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SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay 

Products Manufacturing

(40 CFR Part 63, Subpart JJJJJ)

July 2014

Part A of the Supporting Statement

1.0 Identification of the Information Collection

1(a) Title and Number of the Information Collection

“National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay 

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

request (ICR). The EPA ICR tracking number is 2509.01.

1(b) Short Characterization

Potential respondents are owners or operators of new and existing sources at brick and/or 

structural clay products (BSCP) manufacturing facilities. A BSCP facility manufactures brick, 

including face brick, structural brick, brick pavers, or other brick and/or structural clay products 

including clay pipe; roof tile; extruded floor and wall tile; or other extruded, dimensional clay 

products. The BSCP facilities typically form, dry and fire bricks and shapes that are composed 

primarily of clay and shale. Kilns are used to fire BSCP. The rule applies to all new and existing 

tunnel and periodic kilns at BSCP facilities.

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

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

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

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

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

92 existing BSCP facilities that are currently major sources of HAP. An estimated 25 of these 

facilities are projected to become synthetic area sources (i.e., obtain a federally enforceable limit 

reducing emissions below major source thresholds) by the effective date of the rule rather than 

comply with subpart JJJJJ. The remaining 67 existing BSCP facilities are expected to be subject 

to the rule. Based on the latest BSCP industry profile, no new BSCP facilities or kilns are 

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

cover any short-term increases in production.

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

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

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

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

limitation deviations (or reports certifying that no deviations have occurred) also are required.

General requirements applicable to all NESHAP include records of applicability determinations,
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performance test results, deviations, monitoring records and all other information needed to 

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

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

3 years of data may be retained offsite.

Subpart JJJJJ requires respondents to monitor control device operating parameters to 

assure continuous compliance with the rule. Parameter monitoring requirements for dry injection 

fabric filter (DIFF) or dry lime scrubber/fabric filter (DLS) include lime injection rate 

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

Parameter monitoring requirements for dry limestone adsorbers (DLA) include limestone feed 

rate monitoring, periodic VE determinations and either pressure drop monitoring or bypass stack 

damper position monitoring. Facilities using a DLA must also record the source of limestone 

used in the DLA. The rule also includes monitoring requirements for wet scrubbers, including 

monitoring of pressure drop, scrubber liquid pH, scrubber liquid flow rate and chemical addition 

rate (if applicable), as well as monitoring of carbon flow rate for activated carbon injection.

Respondents with no control device must conduct periodic VE determinations and monitor the 

process rate of the kiln (if their last calculated total facility maximum potential hydrogen 

chloride-equivalent was above the proposed acid gas emission limitation). Respondents also 

must maintain records of specific information needed to determine that the standards are being 

achieved and maintained.

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection

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

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

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

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

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

ensure compliance with a section 112 emission standard. Section 114(a)(1) specifically states 

that the Administrator may require any owner or operator subject to any requirement of the CAA 

to:

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

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

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

equipment parameters, production variables or other indirect data when direct 

monitoring of emissions is impractical; (F) submit compliance certifications 

in accordance with section 114(a)(3); and (G) provide such other information 

as the Administrator may reasonably require.

The predominant HAP emitted from BSCP manufacturing facilities include hydrogen 

fluoride (HF), hydrogen chloride (HCl), chlorine (Cl2) and metals (antimony, arsenic, beryllium, 

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

Administrator’s judgment, the pollutants emitted from BSCP manufacturing facilities cause or 

contribute significantly to air pollution that may reasonably be anticipated to endanger public 
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health. Consequently, NESHAP for this source category were promulgated at 40 CFR part 63, 

subpart JJJJJ on May 16, 2003. (Note: The BSCP manufacturing source category was originally 

included in the clay products manufacturing industry source category in the initial list of source 

categories published on July 16, 1992 (57 FR 31576). The BSCP manufacturing source category 

was subsequently identified as a separate and distinct source category and was added to the list 

of source categories on July 22, 2002 (67 FR 47894).)

The BSCP standards were challenged by the Sierra Club and subsequently vacated by the 

United States Circuit Court for the District of Columbia on March 13, 2007, due to issues 

associated with the methodology used to determine the minimum regulatory “floors” for new and 

existing units. The EPA and Sierra Club later negotiated a consent decree to settle the litigation 

and set forth proposal and promulgation deadlines for reestablishing standards for this source 

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

2(b) Practical Utility/Users of the Data

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

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

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

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

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

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

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

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

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

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

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

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

need to be routinely reported to the EPA.

