### 1 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

National Emission Standards f or Haza rdous Air Pollutants for Brick a nd Structural Clay

Products Manufacturing

(40 C FR Part 63, Subpart JJJJJ)

September 2015

Part A o f t he Supporting Statement

1.0 Identification of the Information Collection

1 (a) Title and Number of the Information Collection

“ National Emission Standards for Hazardous Air Pollutants for 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 faci lities 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

t unnel and periodic kilns at BSCP facilities.

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

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

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

. 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

9 0 existing BSCP facilities that are currently major sources of HAP . An estimated 2 1 of these

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

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

comply wit h subpart JJJJJ

. The remaining 69 existing BSCP facilities are expected to be subject

to the rule , of which 63 are equipped with tunnel kilns, 15 with periodic kilns, and 24 with air

pollution control devices (APCDs)

. Based on the latest BSCP industry prof ile, no new BSCP

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

assumed to be sufficient to cover any short

- term increases in production

.

Respondents must submit one

- time 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 repor ts for periods of emission

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

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

, performance 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 dat a 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 lime stone adsorbers (DLA) include limestone feed

rate monitoring

, periodic VE de terminations 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

monito ring 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 determina tions 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) Ne ed/Authority for the Collection

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

establish emission st andards 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, s ec tion 114 of

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

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

that t he Administrator may require any own er or opera t or subject to any requirement of the CAA

to:

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

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

or methods; (D) sample such emissions; (E) keep records o n 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

Adminis trator may reasonably require.

The predominant HAP emitted from BSCP manufacturing facilities include hydrogen

fluoride (HF), hydrogen chloride (HCl), chlorine (Cl 2 

### ) 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

### 3 contribute significantly to air pollution that may reasonably be anticipated to endanger public

health. Consequently, NESHAP for this source category were promulgated at 40 CFR part 63,

subpart 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).)

Th e 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 wit h 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 re establishing standard s for th is source

category

. Consequently, new NESHAP for this source category are being pro posed

.

2 (b) Prac tical Utility/Users of the Data

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

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

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

(3) ensure that the emission control devices are being 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 practic e 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 repor ted 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 r ulemaking

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

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

or local agency may be provided to the Administrat or 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 co mment period following publication of

the proposed rule in the Federal Register

.

### 4 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

. R epresentatives 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, emiss ions 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

pr oposed 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 provided a 90

- day public comme nt period following proposal of the BSCP

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

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

appropriate, incorporate d them into the final rule. This ICR was also revised to inc orporate 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 a pplying 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 ass essment 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 t itle 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 re gulations 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 und er 40 CFR part 70. All facilities subject to this rule will be required to obtain

operating permits either through the s tate

- 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

### 5 a readily accessible onsite or offsite storage fac ility. 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, P art 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 r espondents 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 af fected by the standards is

3271 2 0

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

t his 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 Manufact uring (40 CFR part 63, subpart JJJJJ). T he

following t able 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)

- ( b )

Notification of performance test 63.7(b)

- (c), 63.9(e) and

63.8480( a )

- ( b )

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( a )

- ( c )

Request to use routine control device maintenance alternative

standard 63.8480( b )

### 6 Requirements Rule Citation by Section

Records

Record retention 63.10(b)(1) and 63.8495

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 request 63.8490(a)(3)

Records for each cont inuous 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(a )

- ( e )

63.8485(a )

- (e )

63.8485(c)(6)

- (7)

63.8485( c)(9), ( d)

- (e)

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

(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 t he effective date of the rule are

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

5 (b) Collection Methodology and Management

Following 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

### 7 compliance and enforcement programs. The semiannua l reports are used for problem

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

determinations.

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

, which is operated and maintained by th e 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 enf orcement 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 opera tor for

5 years.

5 (c) Small Entity Flexibility

The EPA is concerned about the proposed rule’s potential impacts o n 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 a nalysis, 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 were addressed in the BSCP proposed rule. As required by section

604 of the RFA, the EPA prepared a F inal Regulatory F lexibility A nalysis (FRFA) for the BSCP

final rule . The FRFA addresses the issues raised by public comments on the IRFA for the BSCP

proposed rule.

The BSCP rule will allow the affected facilities up to 3 years from the effect ive 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 additi onal time w ill 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 BS CP 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

### 8 before the effective date, or upon startup if th e 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

choose to submit a request to use the routine control device maintenance alternative standard no

later than 120 days prior to the compliance dat e. 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

performanc e 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 a n 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 s ubmitted to the

Administrator on a semi

- annual basis. Repeat performance tests are to be conducted every

5 years to ensure ongoing compliance.

6. Estimating the Bu rden and Cost of the Collection

6 (a) Estimating Respondent Burden

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

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

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

regulation s

, and BSCP industry comments on the proposed rule, including burden estimates from

a recent BIA survey of the BS CP industry

.

