**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS )**  **( Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Refractory

Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal), EPA I CR Number 2040.05, OMB Control Number 2060

- 0515 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Refract ory Products Manufacturing were proposed on June 20, 2002 (67 FR 42107) and promulgated on April 16, 2003 (68 FR 18729). These regulations apply to each existing refractory products manufacturing which produces refractory bricks, refractory

shapes, kiln f

urniture, crucibles, and other materials used as linings for boilers, kilns, and other processing units and equipment where extremes of temperature, corrosions, and abrasion would destroy other materials. The rule applies to facilities that manufacture re fractory products and use organic hazardous air pollutant (HAP), chromium refractory , and clay refractory

products. The new or reconstructed affected sources are shape dryers, curing ovens, and kilns that are used to manufacture refractory products that u se organic HAP; shape preheaters, pitch working tanks, defumers, and coking ovens used to produce pitch

- impregnated refractory products; kilns that are used to manufacture chromium refractory products; and kilns that are used to manufacture clay refractory products. New facilities include th ose that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63 , subpart SSSSS

. In general , all NESHAP standards require initi al notifications, compliance status reports, performance tests, and periodic reports b y the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any s tartup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).2

Over the next three ye ars, an average of eight respondents per ye ar will be subject to the standard , and it is estimated that no additional respondents will become subject to the standard. The Office of Management and Budget (OMB) approved the currently active Information Collection Request (I CR) without any “Terms of Clearance.” The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Refractory Products Manufacturing (40 CFR Part 63 , Subpart SSSSS ) (Renewal) . The burden to the “Federal Government” is attributed entirely to work performed b y either F ederal empl oyees or government contractor s ; this burden may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Refractory Products Manufacturing (40 CFR Part 63 , Subpart SSSSS ) (Renewal).
**2. Need for and Use of the Collection 2(a)**  **Need/Authority for the Collection** The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. Inaddition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this A ct to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; ( F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, particulate matter emissions from facilities in refractory produ cts manufacturing cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this sourc e category at 40 CFR part 63 , subpart SSSSS

. **2(b) Practical Utility/User s of the Data**  The recordkeeping and reporting requirements in the standard ensure s compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The3

collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated , that leaks are being detected and repaired and the standard are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping an d reporting are required under 40 CFR part 63 , subpart SSSSS

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists. **3(b) Public N otice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 76 FR 2690 0 ) on May 9, 2011

. No comments were received on the burden published in the Federal Regi ster

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compl iance data. The growth rate for the industry is4

based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the s tandard as it was being developed. In developing this I CR, we contacted : 1) The Refractories Institute , at ( 412) 244

- 1880 ; and 2) Allied Mineral Products , at (614) 876

- 0244. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. I f the information required by these standards was collected less frequently , the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines** These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Pro visions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars allow s EPA to establish the compliance history of a source , any pattern of non - compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 F R 17674, March 23, 1979). **3(g) Sensitive Questions** The reporting or recordkeeping requirements in the standard do not include sensitive questions

.5

**4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are refractory products manufacturing facilities . The U

. . Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards , which correspond to the North American Industry Classification System (NAI CS ) codes, are listed below for this source category

.
**Standard (**  **40 CFR P**  **art 6 3, S**  **ubpart SSSSS**  **) SIC Codes**  **NAICS Codes** Clay refractory

manufacturing 3255 327124 Nonclay refractory

manufacturing 3297 327125 **4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is required b y NESHAP for Refractory

Products Manufacturing (40 CFR Part 63, Subpart SSSSS). A source must make the following reports:

**Notification s**  Initial notification 63.9(b)(2) and (3), 63.5, 63.9812(b)

- (c) Notification of performance test 63.7(b)

- (c), 63.9(e), and 63.9812(d) Notification of compliance status 63.9(h), 63.10(d)(2), and 63.9812(e) Notification of alternative fuel use 63.9812(f) Startup, shutdown, malfunction 63.10(d)(5), 63.9814(c)(4) No deviations/no continuous monitoring sy stem (CMS) out of control 63.9814(c)(5)

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

- (f) Report of alternative fuel use 63.98 1 4 (g)
A source must keep the following records:6 **Recordkeeping** Record of startup, shutdown, and malfunctions 63.6(e)(3), 63.10(b)(2 ), 63.9816(a)(2) Records of performance tests 63.10(b)(2)(viii), 63.9816(a)(3) Initial notification or notification of compliance status 63.10(b)(2)(xiv), 63.9816(a)(1)
Record of each CMS 63.8(d)(3), 63.8(f)(6)(i), 63.8(g), 63.10(b)(2)(vi)