3. Nonduplication, Consultations and Other Collection Criteria

3(a) Nonduplication

The information required by the BSCP manufacturing NESHAP is not duplicated by 

existing EPA regulations and is not expected to be required by any other EPA rulemaking 

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

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

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

standards.

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

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

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

the proposed rule in the Federal Register.
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3(c) Consultations

Specific comments on the burden associated with the information collection requirements 

were received from the Brick Industry Association (BIA) and companies in the BSCP industry

for the 2003 rulemaking and have been incorporated in the burden estimates for this rule.

Representatives of BIA and its member companies have also been consulted during development 

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

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

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

subcategories, emissions data, MACT floor approach and alternative standards. No specific 

information was provided to the representatives with respect to burden estimates prior to 

proposal of the rule. Others consulted for information during the development process for the 

proposed standards included air pollution control device vendors (Encertec, McGill AirClean, 

Solios Environment, W.L. Gore and Associates and Cabot Norit Activated Carbon) and small 

business owners in the BSCP industry.

The EPA is providing a 60-day public comment period following proposal of the BSCP 

manufacturing NESHAP, during which all affected parties will be given the opportunity to 

comment on the proposed rule. The EPA will consider the comments received and, as 

appropriate, incorporate them into the final rule. This ICR will also be revised to incorporate the 

comments received.

3(d) Effects of Less Frequent Collection

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

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

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

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

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

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

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

regulated community benefit from preservation of our administrative powers. Also, the reporting 

frequency in the rule is consistent with the requirements of title V permit programs.

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

3(e) General Guidelines

The BSCP manufacturing NESHAP requires that facilities retain records for a period of 

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

guidelines in 5 CFR 1320.6(f) of OMB regulations implementing the Paperwork Reduction Act.

However, the 5-year retention period is consistent with the retention requirement in the General 

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

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

operating permits either through the state-approved permitting program or, if one does not exist, 

in accordance with the provisions of 40 CFR part 71. Thus, the 5-year record retention 

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

to retain onsite the most recent 2 years of data. The remaining 3 years of data could be retained at 
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a readily accessible onsite or offsite storage facility. None of the other guidelines in 5 CFR 

1320.6 are being exceeded.

3(f) Confidentiality

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

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

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

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

17674, March 23, 1979.)

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

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

of BSCP manufacturing facilities that are major sources of HAP emissions. The North American 

Industry Classification System (NAICS) code for respondents affected by the standards is 

327120—Clay Building Material and Refractories Manufacturing. Not all processes classified in 

this NAICS code are regulated by the standards.

4(b) Information Requested

(i) Data Items, Including Recordkeeping Requirements

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

Brick and Structural Clay Products Manufacturing (40 CFR part 63, subpart JJJJJ). The 

following table summarizes the recordkeeping and reporting requirements under the rule.

Requirements Rule Citation by Section

Notifications

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

63.8480(a)-(c)

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

63.8480(d)

Notification of compliance status (including performance test 

results, operating parameter values, bag leak detection system 

documentation and OM&M plan)

63.9(h), 63.10(d)(2) and

63.8480(e)

Request for routine control device maintenance exemption 63.8480(f)

Records

Record retention 63.10(b)(1) and 63.8495
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Requirements Rule Citation by Section

Documentation supporting initial notifications and notifications 

of compliance status

63.10(b)(2)(xiv) and 

63.8490(a)(1)

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

63.8490(a)(2)

Records of control device maintenance and documentation of 

approved routine control device maintenance exemption

63.8490(a)(3)

Records for each continuous monitoring system (CMS), 

production records, bag leak detection system records, records of 

operating limit deviations and corrective actions, maintenance 

and inspection records, records used to demonstrate compliance 

with work practice standards and malfunction records

63.8(d)(3), 63.8(g), 

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

63.8490(b)-(c)

OM&M plan 63.8490(c)(6)

Reports

First compliance report

Semi-annual compliance report:

 -No deviations/no out-of-control CMS

 -Deviations/out-of-control CMS

63.8485(b)-(f)

63.8485(b)-(f)

63.8485(c)(6)-(7)

63.8485(d)-(e)

Electronic submittal of performance test results (using ERT) 63.8485(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).

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

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

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

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

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

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

data.

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

5 years.