6 (b) Estimating Respondent Costs

(i) Estimating Labor Costs

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

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

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

NAICS code 3271 0 0

— Clay Product and Refractory Manufacturing

( http://www.bls.gov/ oe s/ 2013/may/naics4_327100 .htm ). 1 

### Labor costs are divided into the

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

including fringe benefits, reported by BLS for May 20 13 (the most recent rates available) are

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

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

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

NAICS code (327120) specified in Sections 4(a) and 5(c).

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

management and $ 31.90 for clerical.

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

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

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

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

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

-

minute VE te st and preparing for/documenting the VE test

. The monitoring equipment needed to

monitor parameters other than VE (e.g., lime or limestone f eed rate) is included as part of the

control system and

, therefore

, adds no additional capital or O&M cost. No capital/startup costs

were expected to be incurred during the first 3 years after the effective date of the rule

.

6 (c) Es timating Agency Burden and Cost

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

because the i nformation 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 incurr ed by

the f ederal g overnment. Publication and distribution of the information are part of the AFS

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

of records to be maintained by the respondents will occur in cidentally 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 f ederal

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

presented in Tables 5 through 7.

Labor rates for f ederal employees are based on the January 20 1 2, Office of Personnel

Management labor rates for General Schedule employees

( http://www.opm.gov/oca /1 2tables/ 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

standar d 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 e ach 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, t he EPA is projec ting that 69 existing BSCP major source

facilities will be subject to the BSCP rule, assuming that 22 BSCP facilities will become

synthetic area sources rather than comply with the rule

. Of these 69 facilities

, 63 are equipped

with tunnel kilns, 15 with pe riodic kilns, and 24 with APCDs. Based on the latest BSCP industry

### 10 profile, no new BSCP facilities or kilns are expected to be construct ed in the near future, and

existing capacity is assumed to be sufficient to cover any short

- term increases in production

.

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

(i) Respondent Tally

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

3 (one table for each year), are calculated by adding person

- hours per year down each column for

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

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

burden over the 3

- year period

. The total number of r esponses over the 3

- year period is 93 , with

an average of 31 responses pe r year. The estimated total burden for the 3

- year period is 62,890

labor hours at a labor cost of $ 3, 339,316

. The average bottom line annual burden over the 3

- year

period is 20,963 la bor hours at a labor cost of $ 1,113,105

. The re are no capital/s tartup 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, 046 , with an average of $ 682 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 c olumn 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

214 , with an average of 71 hours per year. The total cost over the 3

- year period is $ 11,095

. The

average annual cost incurred during each year is $ 3,698

.

(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 train ing personnel on how to record information. Facilities may

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

during the third year.

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

standards until 3 years after the effective date and no new BSCP kilns are anticipated to be

constructed in the near future , much of the respondent burden does not occur until the fourth year

following the effective date

. Attachment 1 contains tables showing respondent and Agency

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

. During the

### 11 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 report ing 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 a re not expected to vary

considerably from year to year because facilities will be conducting ongoing activities (e.g.,

semi

- annual compliance reports, recordkeeping, inspecting every 3 years, retesting every

5 years) as opposed to the one

- time activities ( e.g., developing OM&M plan, submitting

notifications) that occur in the first 4 years following the effective date

.

6 (

f) Reasons for Change in Burden

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

6 (g) Burden Statement

The average annual pub lic reporting and recordkeeping burden for this collection of

information is estimated to average 676 hours per response. Burden means the total time, effort,

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

information to or for a f ederal agency. 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 info rmation 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 revie w 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

- 201 3

- 0291 . An electronic version of the public docket

is available at http://www.regulations.gov/ which may be use d 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, selec t “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 Pub lic 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 Offic e of Information and Regulatory Affairs, Offic e of Management and Budget , Attention:

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

Docket ID Number EPA

- HQ

- OAR

- 201 3

- 0291 in any correspondence.

Part B o f t he Supporti ng Statement

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

associated with the rule

.

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

- Year 1

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

Person

h our s per

occurrence a No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

1. Applications N / A

2. Survey and Studies N / A

3. Reporting Requirements

A. Read and understand rule requirements d 12 1 12 69 414 414 0 $58,676

B. Required activities

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

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

C onduct APCD maintenance/inspections 30 1 30 0 0 0 0 $0

Conduct periodic kiln maintenance/

inspections 160 1 160 0 0 0 0 $0

Conduct burner inspection and tune

- up 40 1 40 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Initial notification of applicability e 6 1 6 69 414 21 41 $25,167

Notificat ion of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notific ation of anticipated startup e 3 1 3 0 0 0 0 $0

No tification of actual startup e 3 1 3 0 0 0 0 $0

R equest to use APCD maintenance

alternative standard e 4 1 4 0 0 0 0 $0

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

Notif ication of compliance status e,f 24 1 24 0 0 0 0 $0

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

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

Semi

- annual compliance reports

D eviations g 30 2 60 0 0 0 0 $0

No deviations g 12 2 24 0 0 0 0 $0

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

Person

h our s per

occurrence a No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

(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 24 1 24 0 0 0 0 $0

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

C. Implement activities

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

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

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

E. Time to enter information

Records of compliance data 8 52 416 0 0 0 0 $0

Records of APCD maintenance/

inspections See 3B

Records of compliance with work

practices See 3B

Records of deviations 2 12 24 0 0 0 0 $0

F. Time to train personnel i

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 0 0 0 0 $0

G. Time to transmit / disclose information j 0.25 1 0.25 69 17 0.9 1.7 $1,049

TOTAL ANNUAL BURDEN AND COST

(SALARY) 845 436 43 $ 84,891

TOTAL ANNUAL NUMBER OF

RESPONSES k 69

CAPITAL COSTS:

