implement activities

Attend initial performance test i 34 2.5 85 3 255 13 26 $15,501

Attend repeat performance test i 34 2.5 85 0.3 26 1.3 2.6 $1,550

D. Develop record system 60 6 360 0 0 0 0 $0

E. Time to enter information

Records of compliance data 8 52 416 3 1,248 62 125 $75,866

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 deviations 2 12 24 3 72 3.6 7.2 $4,377

F. Time to train personnel j

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 3 180 9.0 18 $10,942

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

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

2,745 137 274 $166,859
1-4

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

TOTAL ANNUAL NUMBER OF 

RESPONSES l

16

CAPITAL COSTS:

Initial performance tests m $267,000

Repeat performance tests n $26,700

Total capital cost $293,700

ANNUALIZED CAPITAL COSTS: o

Initial performance tests m $65,500

Repeat performance tests n $6,550

Total annualized capital cost $72,050

ANNUAL O&M COSTS p

Photocopy/postage $343

Visible emissions tests m $26,858

Total O&M cost $27,201

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$72,393

a Person-hours per occurrence and number of occurrences per year were derived based on comments from industry. b A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR compliance period. No new plants or affected sources are 

expected to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. c Costs are based on the following hourly rates: technical at $53.17, management at $88.56, and clerical at $31.90. Management person-hours and clerical person 

hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. d Assumes one-time burden of 8 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among 

technical and management staff.

e One-time only activities. f The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden 

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table. g Assumes 10% of facilities will use an alternative fuel once per year.

h Assumes 15% of respondents have deviations to report in semiannual compliance reports, and 85% report no deviations.

i Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from industry, an average of 2.5 plant personnel attend performance 

tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
1-5

j Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel. 

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

l The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E. m Based on estimates in Clay Ceramics Monitoring and Testing Requirements and Costs Memo. Stack testing costs assume EPA Method 5 or 29 for PM, EPA 

Method 29 for metals, EPA Method 26A for HF and HCl, and EPA Method 23 for dioxins/furans. VE testing costs assume EPA Method 22. n Assumes 10% of plants will fail an initial performance test and must repeat it. o 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). p O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., lime 

feed rate) is included as part of the control system and therefore adds no additional capital or O&M cost. The O&M cost associated with VE monitoring includes 

VE training for two people every 5 years, conducting the 15-minute VE test, and preparing for/documenting the VE test (occurs after 3-year ICR clearance period).

N/A = Not Applicable.
1-6

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

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(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 d 8 1 8 0 0 0 0 $0

B. Required activities

Develop OM&M plan e 200 1 200 0 0 0 0 $0

Update OM&M plan 10 1 10 3 30 1.5 3.0 $1,824

Conduct APCD maintenance/ inspections 30 1 30 0 0 0 0 $0

Conduct shuttle kiln maintenance/

inspections

160 1 160 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Initial notification of applicability e 6 1 6 0 0 0 0 $0

Notification of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notification of anticipated startup e 3 1 3 0 0 0 0 $0

Notification of actual startup e 3 1 3 0 0 0 0 $0

Request to use APCD maintenance 

alternative standard e

4 1 4 0 0 0 0 $0

Notification of performance test 6 1 6 0 0 0 0 $0

Notification of compliance status e,f 24 1 24 0 0 0 0 $0

Report of performance test (through ERT) 20 1 20 0 0 0 0 $0

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

First compliance report 30 1 30 0 0 0 0 $0
1-7

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Semi-annual compliance reports

Deviations h 30 2 60 0.5 27 1.4 2.7 $1,641

No deviations h 12 2 24 2.6 61 3.1 6.1 $3,720

Report of alternative fuel use g 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 24 1 24 0 0 0 0 $0

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

C. Implement activities

Attend initial performance test i 34 2.5 85 0 0 0 0 $0

Attend repeat performance test i 34 2.5 85 0 0 0 0 $0

D. Develop record system 60 6 360 0 0 0 0 $0

E. Time to enter information

Records of compliance data 8 52 416 3 1,248 62 125 $75,866

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 deviations 2 12 24 3 72 3.6 7.2 $4,377