5(c) Small Entity Flexibility

The EPA is concerned about the proposed rule’s potential impacts on small entities, 

because 36 of 44 firms owning BSCP facilities have 750 or fewer employees and thus meet the 

Small Business Administration’s (SBA’s) criterion for a small entity in this industry (NAICS

code 327120). Consequently, the EPA conducted a screening analysis of the potential impacts, 

by computing the ratio of control costs to firm sales revenues. Based on the results of the 

screening analysis, the EPA concluded that it is not able to certify that the rule will not have a 

Significant Impact on a Substantial Number of Small Entities (SISNOSE). Pursuant to section 

603 of the Regulatory Flexibility Act (RFA), the EPA undertook an Initial Regulatory Flexibility 

Analysis (IRFA) that examined the impact of the BSCP proposed rule on small entities along 

with regulatory alternatives that could reduce that impact. The EPA also convened a Small 

Business Advisory Review panel to obtain advice and recommendations of representatives of the 

small entities that potentially would be subject to the BSCP proposed rule’s requirements. All of 

the panel’s recommendations have been addressed in the BSCP proposed rule.

The BSCP rule will allow the affected facilities up to 3 years from the effective date of 

the rule to comply. Under CAA section 112(i), the Administrator or the applicable regulatory 

authority also may grant 1 additional year if the owner or operator demonstrates that more time is 

needed to install controls for a source. This additional time will ease capital availability problems 

for plants in marginal economic condition that need to purchase and install new or upgraded 

emission controls.

5(d) Collection Schedule

Collection of data will begin after the effective date of the final BSCP manufacturing 

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

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

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

schedule for notifications and reports required by the rule is summarized below.

For facilities with existing affected kilns, the initial notification stating that the facility is 

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

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

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

subject to the rule (although we are projecting no new kilns in the short term). Facilities may 
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choose to submit a request for a routine control device maintenance exemption 30 days prior to 

the compliance date. Facilities required to conduct a performance test must submit a notification 

of intent to conduct a performance test at least 60 days before the performance test is scheduled 

to begin. For each 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 studies and background documents from the 

development of the regulation, Agency knowledge and experience with part 63 and other 

regulations, and the ICR for the 2003 BSCP rulemaking. In addition, comments and information 

received from the BIA and BSCP companies on the 2003 rulemaking were incorporated into the 

burden estimates.

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 

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 

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

NAICS code (327120) specified in Sections 4(a) and 5(c).
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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 or limestone feed rate) is included as part 

of the control system and, therefore, adds no additional capital or O&M cost. The capital/startup 

costs were estimated and annualized as described in Tables 1 through 3.

6(c) Estimating Agency Burden and Cost

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

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

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

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

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

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

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

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

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

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

presented in Tables 5 through 7.

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

Management labor rates for General Schedule employees 

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

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

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

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

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

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

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

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

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

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

“respondent universe.” Based on analyses of information collected from industry surveys,

operating permits and test reports, the EPA is projecting that 67 existing BSCP facilities will be 

subject to the BSCP rule, assuming that 25 BSCP facilities will become synthetic area sources 

rather than comply with the rule. Based on the latest BSCP industry profile, no new BSCP 

facilities or kilns are expected to be constructed in the near future, and existing capacity is 

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

6(e) Bottom Line Burden Hours and Costs/Master Tables

(i) Respondent Tally

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

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

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

an average of 45 responses per year. The estimated total burden for the 3-year period is 45,190

labor hours at a labor cost of $2,388,764. The average bottom line annual burden over the 3-year 

period is 15,063 labor hours at a labor cost of $796,255. There are no capital/startup costs that 

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

O&M cost for the 3-year period is estimated to be $2,948, with an average of $983 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 

308, with an average of 103 hours per year. The total cost over the 3-year period is $15,986. The 

average annual cost incurred during each year is $5,329.

(iii) Variations in the Annual Bottom Line

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

(1) existing facilities are not required to come into full compliance with the BSCP standards until 

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

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

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

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

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

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

also choose to submit a request for a routine control device maintenance exemption during the 

third year.

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

standards until 3 years after the effective date, much of the respondent burden does not occur 

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

respondent and Agency burden estimates for the fourth, fifth and sixth years following the 

effective date. During the fourth year when existing facilities are required to come into full 

compliance, the facilities would conduct inspections, submit a notification of intent to conduct a 

performance test, conduct an initial performance test (and, if necessary, a repeat performance 

test), submit a notification of compliance status, submit their test data to the EPA through EPA’s 

electronic reporting tool (ERT), submit their first compliance report and keep records of 

compliance data and malfunctions. During subsequent years, existing facilities would continue to

keep records and submit semi-annual reports. After the fourth year, burden estimates are not 

expected to vary considerably from year to year because facilities will be conducting ongoing 

activities (e.g., semi-annual compliance reports, recordkeeping, inspecting every 3 years, 
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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 337 hours per response. Burden means the total time, effort, 

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

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

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

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

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

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

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

transmit or otherwise disclose the information.