Initial performance tests l $0

Repeat performance tests m $0

Total capital cost $0

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

Person

h our s per

occurrence a No. of

occurrences per

respondent per

year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

ANNUALIZED CAPITAL COSTS: n

Initial performance tests l $0

Repeat performance tests m $0

Total annualized capital cost $0

ANNUAL O&M COSTS o

Photocopy/postage $1, 518

Visible emissions tests l $0

Total O&M cost $1, 518

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $1, 518

a Person

- hours per occurrence were derived based on comments from industry.

b A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs. 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.

c Costs are based on the following hourly rat es: technical at $53.17, management at $ 88.56, and clerical at $31.90. Management person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

d Assumes one

- time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among

technical and management staff.

e One

- time only activities.

f The notification of compliance status includes the performance test report and documenta tion of any other ini tial compliance demonstration. The cost burden

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table.

g Assumes 15% of respondents have deviations to report i n semiannual compliance reports, and 85% report no deviations.

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

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

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

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

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

l Based on estimates in BSCP Impacts Memo. Stack testing costs assume EP A Method 29 for PM/metals and EPA Method 26A for HF, HCl, and Cl 2 . VE testing

costs assume EPA Method 22.

m Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it.

n Annualized costs are calculated by multiplying the ca pital recovery fac tor (CRF) by the capital cost. CRF=(i)*(1+i) t /((1+i) t

- 1) where i = interest rate (%) and t =

equipment life (years)

.

### 16 o O&M costs for photocopying and posta ge estimated as $22/report. The monitoring equipment needed to monitor parameters o ther than visible emissions (e.g.,

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

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

- minute VE test, and preparing for/documenting the VE test (occurs after 3

- year

ICR clearance period).

N/A = Not Applicable.

### 17 Table 2 . Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP

- Year 2

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

1. Applications N/ A

2. Survey and Studies N /A

3. Reporting Requirements

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

B. Required activities

Develop OM&M plan e 2 00 1 2 00 0 0 0 0 $0

Update OM&M plan 10

C onduct APCD maintenance/inspections 3 0 1 3 0 0 0 0 0 $0

Conduct periodic kiln maintenance/

inspections 16 0 1 16 0 0 0 0 0 $0

Conduct burner inspection and tune

- up 4 0 1 4 0 0 0 0 0 $0

C. Create information See 3 B

D. Gather existing information See 3 B

E. Write report

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

Notificat ion of constr

. /reconstr. e 2 8 1 2 8 0 0 0 0 $0

Notific ation of anticipated startup e 3 1 3 0 0 0 0 $0

No tification of actual startup e 3 1 3 0 0 0 0 $0

R equest to use APCD maintenance

alternative standard e 4 1 4 0 0 0 0 $0

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

Notif ication of compliance status e ,f 24 1 24 0 0 0 0 $0

Report of performance test (through

ERT) 20 1 20 0 0 0 0 $0

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

Semi

- annual compliance reports

D eviations g 30 2 60 0 0 0 0 $0

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

No deviations g 12 2 24 0 0 0 0 $0

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

Attend initial performance test h 3 4 2.5 85 0 0 0 0 $0

Attend repeat performance test h 3 4 2.5 85 0 0 0 0 $0

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

E. Time to enter information

Records of compliance data 8 52 416 0 0 0 0 $0

Records of APCD maintenance/

inspections See 3B

Records of compliance with work

practices See 3B

Records of deviation s 2 12 24 0 0 0 0 $0

F. Time to train personnel i

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 0 0 0 0 $0

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

TOTAL ANNUAL BURDEN AND COST

(SALARY) 0 0 0 $ 0

TOTAL ANNUAL NUMBER OF

RESPONSES k 0

CAPITAL COSTS:

Initial performance tests l $0

Repeat performance tests m $0

Total capital cost $0

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

ANNUALIZED CAPITAL COSTS: n

Initial performance tests l $0

Repeat performance tests m $0

Total annualized capital cost $0

ANNUAL O&M COSTS o

Photocopy/postage $ 0

Visible emissions tests l $0

Total O&M cost $ 0

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $ 0

a Person

- hours per occurrence were derived based on comments from industry.

b A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs. 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.

c Costs are based on the following hourly rat es: technical at $53.17, management at $ 88.56, and clerical at $31.90. Management person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

d Assumes one

- time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among

technical and management staff.

e One

- time only activities.

f The notification of compliance status includes the performance test report and documenta tion of any other ini tial compliance demonstration. The cost burden

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table.

g Assumes 15% of respondents have deviations to report i n semiannual compliance reports, and 85% report no deviations.

