SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
NO.
2022.02
INFORMATION
COLLECTION
REQUEST
FOR
THE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FOR
THE
BRICK
AND
STRUCTURAL
CLAY
PRODUCTS
SOURCE
CATEGORY
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
JANUARY
2003
2
PART
A
OF
THE
SUPPORTING
STATEMENT
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Reporting
and
Recordkeeping
Requirements
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Brick
and
Structural
Clay
Products
Manufacturing
(
to
be
codified
at
40
CFR
Part
63,
Subpart
JJJJJ)."
This
is
a
new
information
collection
request
(
ICR).
The
U.
S.
Environmental
Protection
Agency
(
EPA)
tracking
number
is
2022.01.

(
b)
Short
Characterization.

Potential
respondents
are
owners
or
operators
of
new
and
existing
brick
and/
or
structural
clay
products
(
BSCP)
manufacturing
facilities.
A
BSCP
facility
manufactures
brick,
including
face
brick,
structural
brick,
brick
pavers,
or
other
brick,
and/
or
structural
clay
products
including
clay
pipe;
roof
tile;
extruded
floor
and
wall
tile;
or
other
extruded,
dimensional
clay
products.

The
BSCP
facilities
typically
form,
dry,
and
fire
bricks
and
shapes
that
are
composed
primarily
of
clay
and
shale.
The
rule
applies
to
existing
large
tunnel
kilns
(
i.
e.,
tunnel
kilns
with
design
capacities
of
10
tons
per
hour
(
tph)
or
more
of
fired
product)
at
these
facilities.
The
rule
also
applies
to
all
new
or
reconstructed
tunnel
kilns.
However,
the
emission
limits
in
the
rule
are
different
for
new
small
and
new
large
tunnel
kilns.
Small
tunnel
kilns
have
design
capacities
of
less
than
10
tons
per
hour
of
fired
product,
while
large
tunnel
kilns
have
design
capacities
greater
than
or
equal
to
10
tons
per
hour
of
fired
product.
Kilns
are
used
to
fire
BSCP.

Consistent
with
the
General
Provisions
for
NESHAP
for
Source
Categories
(
40
CFR
Part
63,
Subpart
A),
respondents
do
not
include
the
owner
or
operator
of
any
facility
that
is
not
a
major
source
of
hazardous
air
pollutant
(
HAP)
emissions
or
any
facility
that
does
not
operate
affected
kilns,
even
if
the
facility
is
a
major
source.
A
major
source
of
HAP
is
a
plant
site
that
emits
or
has
the
potential
to
emit
any
single
HAP
at
a
rate
of
10
tons
or
more
per
year
or
any
combination
of
HAP
at
a
rate
of
25
tons
or
more
per
year.
Approximately
68
BSCP
facilities
with
existing
tunnel
kilns
are
expected
to
meet
the
applicability
criteria
defined
in
the
rule.
An
estimated
15
facilities
are
expected
to
construct
new
kilns
in
the
next
5
years.
We
assume
that
3
new
tunnel
kilns
will
be
constructed
in
each
of
the
first
3
years
after
the
effective
date
of
the
rule
3
and
that
each
of
the
3
new
kilns
will
be
constructed
at
a
facility
that
otherwise
would
not
have
been
subject
to
the
rule
(
e.
g.,
at
a
new
plant
or
a
plant
with
existing
kilns
below
the
size
cutoff).

Respondents
must
submit
one­
time
notifications
of
applicability
and
reports
on
initial
performance
test
results.
Plants
must
develop
and
implement
a
startup,
shutdown,
and
malfunction
plan
(
SSMP)
and
submit
semiannual
reports
of
any
event
where
the
plan
was
not
followed.
Respondents
must
also
develop
and
implement
an
operation,
maintenance,
and
monitoring
(
OM&
M)
plan
covering
each
affected
source
and
each
emission
control
device
used
for
compliance
with
the
rule.
Semiannual
reports
for
periods
of
emission
limitation
deviations
(
or
reports
certifying
that
no
deviations
have
occurred)
also
are
required.
General
requirements
applicable
to
all
NESHAP
require
records
of
applicability
determinations;
performance
test
results;
deviations;
periods
of
startups,
shutdowns,
or
malfunctions;
monitoring
records;
and
all
other
information
needed
to
determine
compliance
with
the
applicable
standard.
Records
and
reports
must
be
retained
for
a
minimum
of
5
years.
The
most
recent
2
years
of
data
must
be
retained
onsite.
The
remaining
3
years
of
data
may
be
retained
offsite.