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

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

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

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

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

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

under Docket ID Number EPA-HQ-OAR-2013-0291. An electronic version of the public docket 

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

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

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

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

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

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

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

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

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

the Office of Information and Regulatory Affairs, Office of Management and Budget, Attention: 

Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503. Please include the EPA 

Docket ID Number EPA-HQ-OAR-2013-0291 in any correspondence.

Part B of the Supporting Statement

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

associated with the rule.
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Table 1. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP - Year 1

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read and understand rule requirements 2 1 2 67 134 6.7 13 $8,146

B. Required activities

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

Conduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct periodic kiln 

maintenance/inspections

20 1 20 0 0 0 0 $0

Conduct burner inspection and tune-up 20 1 20 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Initial notification of applicability d 2 1 2 67 134 6.7 13 $8,146

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

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

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

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

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

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

Report of performance test (through 

ERT)

4 1 4 0 0 0 0 $0

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

Semi-annual compliance reports

Deviations f 20 2 40 0 0 0 0 $0

No deviations f 8 2 16 0 0 0 0 $0
13

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

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

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

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

E. Time to enter information

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

Records of APCD 

maintenance/inspections

See 3B

Records of compliance with work 

practices

See 3B

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

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

G. Time to transmit/disclose information i 0.25 1 0.25 67 17 0.8 1.7 $1,018

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

285 14 28 $17,310

TOTAL ANNUAL NUMBER OF 

RESPONSES j

67

CAPITAL COSTS:

Initial performance tests k $0

Repeat performance tests l $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: m

Initial performance tests $0

Repeat performance tests $0
14

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Total annualized capital cost $0

ANNUAL O&M COSTS n

Photocopy/postage $1,474

Visible emissions tests $0

Total O&M cost $1,474

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$1,474

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

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

are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Person-hours per occurrence and number of occurrences per year were derived based on comments from BIA. d One-time only activities. e The notification of compliance status includes the performance test report. The cost burden associated with developing the performance test report is included in the 

performance test capital cost at the bottom of the table. f Assumes 15% of respondents have deviations to report in semiannual compliance reports and 85% report no deviations. g Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from BIA, an average of 2.5 plant personnel attend performance tests. 

Assume no travel for plant personnel. Assume testing takes 2, 12-hour days per plant. Repeat testing is also required 5 years following initial testing. h Based on comments from BIA, assumes 40 hours of training for 6 plant personnel. i

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

j

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. k Assumes EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl and Cl2. l

Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it. m Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t = 

equipment life (years). Performance testing costs annualized assuming a 5 year life and 7 percent interest. n O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., 

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

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

clearance period).

N/A = Not Applicable.
15

Table 2. Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP - Year 2

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required activities

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

Conduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct periodic kiln 

maintenance/inspections

20 1 20 0 0 0 0 $0

Conduct burner inspection and tune-up 20 1 20 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

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

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

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

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

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

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

Report of performance test (through 

ERT)

4 1 4 0 0 0 0 $0

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

Semi-annual compliance reports

Deviations f 20 2 40 0 0 0 0 $0

No deviations f 8 2 16 0 0 0 0 $0
16

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

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

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

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

E. Time to enter information

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

Records of APCD 

maintenance/inspections

See 3B

Records of compliance with work 

practices

See 3B

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

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

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

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

0 0 0 $0

TOTAL ANNUAL NUMBER OF 

RESPONSES j

0

CAPITAL COSTS:

Initial performance tests k $0

Repeat performance tests l $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: m

Initial performance tests $0

Repeat performance tests $0
17

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Total annualized capital cost $0

ANNUAL O&M COSTS n

Photocopy/postage $0

Visible emissions tests $0

Total O&M cost $0

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$0

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

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

are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Person-hours per occurrence and number of occurrences per year were derived based on comments from BIA. d One-time only activities. e The notification of compliance status includes the performance test report. The cost burden associated with developing the performance test report is included in the 

performance test capital cost at the bottom of the table. f Assumes 15% of respondents have deviations to report in semiannual compliance reports and 85% report no deviations. g Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from BIA, an average of 2.5 plant personnel attend performance tests. 