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

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

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

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

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

l Based on estimates in BSCP Impacts Memo. Stack testing costs assume EP A Method 29 for PM/metals and EPA Method 26A for HF, HCl, and Cl 2 . VE testing

costs assume EPA Method 22.

m Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it.

n Annualized costs are calculated by multiplying the ca pital recovery fac tor (CRF) by the capital cost. CRF=(i)*(1+i) t /((1+i) t

- 1) where i = interest rate (%) and t =

equipment life (years)

.

### 20 o O&M costs for photocopying and posta ge estimated as $22/report. The monitoring equipment needed to monitor parameters o ther than visible emissions (e.g.,

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

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

- minute VE test, and preparing for/documenting the VE test (occurs after 3

- year

ICR clearance period).

N/A = Not Applicable.

### 21 Table 3 . Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the BSCP NESHAP

- Year 3

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ c

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

1. Applications N/ A

2. Survey and Studies N /A

3. Reporting Requirements

A. Read and understand rule requirements d 12 1 12 0 0 0 0 $0

B. Required activities

Develop OM&M plan e 200 1 200 63 12,600 630 1,260 $765,951

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

C onduct APCD maintenance/inspections 30 1 30 0 0 0 0 $0

Conduct periodic kiln maintenance/

inspections 160 1 160 0 0 0 0 $0

Conduct burner inspection and tune

- up 40 1 40 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

Notificat ion of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notific ation of anticipated startup e 3 1 3 0 0 0 0 $0

No tification of actual startup e 3 1 3 0 0 0 0 $0

R equest to use APCD maintenance

alternative standard e 4 1 4 24 96 4.8 10 $5,836

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

Notif ication of compliance status e,f 24 1 24 0 0 0 0 $0

Report of performance test (through

ERT) 20 1 20 0 0 0 0 $0

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

Semi

- annual compliance reports

D eviations g 30 2 60 0 0 0 0 $0

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ c

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

No deviations g 12 2 24 0 0 0 0 $0

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

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

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

D. Develop record system 60 6 360 63 22,680 1,134 2,268 $1,378,712

E. Time to enter information

Records of compliance data 8 52 416 0 0 0 0 $0

Records of APCD maintenance/

inspections See 3B

Records of compliance with work

practices See 3B

Records of deviations 2 12 24 0 0 0 0 $0

F. Time to train personnel i

Initial training 48 6 288 63 18,144 907 1,814 $1,102,969

Annual training 10 6 60 0 0 0 0 $0

G. Time to transmit / disclose information j 0.25 1 0.25 63 16 0.8 1.6 $957

TOTAL ANNUAL BURDEN AND COST

(SALARY) 53,536 2,677 5,354 $3,254,425

TOTAL ANNUAL NUMBER OF

RESPONSES k 24

CAPITAL COSTS:

Initial performance tests l $0

Repeat performance tests m $0

Total capital cost $0

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ c

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

ANNUALIZED CAPITAL COSTS: n

Initial performance tests l $0

Repeat performance tests m $0

Total annualized capital cost $0

ANNUAL O&M COSTS o

Photocopy/postage $ 528

Visible emissions tests l $0

Total O&M cost $ 528

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $ 528

a Person

- hours per occurrence were derived based on comments from industry.

b A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs. Based on the latest BSCP industry profile, no new kilns are anticipa ted to be constructed in the near future, and existing capacity is

assumed sufficient to cover any short

- term increases in production.

c Costs are based on the following hourly rates: technical at $53.17, management at $ 88.56, and clerical at $31.90. Manag ement person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

d Assumes one

- time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requir ements, divided equally among

technical and management staff.

e One

- time only activities.

f The notification of compliance status includes the performance test report and documentation of any other ini tial compliance demonstration. The cost burden

associat ed with developing the performance test report is included in the performance test capital cost at the bottom of the table.

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

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

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

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

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

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

l Based on estimates in BSCP Impacts Memo. Stack testing costs assume EPA Method 29 for PM/metals and EPA Method 26A for HF, HC l, and Cl 2 . VE testing

costs assume EPA Method 22.

m Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it.

n Annualized costs are calculated by multiplying the capital recovery fac tor (CRF) by the capital cost. CRF=(i)*(1+i) t / ((1+i) t

- 1) where i = interest rate (%) and t =

equipment life (years)

.

### 24 o O&M costs for photocopying and posta ge 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 a dditional 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 th e VE test (occurs after 3

- year

ICR clearance period).

N/A = Not Applicable.