- (xi), and 63.9816(c) Records are required to be retained for five years 63.10(b)(1) Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordke eping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Perform initial performance test, Reference Methods 25A test, and repeat performance tests if necessary . Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifyin g information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.7

Currently sources are using automated monitoring and reporting equipment that provide parameter data in an automated way , e.g. continuous parameter monitoring sy stem. Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information. **Agenc y Activities**  Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comply

with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of complianc e data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However,8

the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involv ing the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown in below Table 1: Annual Respondent Burden and Cost

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

. **6. Estimating the Burden and Cost of the Collection**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standa rdized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 338 ( Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experienc e with the NESHAP program, the previousl y approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 121

. 42 ($57. 82 + 110%) Technical $99.14 ($47.21 + 110%) Clerical $49.81 ($23.72 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, “Table 2. Civilian Workers, by occupational and industry group.” The rates9

are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed b y private industry

.

**(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated w ith the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one time costs when a facility becomes subj ect to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs su ch as photocop ying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs.**  **Operation and Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)
Continuous parameter mo nitoring system $16,820 0 $0 $380 8 $3,040

The total capital/startup costs for this I CR are zero . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 3,040

. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 3,040

. These are recordkeeping costs

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection o f sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 8,085

. This cost is based on the average hourl y labor rate as follows:10
Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 1 General Schedule , which excludes locality rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees . Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately eight existing respondents wil l be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below , is eight per year . The number of respondents is calculated using the fol lowing table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 8 0 0 8
2 0 8 0 0 8
3 0 8 0 0 8 Average 0 8 0 0 8
1 New respondent include sources with constructed, reconstructed and modified affected facilities.

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is eight

. The total number of annual responses per ye ar is calculated using the following table:11

**Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D Notification of applicability 0 1 0 0 Notification of construction/reconstruction 0 1 0 0 Notification of anticipated startup 0 1 0 0 Notification of actual startup 0 1 0 0 Notification of performance test 0 1 0 0 Notification of compliance status 0 1 0 0 Notification of intent to use alternative fuel 3 1 0 3 Report of deviations 1 1 0 1 Report of no deviations 7 2 0 14 Startup, shutdown, malfunction report 1 1 0 1 Report of alternative fuel use 3 1 0 3 Total 22 The number of Total Annual Responses is 22

. The total annual labor costs are $32, 396

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

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

. **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 below , respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 338 hours, at a cost of $32,396

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Refractory

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

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 15 hours per response

.12

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

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 179 labor hours , at a cost of $8, 085 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Refractory

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

. **6(f) Reasons for Change in Burden** There is no change in the estimation methodology for labor hours or cost to the respondents in this I CR compared to the previous ICR. This is due to two considerations : 1) the regulations have not changed o ver the past three years and are not anticipated to change over the next three years ; and 2) the growth rate for respondents is very low, negative, or non

- existent. However, there is an adjustment increase in the total costs to the respondents and the Ag ency . The increase in costs reflects updated labor rates for each of the labor categories

. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 15 hours per response. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable in structions 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 spo nsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for t his I CR under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0261

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified13

in this document. The documents are al so available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2011

- 0261 and OMB Control Number 2060

- 0515 in any correspondence. **Par t B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.14

**Table 1: Annual Respondent Burden and Cost** 

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

**Burden item (A)**  **Person**
**- hours**  **per occurrence**  **(B)**

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
**- hours**  **per respondent**  **per year (C=AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements A. Read instructions 0.5 1 4 0 0 0 $0 B. Required activities Startup, shutdown, malfunction plan 32 1 32 0 0 0 $0 Operation, maintenance, monitoring plan 32 1 32 0 0 0 $0 C. Create information See 3B D. Gather existing information See 3B E. Write report Notific ation of applicability 2 1 2 0 0 0 $0 Notific ation of construction/ reconstruction 2 1 2 0 0 0 $0 Notification of anticipated startup 2 1 2 0 0 0 $0 Notific ation of actual startup 2 1 2 0 0 0 $0 Notification of performance test 2 1 2 0 0 0 $0 Notific ation of compliance status 16 1 16 0 0 0 $0 Notification of intent to use alternative fuel c 2 1 2 3 6 0.3 0.6 $661.15 Report of deviations d 16 1 16 1 16 0.8 1.6 $1,763.0715