Assume no travel for plant personnel. Assume testing takes 2, 12-hour days per plant. Repeat testing is also required 5 years following initial testing. h Based on comments from BIA, assumes 40 hours of training for 6 plant personnel. i

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

j

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. k Assumes EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl and Cl2. l

Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it. m Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t = 

equipment life (years). Performance testing costs annualized assuming a 5 year life and 7 percent interest. n O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., 

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

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

clearance period).

N/A = Not Applicable.
18

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

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required activities

Develop OM&M plan c,d 100 1 100 67 6,700 335 670 $407,291

Conduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct periodic kiln 

maintenance/inspections

20 1 20 0 0 0 0 $0

Conduct burner inspection and tune-up 20 1 20 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

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

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

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

Request APCD maintenance exemption d 2 1 2 67 134 6.7 13 $8,146

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

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

Report of performance test (through

ERT)

4 1 4 0 0 0 0 $0

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

Semi-annual compliance reports

Deviations f 20 2 40 0 0 0 0 $0

No deviations f 8 2 16 0 0 0 0 $0
19

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

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

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

D. Develop record system 40 6 240 67 16,080 804 1,608 $977,499

E. Time to enter information

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

Records of APCD 

maintenance/inspections

See 3B

Records of compliance with work 

practices

See 3B

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

F. Time to train personnel c,h 40 6 240 67 16,080 804 1,608 $977,499

G. Time to transmit/disclose information i 0.25 1 0.25 67 17 0.8 1.7 $1,018

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

39,011 1,951 3,901 $2,371,454

TOTAL ANNUAL NUMBER OF 

RESPONSES j

67

CAPITAL COSTS:

Initial performance tests k $0

Repeat performance tests l $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: m

Initial performance tests $0

Repeat performance tests $0
20

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Total annualized capital cost $0

ANNUAL O&M COSTS n

Photocopy/postage $1,474

Visible emissions tests $0

Total O&M cost $1,474

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$1,474

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

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

are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Person-hours per occurrence and number of occurrences per year were derived based on comments from BIA. d One-time only activities. e The notification of compliance status includes the performance test report. The cost burden associated with developing the performance test report is included in the 

performance test capital cost at the bottom of the table. f Assumes 15% of respondents have deviations to report in semiannual compliance reports and 85% report no deviations. g Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from BIA, an average of 2.5 plant personnel attend performance tests. 

Assume no travel for plant personnel. Assume testing takes 2, 12-hour days per plant. Repeat testing is also required 5 years following initial testing. h Based on comments from BIA, assumes 40 hours of training for 6 plant personnel. i

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

j

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. k Assumes EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl and Cl2. l

Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it. m Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t = 

equipment life (years). Performance testing costs annualized assuming a 5 year life and 7 percent interest. n O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., 

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

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

clearance period).

N/A = Not Applicable.
21

Table 4. Summary of Respondent Burden and Cost of the BSCP 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 67 285 14 28 327 $17,310 $0 $0 $1,474 $1,474

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

Year 3 67 39,011 1,951 3,901 44,862 $2,371,454 $0 $0 $1,474 $1,474

Totals 134 39,296 1,965 3,930 45,190 $2,388,764 $0 $0 $2,948 $2,948

Average 45 15,063 $796,255 $0 $0 $983 $983
22

Table 5. Annual Burden and Cost to the Federal Government of the BSCP 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 67 134 6.7 13 $7,993

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

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

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

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

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

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

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

TOTAL BURDEN AND COST (SALARY) 134 6.7 13 $7,993

Travel Expenses for Tests Attended i $0

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$7,993

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

anticipated to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours 

are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
23

c Assumes Agency personnel will attend performance tests at 10% of plants.

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

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

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

Assumes Agency personnel (1 person) will spend 2 days per plant plus time for travel, at $50 per diem per day, and $400 transportation expense per round trip to attend 

performance tests.

N/A = Not applicable.
24

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

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

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

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

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

Travel Expenses for Tests Attended i $0

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$0

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

anticipated to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours 

are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
25

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

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

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

Assumes Agency personnel (1 person) will spend 2 days per plant plus time for travel, at $50 per diem per day, and $400 transportation expense per round trip to attend 

performance tests.

N/A = Not applicable.
26

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 for APCD maintenance exemption 2 1 2 67 134 6.7 13 $7,993

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

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

TOTAL BURDEN AND COST (SALARY) 134 6.7 13 $7,993

Travel Expenses for Tests Attended i $0

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$7,993

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

anticipated to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours 

are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
27

c Assumes Agency personnel will attend performance tests at 10% of plants.