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

- Years 1 t o 3

Year No.

responses Total

hours Labor costs Non

- Labor Costs

Technical

hours Management

hours Clerical

Hours Capital Annualized

capital Annual

O&M Total

annualized cost

Year 1 69 845 436 43 1,324 $84,891 $0 $0 $1,518 $1,518

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

Year 3 24 53,536 2,677 5,354 61,566 $3,254,425 $0 $0 $528 $528

Totals 93 54,381 3,112 5,397 62,890 $3,339,316 $0 $0 $2,046 $2,046

Average 31 20,963 $1,113,105 $0 $0 $682 $682

### 26 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

person

hours per

occurrence No. of

occurrences

per plant per

year EPA

person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ b

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

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

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

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

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

5. Report review

Initial notification of applicability 2 1 2 69 13 8 6. 9 14 $ 8,231

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

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

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

Request to use APCD maintenance alternative

standard 2 1 2 0 0 0 0 $0

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

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

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) 138 6.9 14 $ 8,231

Travel Expenses for Tests Attended i $0

TOTAL ANNUAL COST (SALARY +

EXPENSES) $8,231

a A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period , of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs . 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.

### 27 b Costs ar e based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

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

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests.

e Assumes 1% of plants will be involved in litigation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of th e retests.

g Notification of compliance status includes the performance test report.

h Assumes 15% of the plants r eport 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 trans portation expense per round trip to

attend performance tests.

### 28 Tabl e 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

person

hours per

occurrence No. of

occurrences

per plant per

year EPA

person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ b

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

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

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

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

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

5. Report review

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

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

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

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

Request to use APCD maintenance alternative

standard 2 1 2 0 0 0 0 $0

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

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

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 69 existing major sources are expected to comply during the 3

- year ICR clearance period , of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs . Based on the latest BSCP industry profile, no new kilns are anticipated to be cons tructed in the near future, and existing capacity is

assumed sufficient to cover any short

- term increases in production.

### 29 b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person

- ho urs and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

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

d Assumes 10% of plants will fail an initial performance test and m ust 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 t he 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 t ravel, at $50 per diem per day, and $400 transportation expense per round trip to

attend performance tests.

### 30 Table 7

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

- Year 3

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

EPA

person

hours per

occurrence No. of

occurrences

per plant per

year EPA

person

hours per

plant per

year Plants

per year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ b

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

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

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

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

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

5. Report review

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

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

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

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

Request to use APCD maintenance alternative

standard 2 1 2 24 48 2.4 4.8 $ 2,863

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) 48 2.4 4.8 $ 2,863

Travel Expenses for Tests Attended i $0

TOTAL ANNUAL COST (SALARY +

EXPENSES) $ 2,863

a A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period , of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs . 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.

### 31 b Costs ar e based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

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

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests.

e Assumes 1% of plants will be involved in litigation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of th e 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 trans portation expense per round trip to

attend performance tests.

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

- Years 1 t o 3

Year Technical hours Management hours Clerical Hours Total hours Labor costs

Year 1 138 6.9 1 4 1 59 $ 8,231

Year 2 0 0 0 0 $0

Year 3 138 2.4 4.8 55 $ 2,863

Totals 186 9. 3 19 214 $ 11,095

Average 71 $ 3,698

### 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)

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

1. Applications N /A

2. Survey and Studies N / A

3. Reporting Requirements

A. Read and understand rule requirements d 12 1 12 0 0 0 0 $0

B. Required activities

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

Update OM&M plan 10 1 10 63 630 32 63 $56,796

C onduct APCD maintenance/inspections 30 1 30 24 720 36 72 $43,769

Conduct periodic kiln maintenance/

inspections 160 1 160 15 2,400 120 240 $145,895

Conduct burner inspection and tune

- up 40 1 40 63 2,520 126 252 $153,190

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

Notificat ion of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notific ation of anticipated startup e 3 1 3 0 0 0 0 $0

No tification of actual startup e 3 1 3 0 0 0 0 $0

R equest to use APCD maintenance

alternative standard e 4 1 4 0 0 0 0 $0

Notification of performance test 6 1 6 63 378 18.9 38 $22,979

Notif ication of compliance status e,f 24 1 24 69 1,656 83 166 $100,668

Report of performance test (through

ERT) 20 1 20 63 1,260 63 126 $76,595

First compliance report 30 1 30 69 2,070 104 207 $125,835

Semi

- annual compliance reports

D eviations g 30 2 60 0 0 0 0 $0

### 1

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

No deviations g 12 2 24 0 0 0 0 $0

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

Prepare for initial performance test 24 1 24 63 1,512 76 151 $91,914

Prepare for repeat performance test 24 1 24 6.3 151 7.6 15.1 $9,191

C. Implement activities

Attend initial performance test h 34 2.5 85 63 5,355 268 536 $325,529

Attend repeat performance test h 34 2.5 85 6.3 536 27 54 $32,553

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

E. Time to enter information

Records of compliance data 8 52 416 69 28,704 1,435 2,870 $1,744,909

Records of APCD maintenance/

inspections See 3B

Records of compliance with work

practices See 3B

Records of deviations 2 12 24 69 1,656 83 166 $100,668

F. Time to train personnel i

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 63 3,780 189 378 $340,774

G. Time to transmit / disclose information j 0.25 1 0.25 69 17 0.9 1.7 $1,049

TOTAL ANNUAL BURDEN AND COST

(SALARY) 53,345 2,667 5,334 $3,372,313

TOTAL ANNUAL NUMBER OF

RESPONSES k 2 6 4

CAPITAL COSTS:

Initial performance tests l $2,262,000

Repeat performance tests m $226,200

Total capital cost $2,488,200

### 1

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

ANNUALIZED CAPITAL COSTS: n

Initial performance tests l $551,600

Repeat performance tests m $55,160

Total annualized capital cost $606,760

ANNUAL O&M COSTS o

Photocopy/postage $5,808

Visible emissions tests l $202,912

Total O&M cost $208,720

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $815,480

a Person

- hours per occurrence were derived based on comments from industry.

b A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs. 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.

c Costs are based on the following hourly rat es: technical at $53.17, management at $ 88.56, and clerical at $31.90. Management person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

d Assumes one

- time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among

technical and management staff.

e One

- time only activities.

f The notification of compliance status includes the performance test report and documenta tion of any other ini tial compliance demonstration. The cost burden

associated with developing the performance test report is included in the performance test capital cost at the bottom of the table.

g Assumes 15% of respondents have deviations to report i n semiannual compliance reports, and 85% report no deviations.

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

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

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

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

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

l Based on estimates in BSCP Impacts Memo. Stack testing costs assume EP A Method 29 for PM/metals and EPA Method 26A for HF, HCl, and Cl 2 . VE testing

costs assume EPA Method 22.

m Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it.

n Annualized costs are calculated by multiplying the capital recovery fac tor (CRF) by the capital cost. CRF=(i)*(1+i) t /((1+i) t

- 1) where i = interest rate (%) and t =

equipment life (years)

.

### 1

- 5 o O&M costs for photocopying and posta ge estimated as $22/report. T he 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 a dditional capital or O&M cost. The O&M cost associated with VE

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

- minute VE test, and preparing for/documenting the VE test (occurs after 3

- year

ICR clearance period).

N/A = Not Applicable.

### 1

- 6 Table 1

- 2 . Annual Respondent Burden and Cost of Reporting an d Recordkeeping Requirements of the BSCP NESHAP

- Year 5

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

1. Applications N / A

2. Survey and Studies N / A

3. Reporting Requirements

A. Read and understand rule requirements d 12 1 12 0 0 0 0 $0

B. Required activities

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

Update OM&M plan 10 1 10 63 630 32 63 $56,796

C onduct APCD maintenance/

inspections 30 1 30 0 0 0 0 $0

Conduct periodic kiln maintenance/

inspections 160 1 160 0 0 0 0 $0

Conduct burner inspection and tune

- up 40 1 40 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

Notificat ion of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notific ation of anticipated startup e 3 1 3 0 0 0 0 $0

No tification of actual startup e 3 1 3 0 0 0 0 $0

R equest to use APCD maintenance

alternative standard e 4 1 4 0 0 0 0 $0

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

Notif ication of compliance status e,f 24 1 24 0 0 0 0 $0

Report of performance test (through

ERT) 20 1 20 0 0 0 0 $0

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

Semi

- annual compliance reports

### 1

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

D eviations g 30 2 60 10 621 31 62 $37,750

No deviations g 12 2 24 59 1,408 70 141 $85,568

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

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

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

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

E. Time to enter information

Records of compliance data 8 52 416 69 28,704 1,435 2,870 $1,744,909

Records of APCD maintenance/

inspections See 3B

Records of compliance with work

practices See 3B

Records of deviations 2 12 24 69 1,656 83 166 $100,668

F. Time to train personnel i

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 63 3,780 189 378 $340,774

G. Time to transmit / disclose information j 0.25 1 0.25 69 17 0.9 1.7 $1,049

TOTAL ANNUAL BURDEN AND COST

(SALARY) 36,816 1,841 3,682 $2,367,514

TOTAL ANNUAL NUMBER OF

RESPONSES k 138

CAPITAL COSTS:

Initial performance tests l $0

Repeat performance tests m $0

### 1

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

Total capital cost $0

ANNUALIZED CAPITAL COSTS: n

Initial performance tests l $551,600

Repeat performance tests m $55,160

Total annualized capital cost $606,760

ANNUAL O&M COSTS o

Photocopy/postage $3,036

Visible emissions tests l $202,912

Total O&M cost $205,948

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $812,708

a Person

- hours per occurrence were derived based on comments from industry.

b A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs. Based on the latest BSCP industry profile, no new kilns are anticipa ted to be constructed in the near future, and existing capacity is

assumed sufficient to cover any short

- term increases in production.

c Costs are based on the following hourly rates: technical at $53.17, management at $ 88.56, and clerical at $31.90. Manag ement person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

d Assumes one

- time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requir ements, divided equally among

technical and management staff.

e One

- time only activities.

f The notification of compliance status includes the performance test report and documentation of any other ini tial compliance demonstration. The cost burden

associat ed with developing the performance test report is included in the performance test capital cost at the bottom of the table.

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

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

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

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

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

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

l Based on estimates in BSCP Impacts Memo. Stack testing costs assume EPA Method 29 for PM/metals and EPA Method 26A for HF, HC l, and Cl 2 . VE testing

costs assume EPA Method 22.

m Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it.

n Annualized costs are calculated by multiplying the capital recovery fac tor (CRF) by the capital cost. CRF=(i)*(1+i) t / ((1+i) t

- 1) where i = interest rate (%) and t =

equipment life (years)

.