Report of no deviations e 8 2 16 7 112 5.6 11.2 $12,341.50 Startup , shutdown, malfunction report f 8 1 8 1 8 0.4 0.8 $881.54 Report of alternative fuel use g 4 1 4 3 12 0.6 1.2 $1,322.30 **S ubtotal for**  **Reporting Requirements**  **177** 4. Recordkeeping Requirements A. Rea d instructions h 4 1 4 8 32 1.6 3.2 $3,52 6

. 14 B. Plan activities See 4E C. Imp lement activities See 4E D. Develop record system See 4E E. Time to enter information Records of all information required by standards i 0.25 52 13 8 104 5.2 10.4 $11,459

. 97 F. Time to train personnel 20 1 20 0 0 0 0 $0 G. Time to adjust existing ways to com ply with previously applicable requirements N/A
H. Time to transmit or disclose information j 0.25 2 0.5 8 4 0.2 0.4 $440. 77 I. Time for audits N/A **S ubtotal for**  **Recordkeeping Requirements**  **161 TOTA**  **L LABOR BURDEN AND COST (rounded)**  **338 $32,396** 

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be eight. There will be no addi tional new source per year that will become subject to the rule over the three

- year period of this ICR. b This ICR uses the fol lowing labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 , “ Table 2: Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.16

c We have assumed that three respondent will use alternative fuel once per year and will have to submit notification of intent to use alternative fuel. d We have assumed that one respondent will report deviation once a year. e We have assumed that seven respondents will report no deviation on a semiannual basis. f It is assumed that one respondents will have a startup, shutdow n, malfunction occur. g We have assumed that three respondents will report on alternative fuel usage once a year. h We have assumed that it will take 4 hours for each respondent to read instructions. i We have assumed that information will be recorded once per week for 52 weeks per year. j We have assumed that it will take 0.25 hours for information to be transmitted or disclosed.17

**Table 2: Average Annual EPA Burden and Cost** 

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

**Activity (A)** 

**EPA person**
  ** hours per** **occurrence (B)** 

**No. of occurrences per**  **plant per year (C**  **)**

**EPA person**  **** **hours per plant per**  **year (C=AxB)**  **(D)**

**Plants per year**  **a (E)**  **Technical person**  **- hours**  **per year (E=CxD)**  **(F)**

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **- hours**  **per year (Ex0.1)**  **(H)**

**Cost, $ b** 

Attend initial performance test 40 1 40 0 0 0 0 $0 Attend repeat performance test Retes ting preparation 8 1 8 0 0 0 0 $0 Retesting 40 1 40 0 0 0 0 $0 Report Review Notif ication of applicability 2 1 2 0 0 0 0 $0 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0 Notification of anticipated startup 2 1 2 0 0 0 0 $0 Notification of actual startup 2 1 2 0 0 0 0 $0 Notif ication of initial performance test 2 1 2 0 0 0 0 $0 Notification of compliance status 2 1 2 0 0 0 0 $0 Notif ication of intent to use alternative fuel c 2 1 2 3 6 0.3 0 0.6 $310.95 Repeat performance test report 40 1 40 0 0 0 0 $0 Semiannual compliance reports Deviation d 16 1 16 1 16 0.8 1.6 $829.19 No Deviation e 8 2 16 7 112 5.6 11.2 $5,804.3418

Startup, shutdown, malfunction report f 16 1 16 1 16 0.8 1.6 $829.19
Notif ication of alternative fuel use g 2 1 2 3 6 0.3 0.6 $310.95 **TOTAL ANNUAL BURDEN AND**  **COST (rounded) 179**  **$8,08 5** 

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be eight. There will be no addi tional new source per year that will become subject to the rule over the three

- year period of this ICR. b This cos t is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $ 62.27 (GS

- 13, Step 5, $ 38

. 92 x 1.6), Technical rate of $ 46.21 (GS

- 12, Step 1, $2 8.8 8 x 1.6), and Clerical rate of $ 25.01 (GS

- 6, Step 3, $1 5.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “ 2011 General Schedule” which excludes locality rates of pay. c We have assumed that three respondent will use alternative fuel once p er year and will have to submit notification of intent to use alternative fuel. d We have assumed that one respondent will report deviation once a year. e We have assumed that seven respondents will report no deviation on a semiannual basis. f It is assumed that one respondents will have a startup, shutdow n, malfunction occur. g We have assumed that three respondents will report on alternative fuel usage once a year.