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

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests. g Notification of compliance status includes the performance test report. h Assumes 15% of the plants report deviations semiannually and 85% report no deviations. i

Assumes Agency personnel (1 person) will spend 2 days per plant plus time for travel, at $50 per diem per day, and $400 transportation expense per round trip to attend 

performance tests.

N/A = Not applicable.
28

Table 8. Summary of Burden and Cost to the Federal Government of the BSCP NESHAP - Years 1 to 3

Year Technical hours Management hours Clerical Hours Total hours Labor costs

Year 1 134 6.7 13 154 $7,993

Year 2 0 0 0 0 $0

Year 3 134 6.7 13 154 $7,993

Totals 268 13 27 308 $15,986

Average 103 $5,329
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 BSCP NESHAP - Year 4

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required activities

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

Conduct APCD maintenance/inspections 20 1 20 67 1,340 67 134 $81,458

Conduct periodic kiln 

maintenance/inspections

20 1 20 67 1,340 67 134 $81,458

Conduct burner inspection and tune-up 20 1 20 67 1,340 67 134 $81,458

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

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

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

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

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

Notification of performance test 2 1 2 67 134 6.7 13 $8,146

Notification of compliance status e 16 1 16 67 1,072 54 107 $65,167

Report of performance test (through 

ERT)

4 1 4 67 268 13 27 $16,292

First compliance report 16 1 16 67 1,072 54 107 $65,167

Semi-annual compliance reports

Deviations f 20 2 40 0 0 0 0 $0

No deviations f 8 2 16 0 0 0 0 $0
1-3

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

Prepare for initial performance test c 24 1 24 67 1,608 80 161 $97,750

Prepare for repeat performance test c 24 1 24 6.7 161 8.0 16 $9,775

C. Implement activities

Attend initial performance test c,g 24 2.5 60 67 4,020 201 402 $244,375

Attend repeat performance test c,g 24 2.5 60 6.7 402 20 40 $24,437

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

E. Time to enter information

Records of compliance data c 6 52 312 67 20,904 1,045 2,090 $1,270,749

Records of APCD 

maintenance/inspections

See 3B

Records of compliance with work 

practices

See 3B

Records of malfunctions 2 12 24 67 1,608 80 161 $97,750

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

G. Time to transmit/disclose information i 0.25 1 0.25 67 17 0.8 1.7 $1,018

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

35,286 1,764 3,529 $2,145,000

TOTAL ANNUAL NUMBER OF 

RESPONSES j

268

CAPITAL COSTS:

Initial performance tests k $977,420

Repeat performance tests l $97,742

Total capital cost $1,075,162

ANNUALIZED CAPITAL COSTS: m

Initial performance tests $238,290

Repeat performance tests $23,829
1-4

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Total annualized capital cost $262,119

ANNUAL O&M COSTS n

Photocopy/postage $5,896

Visible emissions tests $346,144

Total O&M cost $352,040

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$614,159

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

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

are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Person-hours per occurrence and number of occurrences per year were derived based on comments from BIA. d One-time only activities. e The notification of compliance status includes the performance test report. The cost burden associated with developing the performance test report is included in the 

performance test capital cost at the bottom of the table. f Assumes 15% of respondents have deviations to report in semiannual compliance reports and 85% report no deviations. g Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from BIA, an average of 2.5 plant personnel attend performance tests. 

Assume no travel for plant personnel. Assume testing takes 2, 12-hour days per plant. Repeat testing is also required 5 years following initial testing. h Based on comments from BIA, assumes 40 hours of training for 6 plant personnel. i

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

j

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. k Assumes EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl and Cl2. l

Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it. m Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t = 

equipment life (years). Performance testing costs annualized assuming a 5 year life and 7 percent interest. n O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., 

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

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

clearance period).