### 1

- 9 o O&M costs for photocopying and posta ge 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 a dditional capital or O&M cost. The O&M cost associated with VE

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

- minute VE test, and preparing for/documenting the VE test (occurs after 3

- year

ICR clearance period).

N/A = Not Applicable.

### 1

- 10 Table 1

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

- Year 6

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

1. Applications N / A

2. Survey and Studies N / A

3. Reporting Requirements

A. Read and understand rule requirements d 12 1 12 0 0 0 0 $0

B. Required activities

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

Update OM&M plan 10 1 10 63 630 32 63 $56,796

C onduct APCD maintenance/

inspections 30 1 30 0 0 0 0 $0

Conduct periodic kiln maintenance/

inspections 160 1 160 0 0 0 0 $0

Conduct burner inspection and tune

- up 40 1 40 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

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

Notificat ion of constr./reconstr. e 28 1 28 0 0 0 0 $0

Notific ation of anticipated startup e 3 1 3 0 0 0 0 $0

No tification of actual startup e 3 1 3 0 0 0 0 $0

R equest to use APCD maintenance

alternative standard e 4 1 4 0 0 0 0 $0

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

Notif ication of compliance status e,f 24 1 24 0 0 0 0 $0

Report of performance test (through

ERT) 20 1 20 0 0 0 0 $0

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

Semi

- annual compliance reports

### 1

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

D eviations g 30 2 60 10 621 31 62 $37,750

No deviations g 12 2 24 59 1,408 70 141 $85,568

4. Recordkeeping Requirements

A. Read instructions See 3A

B. Plan activities

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

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

C. Implement activities

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

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

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

E. Time to enter information

Records of compliance data 8 52 416 69 28,704 1,435 2,870 $1,744,909

Records of APCD maintenance/

inspections See 3B

Records of compliance with work

practices See 3B

Records of deviations 2 12 24 69 1,656 83 166 $100,668

F. Time to train personnel i

Initial training 48 6 288 0 0 0 0 $0

Annual training 10 6 60 63 3,780 189 378 $340,774

G. Time to transmit / disclose information j 0.25 1 0.25 69 17.3 0.9 1.7 $1,049

TOTAL ANNUAL BURDEN AND COST

(SALARY) 36,816 1,841 3,682 $2,367,514

TOTAL ANNUAL NUMBER OF

RESPONSES k 13 8

CAPITAL COSTS:

Initial performance tests l $0

Repeat performance tests m $0

### 1

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

Person

h our s per

occurrence a No. of

occurrences

per respondent

per year Person

hours per

respondent

per year Respondents

per year b Technical

person

h ours per

year Management

person

- hours

per year Clerical

person

hours per

year Cost,$ c

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

Total capital cost $0

ANNUALIZED CAPITAL COSTS: n

Initial performance tests l $551,600

Repeat performance tests m $55,160

Total annualized capital cost $606,760

ANNUAL O&M COSTS o

Photocopy/postage $3,036

Visible emissions tests l $202,912

Total O&M cost $205,948

TOTAL ANNUALIZED COSTS

(Annualized capital + O&M costs) $812,708

a Person

- hours per occurrence were derived based on comments from industry.

b A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period, of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs. Based on the latest BSCP industry profile, no new kilns are anticipa ted to be constructed in the near future, and existing capacity is

assumed sufficient to cover any short

- term increases in production.

c Costs are based on the following hourly rates: technical at $53.17, management at $ 88.56, and clerical at $31.90. Manag ement person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

d Assumes one

- time burden of 12 hours (based on an average reading rate of 100 words/minute) to read and understand rule requir ements, divided equally among

technical and management staff.

e One

- time only activities.

f The notification of compliance status includes the performance test report and documentation of any other ini tial compliance demonstration. The cost burden

associat ed with developing the performance test report is included in the performance test capital cost at the bottom of the table.

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

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

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

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

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

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

l Based on estimates in BSCP Impacts Memo. Stack testing costs assume EPA Method 29 for PM/metals and EPA Method 26A for HF, HC l, and Cl 2 . VE testing

costs assume EPA Method 22.

m Assumes 10% of plants will fail an initial performance test for one kiln and must repeat it.

n Annualized costs are calculated by multiplying the capital recovery fac tor (CRF) by the capital cost. CRF=(i)*(1+i) t / ((1+i) t

- 1) where i = interest rate (%) and t =

equipment life (years)

.

### 1

- 13 o O&M costs for photocopying and posta ge 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 a dditional 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 th e VE test (occurs after 3

- year

ICR clearance period).

N/A = Not Applicable.