F. Time to train personnel j

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 3 180 9.0 18 $10,942

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

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

1,657 83 166 $100,750
1-8

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

TOTAL ANNUAL NUMBER OF 

RESPONSES l

7

CAPITAL COSTS:

Initial performance tests m $0

Repeat performance tests n $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: o

Initial performance tests m $65,500

Repeat performance tests n $6,550

Total annualized capital cost $72,050

ANNUAL O&M COSTS p

Photocopy/postage $145

Visible emissions tests m $26,858

Total O&M cost $27,003

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$72,195

a Person-hours per occurrence and number of occurrences per year were derived based on comments from industry. b A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR compliance period. No new plants or affected sources are 

expected to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. c Costs are based on the following hourly rates: technical at $53.17, management at $88.56, and clerical at $31.90. Management person-hours and clerical person 

hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. d Assumes one-time burden of 8 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among 

technical and management staff.

e One-time only activities. f The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden 

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table. g Assumes 10% of facilities will use an alternative fuel once per year.

h Assumes 15% of respondents have deviations to report in semiannual compliance reports, and 85% report no deviations.

i Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from industry, an average of 2.5 plant personnel attend performance 

tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
1-9

j Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel. 

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

l The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E. m Based on estimates in Clay Ceramics Monitoring and Testing Requirements and Costs Memo. Stack testing costs assume EPA Method 5 or 29 for PM, EPA 

Method 29 for metals, EPA Method 26A for HF and HCl, and EPA Method 23 for dioxins/furans. VE testing costs assume EPA Method 22. n Assumes 10% of plants will fail an initial performance test and must repeat it. o 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). p O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., lime 

feed rate) is included as part of the control system and therefore adds no additional capital or O&M cost. The O&M cost associated with VE monitoring includes 

VE training for two people every 5 years, conducting the 15-minute VE test, and preparing for/documenting the VE test (occurs after 3-year ICR clearance period).

N/A = Not Applicable.
1-10

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

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(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 d 8 1 8 0 0 0 0 $0

B. Required activities

Develop OM&M plan e 200 1 200 0 0 0 0 $0

Update OM&M plan 10 1 10 3 30 1.5 3.0 $1,824

Conduct APCD maintenance/inspections 30 1 30 0 0 0 0 $0

Conduct shuttle kiln maintenance/

inspections

160 1 160 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Initial notification of applicability e 6 1 6 0 0 0 0 $0

Notification of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notification of anticipated startup e 3 1 3 0 0 0 0 $0

Notification of actual startup e 3 1 3 0 0 0 0 $0

Request to use APCD maintenance 

alternative standard e

4 1 4 0 0 0 0 $0

Notification of performance test 6 1 6 0 0 0 0 $0

Notification of compliance status e,f 24 1 24 0 0 0 0 $0

Report of performance test (through 

ERT)

20 1 20 0 0 0 0 $0

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

First compliance report 30 1 30 0 0 0 0 $0
1-11

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Semi-annual compliance reports

Deviations h 30 2 60 0.5 27 1.4 2.7 $1,641

No deviations h 12 2 24 2.6 61 3.1 6.1 $3,720

Report of alternative fuel use g 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 24 1 24 0 0 0 0 $0

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

C. Implement activities

Attend initial performance test i 34 2.5 85 0 0 0 0 $0

Attend repeat performance test i 34 2.5 85 0 0 0 0 $0

D. Develop record system 60 6 360 0 0 0 0 $0

E. Time to enter information

Records of compliance data 8 52 416 3 1,248 62 125 $75,866

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 deviations 2 12 24 3 72 3.6 7.2 $4,377

F. Time to train personnel j

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 3 180 9.0 18 $10,942

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

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

1,657 83 166 $100,750
1-12

Burden item

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

Personhours per 

occurrence a

No. of 

occurrences 

per respondent 

per year

Personhours per 

respondent 

per year

Respondents 

per year b

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ c

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

TOTAL ANNUAL NUMBER OF 

RESPONSES l

7

CAPITAL COSTS:

Initial performance tests m $0

Repeat performance tests n $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: o

Initial performance tests m $65,500

Repeat performance tests n $6,550

Total annualized capital cost $72,050

ANNUAL O&M COSTS p

Photocopy/postage $145

Visible emissions tests m $26,858

Total O&M cost $27,003

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$72,195

a Person-hours per occurrence and number of occurrences per year were derived based on comments from industry. b A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR compliance period. No new plants or affected sources are 

expected to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. c Costs are based on the following hourly rates: technical at $53.17, management at $88.56, and clerical at $31.90. Management person-hours and clerical person 

hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. d Assumes one-time burden of 8 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among 

technical and management staff.

e One-time only activities. f The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration. The cost burden 

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table. g Assumes 10% of facilities will use an alternative fuel once per year.

h Assumes 15% of respondents have deviations to report in semiannual compliance reports, and 85% report no deviations.

i Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from industry, an average of 2.5 plant personnel attend performance 

tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
1-13

j Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel. 

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

l The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 3E. m Based on estimates in Clay Ceramics Monitoring and Testing Requirements and Costs Memo. Stack testing costs assume EPA Method 5 or 29 for PM, EPA 

Method 29 for metals, EPA Method 26A for HF and HCl, and EPA Method 23 for dioxins/furans. VE testing costs assume EPA Method 22. n Assumes 10% of plants will fail an initial performance test and must repeat it. o 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). p O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., lime 

feed rate) is included as part of the control system and therefore adds no additional capital or O&M cost. The O&M cost associated with VE monitoring includes 

VE training for two people every 5 years, conducting the 15-minute VE test, and preparing for/documenting the VE test (occurs after 3-year ICR clearance period).

N/A = Not Applicable.
1-14

Table 1-4. Summary of Respondent Burden and Cost of the Clay Ceramics NESHAP - Years 4 to 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 2,745 137 274 3,157 $166,859 $293,700 $72,050 $27,201 $99,251

Year 5 7 1,657 83 166 1,906 $100,750 $0 $72,050 $27,003 $99,053

Year 6 7 1,657 83 166 1,906 $100,750 $0 $72,050 $27,003 $99,053

Totals 29 6,060 303 606 6,968 $368,359 $293,700 $216,150 $81,208 $297,358

Average 10 2,323 $122,786 $97,900 $72,050 $27,069 $99,119
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

personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants 

per year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

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 to use APCD maintenance alternative 

standard

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
1-16

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$17,780

a A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. No new plants or affected sources 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 personhours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Assumes Agency personnel will attend performance tests at 10% of plants.

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests. e Assumes 1% of plants will be involved in litigation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests. g Notification of compliance status includes the performance test report.

h Assumes 15% of the plants report deviations semiannually and 85% report no deviations. i Assumes 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.
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 personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants 

per year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

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 to use APCD maintenance 

alternative standard

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
1-18

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$5,282

a A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. No new plants or affected sources 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 personhours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Assumes Agency personnel will attend performance tests at 10% of plants.

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests. e Assumes 1% of plants will be involved in litigation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests. g Notification of compliance status includes the performance test report.

h Assumes 15% of the plants report deviations semiannually and 85% report no deviations. i Assumes 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.
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 personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants 

per year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

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 to use APCD maintenance 

alternative standard

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
1-20

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$5,282

a A total of three existing major sources (all sanitaryware) are expected to comply during the 3-year ICR clearance period. No new plants or affected sources 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 personhours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Assumes Agency personnel will attend performance tests at 10% of plants.

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests. e Assumes 1% of plants will be involved in litigation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests. g Notification of compliance status includes the performance test report.

h Assumes 15% of the plants report deviations semiannually and 85% report no deviations. i Assumes 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.
1-21

Table 1-8. Summary of Burden and Cost to the Federal Government of the Clay Ceramics NESHAP - Years 4 to 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