N/A = Not Applicable.
1-5

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

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required activities

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

Conduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct periodic kiln 

maintenance/inspections

20 1 20 0 0 0 0 $0

Conduct burner inspection and tune-up 20 1 20 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

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

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

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

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

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

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

Report of performance test (through 

ERT)

4 1 4 0 0 0 0 $0

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

Semi-annual compliance reports

Deviations f 20 2 40 10 402 20 40 $24,437

No deviations f 8 2 16 57 911 46 91 $55,392
1-6

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

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

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

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

E. Time to enter information

Records of compliance data c 6 52 312 67 20,904 1,045 2,090 $1,270,749

Records of APCD 

maintenance/inspections

See 3B

Records of compliance with work 

practices

See 3B

Records of malfunctions 2 12 24 67 1,608 80 161 $97,750

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

G. Time to transmit/disclose information i 0.25 1 0.25 67 17 0.8 1.7 $1,018

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

23,842 1,192 2,384 $1,449,346

TOTAL ANNUAL NUMBER OF 

RESPONSES j

134

CAPITAL COSTS:

Initial performance tests k $0

Repeat performance tests l $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: m

Initial performance tests $238,290

Repeat performance tests $23,829
1-7

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Total annualized capital cost $262,119

ANNUAL O&M COSTS n

Photocopy/postage $2,948

Visible emissions tests $346,144

Total O&M cost $349,092

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$611,211

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

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

are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Person-hours per occurrence and number of occurrences per year were derived based on comments from BIA. d One-time only activities. e The notification of compliance status includes the performance test report. The cost burden associated with developing the performance test report is included in the 

performance test capital cost at the bottom of the table. f Assumes 15% of respondents have deviations to report in semiannual compliance reports and 85% report no deviations. g Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from BIA, an average of 2.5 plant personnel attend performance tests. 

Assume no travel for plant personnel. Assume testing takes 2, 12-hour days per plant. Repeat testing is also required 5 years following initial testing. h Based on comments from BIA, assumes 40 hours of training for 6 plant personnel. i

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

j

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. k Assumes EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl and Cl2. l

Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it. m Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t = 

equipment life (years). Performance testing costs annualized assuming a 5 year life and 7 percent interest. n O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., 

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

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

clearance period).

N/A = Not Applicable.
1-8

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

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required activities

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

Conduct APCD maintenance/inspections 20 1 20 0 0 0 0 $0

Conduct periodic kiln 

maintenance/inspections

20 1 20 0 0 0 0 $0

Conduct burner inspection and tune-up 20 1 20 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

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

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

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

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

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

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

Report of performance test (through 

ERT)

4 1 4 0 0 0 0 $0

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

Semi-annual compliance reports

Deviations f 20 2 40 10 402 20 40 $24,437

No deviations f 8 2 16 57 911 46 91 $55,392
1-9

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

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

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

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

E. Time to enter information

Records of compliance data c 6 52 312 67 20,904 1,045 2,090 $1,270,749

Records of APCD 

maintenance/inspections

See 3B

Records of compliance with work 

practices

See 3B

Records of malfunctions 2 12 24 67 1,608 80 161 $97,750

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

G. Time to transmit/disclose information i 0.25 1 0.25 67 17 0.8 1.7 $1,018

TOTAL ANNUAL BURDEN AND COST 

(SALARY)

23,842 1,192 2,384 $1,449,346

TOTAL ANNUAL NUMBER OF 

RESPONSES j

134

CAPITAL COSTS:

Initial performance tests k $0

Repeat performance tests l $0

Total capital cost $0

ANNUALIZED CAPITAL COSTS: m

Initial performance tests $238,290

Repeat performance tests $23,829
1-10

Burden item

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

Personhours per 

occurrence

No. of 

occurrences per 

respondent per 

year

Personhours per 

respondent 

per year

Respondents 

per year a

Technical 

person- hours 

per year

Management 

person-hours 

per year

Clerical 

personhours per 

year Cost,$ b

(C=A×B) (E=C×D) (E×0.05) (E×0.1)

Total annualized capital cost $262,119

ANNUAL O&M COSTS n

Photocopy/postage $2,948

Visible emissions tests $346,144

Total O&M cost $349,092

TOTAL ANNUALIZED COSTS 

(Annualized capital + O&M costs)

$611,211

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

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

are assumed to be 5 percent and 10 percent of technical person-hours, respectively. c Person-hours per occurrence and number of occurrences per year were derived based on comments from BIA. d One-time only activities. e The notification of compliance status includes the performance test report. The cost burden associated with developing the performance test report is included in the 

performance test capital cost at the bottom of the table. f Assumes 15% of respondents have deviations to report in semiannual compliance reports and 85% report no deviations. g Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from BIA, an average of 2.5 plant personnel attend performance tests. 

Assume no travel for plant personnel. Assume testing takes 2, 12-hour days per plant. Repeat testing is also required 5 years following initial testing. h Based on comments from BIA, assumes 40 hours of training for 6 plant personnel. i

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

j

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. k Assumes EPA Method 29 for PM/metals and EPA Method 26A for HF, HCl and Cl2. l

Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it. m Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t = 

equipment life (years). Performance testing costs annualized assuming a 5 year life and 7 percent interest. n O&M costs for photocopying and postage estimated as $22/report. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., 

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

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

clearance period).