### 1

- 14 Table 1

- 4. Summary of Respondent Burden and Cost of the BSCP NESHAP

- Years 4 t o 6

Year No.

responses Total

hours Labor costs Non

- Labor Costs

Technical

hours Management

hours Clerical

Hours Capital Annualized

capital Annual

O&M Total

annualized cost

Year 4 264 53,345 2,667 5,334 61,347 $3,372,313 $2,488,200 $606,760 $208,720 $815,480

Year 5 138 36,816 1,841 3,682 42,338 $2,367,514 $0 $606,760 $205,948 $812,708

Year 6 138 36,816 1,841 3,682 42,338 $2,367,514 $0 $606,760 $205,948 $812,708

Totals 540 126,977 6,349 12,698 146,023 $8,107,341 $2,488,200 $1,820,280 $620,616 $2,440,896

Average 180 48,674 $2,702,447 $829,400 $606,760 $206,872 $813,632

### 1

- 15 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

person

hours per

occurrence No. of

occurrences

per plant per

year EPA

person

hours per

plant per

year Plants per

year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ b

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

1. Attend initial performance test c 24 1 24 6.3 151 7.6 15 $9,019

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0.6 5 .0 0.3 0.5 $301

Retesting 24 1 24 0.6 15 0.8 1.5 $902

3. Litigation e 2,080 1 2,080 0.6 1,310 66 131 $78,163

4. Excess emissions enforcement activities f 48 1 48 3.2 151 7.6 15 $9,019

5. Report review

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

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

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

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

Request to use APCD maintenance alternative

standard 2 1 2 0 0 0 0 $0

Notification of performance test 2 1 2 63 126 6.3 13 $7,516

Notification of compliance status g 60 1 60 69 4,140 207 414 $246,943

Repeat performance test report d 40 1 40 6.3 252 13 25 $15,031

First compliance report 4 1 4 69 276 14 28 $16,463

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 $383,355

Travel Expenses for Tests Attended i $5,040

TOTAL ANNUAL COST (SALARY +

EXPENSES) $388,395

a A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period , of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs . 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.

### 1

- 16 b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

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

d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests.

e Assumes 1% of plants will be involved in litig ation.

f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of th e retests.

g Notification of compliance status includes the performance test 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 trans portation expense per round trip to

atten d performance tests.

### 1

- 17 Table 1

- 6

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

- Year 5

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

EPA

person

hours per

occurrence No. of

occurrences

per plant per

year EPA

person

hours per

plant per

year Plants per

year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ b

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

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

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

3. Litigation e 2,080 1 2,080 0.6 1,310 66 131 $78,163

4. Excess emissions enforcement activities f 48 1 48 3.2 151 7.6 15 $9,019

5. Report review

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

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

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

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

Request to use APCD maintenance alternative

standard 2 1 2 0 0 0 0 $0

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

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

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 10 166 8.3 17 $9,878

No deviations h 2 2 4 59 235 12 23 $13,993

TOTAL BURDEN AND COST (SALARY) 1,862 93 186 $111,053

Travel Expenses for Tests Attended i $1,575

TOTAL ANNUAL COST (SALARY +

EXPENSES) $112,628

a A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period , of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs . 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

### 1

- 18 b Costs are based on the following hourly rates: technical at $ 52.37, management at $86.56 and clerical at $29.52. Management person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

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

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 th e 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 trans portation expense per round trip to

atten d performance tests.

### 1

- 19 Table 1

- 7

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

- Year 6

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

EPA

person

hours per

occurrence No. of

occurrences

per plant per

year EPA

person

hours per

plant per

year Plants per

year a Technical

person

ho urs per

year Management

person

- hours

per year Clerical

person

hours

per year Cost,$ b

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

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

2. Attend repeat performance test c,d

Retesting preparation 8 1 8 0 0 0 0 $0

Retesting 24 1 24 0 0 0 0 $0

3. Litigation e 2,080 1 2,080 0.6 1,310 66 131 $78,163

4. Excess emissions enforcement activities f 48 1 48 3.2 151 7.6 15 $9,019

5. Report review

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

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

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

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

Request to use APCD maintenance alternative

standard 2 1 2 0 0 0 0 $0

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

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

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 10 166 8.3 17 $9,878

No deviations h 2 2 4 59 235 12 23 $13,993

TOTAL BURDEN AND COST (SALARY) 1,862 93 186 $111,053

Travel Expenses for Tests Attended i $1,575

TOTAL ANNUAL COST (SALARY +

EXPENSES) $112,628

a A total of 69 existing major sources are expected to comply during the 3

- year ICR clearance period , of which 63 are equipped with tunnel kilns, 15 with periodic

kilns, and 24 with APCDs . 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

### 1

- 20 b Costs are based on the following hourly rates: technical at $52.37, management at $86.56 and clerical at $29.52. Management person

- hours and clerical person

hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

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

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 trans portation expense per round trip to

attend performance tests.

### 1

- 21 Table 1

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

- Years 4 t o 6

Year Technical hours Management hours Clerical Hours Total hours Labor costs

Year 4 6,427 321 643 7,391 $388,395

Year 5 1,862 93 186 2,141 $112,628

Year 6 1,862 93 186 2,141 $112,628

Totals 10,151 508 1,015 11,673 $613,651

Average 3,891 $204,550