N/A = Not Applicable.
1-11

Table 1-4. Summary of Respondent Burden and Cost of the BSCP 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 4 268 35,286 1,764 3,529 40,578 $2,145,000 $1,075,162 $262,119 $352,040 $614,159

Year 5 134 23,842 1,192 2,384 27,418 $1,449,346 $0 $262,119 $349,092 $611,211

Year 6 134 23,842 1,192 2,384 27,418 $1,449,346 $0 $262,119 $349,092 $611,211

Totals 536 82,969 4,148 8,297 95,415 $5,043,692 $1,075,162 $786,357 $1,050,224 $1,836,581

Average 179 31,805 $1,681,231 $358,387 $262,119 $350,075 $612,194
1-12

Table 1-5. Annual Burden and Cost to the Federal Government of the BSCP 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 6.7 161 8.0 16 $9,591

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0.7 5 0.3 0.5 $320

Retesting 24 1 24 0.7 16 0.8 1.6 $959

3. Litigation e 2,080 1 2,080 0.7 1,394 70 139 $83,125

4. Excess emissions enforcement activities f 48 1 48 3.4 161 8 16 $9,591

5. Report review

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

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

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

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

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

Notification of performance test 2 1 2 67 134 6.7 13 $7,993

Notification of compliance status g 60 1 60 67 4,020 201 402 $239,785

Repeat performance test report d 40 1 40 6.7 268 13 27 $15,986

First compliance report 4 1 4 67 268 13 27 $15,986

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

TOTAL BURDEN AND COST (SALARY) 6,427 321 643 $383,336

Travel Expenses for Tests Attended i $5,360

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$388,696

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

anticipated to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours 

are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
1-13

c Assumes Agency personnel will attend performance tests at 10% of plants.

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

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

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

Assumes Agency personnel (1 person) will spend 2 days per plant plus time for travel, at $50 per diem per day, and $400 transportation expense per round trip to attend 

performance tests.

N/A = Not applicable.
1-14

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 0.7 1,394 70 139 $83,125

4. Excess emissions enforcement activities f 48 1 48 3.4 161 8.0 16 $9,591

5. Report review

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

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

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

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

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

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

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

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 10 161 8.0 16 $9,591

No deviations h 2 2 4 57 228 11 23 $13,588

TOTAL BURDEN AND COST (SALARY) 1,943 97 194 $115,896

Travel Expenses for Tests Attended i $1,675

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$117,571

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

anticipated to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours 

are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
1-15

c Assumes Agency personnel will attend performance tests at 10% of plants.

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

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

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

Assumes Agency personnel (1 person) will spend 2 days per plant plus time for travel, at $50 per diem per day, and $400 transportation expense per round trip to attend 

performance tests.

N/A = Not applicable.
1-16

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 0.7 1,394 70 139 $83,125

4. Excess emissions enforcement activities f 48 1 48 3.4 161 8.0 16 $9,591

5. Report review

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

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

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

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

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

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

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

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 10 161 8.0 16 $9,591

No deviations h 2 2 4 57 228 11 23 $13,588

TOTAL BURDEN AND COST (SALARY) 1,943 97 194 $115,896

Travel Expenses for Tests Attended i $1,675

TOTAL ANNUAL COST (SALARY + 

EXPENSES)

$117,571

a A total of 67 existing major sources are expected to comply during the 3-year ICR clearance period. Based on the latest BSCP industry profile, no new kilns are 

anticipated to be constructed in the near future, and existing capacity is assumed sufficient to cover any short-term increases in production. b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person-hours and clerical person-hours 

are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
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c Assumes Agency personnel will attend performance tests at 10% of plants.

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

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

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

Assumes Agency personnel (1 person) will spend 2 days per plant plus time for travel, at $50 per diem per day, and $400 transportation expense per round trip to attend 

performance tests.

N/A = Not applicable.
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Table 1-8. Summary of Burden and Cost to the Federal Government of the BSCP NESHAP - Years 4 to 6

Year Technical hours Management hours Clerical Hours Total hours Labor costs

Year 4 6,427 321 643 7,391 $388,696

Year 5 1,943 97 194 2,234 $117,571

Year 6 1,943 97 194 2,234 $117,571

Totals 10,313 516 1,031 11,860 $623,838

Average 3,953 $207,946