Subpart
JJJJJ
requires
respondents
to
monitor
control
device
operating
parameters
to
assure
continuous
compliance
with
the
rule.
Parameter
monitoring
requirements
for
dry
lime
adsorbers
(
DLA)
include
periodic
visible
emissions
determinations,
pressure
drop
monitoring,
and
limestone
feed
rate
monitoring.
Facilities
using
a
DLA
must
also
record
the
source
of
limestone
used
in
the
DLA.
Parameter
monitoring
requirements
for
dry
injection
fabric
filter
(
DIFF)
or
dry
lime
scrubber/
fabric
filter
(
DLS)
include
either
periodic
visible
emissions
determinations
or
bag
leak
detectors
and
lime
injection
rate
monitoring.
The
rule
also
includes
monitoring
requirements
for
wet
scrubbers,
including
monitoring
of
pressure
drop,
liquid
pH,
liquid
flow
rate,
and
chemical
addition
rate
(
if
applicable).
While
any
of
these
technologies
could
be
used
to
comply
with
the
emission
standards,
it
is
anticipated
that
most
facilities
will
use
a
DLA
system
for
existing
large
tunnel
kilns
and
new
small
tunnel
kilns
or
a
DIFF
system
for
new
large
tunnel
kilns.
Respondents
also
must
maintain
records
of
specific
information
needed
to
determine
that
the
standards
are
being
achieved
and
maintained.
These
requirements
are
described
in
Attachment
1.

2.
Need
For
and
Use
of
the
Collection
4
(
a)
Need/
Authority
for
the
Collection.

The
EPA
is
required
under
section
112(
d)
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
emission
standards
for
each
category
or
subcategory
of
major
and
area
sources
of
HAP
listed
for
regulation
in
section
112(
b).
These
standards
are
applicable
to
new
or
existing
sources
of
HAP
and
shall
require
the
maximum
degree
of
emission
reduction.

The
predominant
HAP
emitted
from
BSCP
manufacturing
facilities
include
hydrogen
fluoride
(
HF),
hydrogen
chloride
(
HCl),
and
metals
(
antimony,
arsenic,
beryllium,
cadmium,

chromium,
cobalt,
mercury,
manganese,
nickel,
lead,
and
selenium).
In
the
Administrator's
judgement,
the
pollutants
emitted
from
BSCP
manufacturing
facilities
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.

Consequently,
NESHAP
for
this
source
category
has
been
developed
and
are
being
promulgated.

(
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).)

Section
114
of
the
CAA
allows
the
Administrator
to
require
inspections,
monitoring,
and
entry
into
facilities
to
ensure
compliance
with
a
section
112
emission
standard.
Section
114(
a)(
1)

specifically
states:

"
The
Administrator
may
require
any
person
who
owns
or
operates
any
emission
source
...

who
is
subject
to
the
provisions
of
the
CAA
on
a
one­
time,
periodic,
or
continuous
basis
to;

(
A)
establish
and
maintain
such
records;

(
B)
make
such
reports;

(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;

(
D)
sample
such
emissions;

(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;

(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3);
and
5
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require."

Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
sources
subject
to
the
standards
and
to
ensure
that
the
standards
are
being
achieved.

(
b)
Practical
Utility/
Users
of
the
Data.

The
information
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
EPA
to
identify
facilities
that
may
not
be
in
compliance
with
the
standards.
Based
on
the
reported
information,
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
EPA
whether
the
owners
or
operators
are
in
compliance
with
the
emission
limitations.
Much
of
the
information
EPA
would
need
to
determine
compliance
would
be
recorded
and
retained
onsite
at
the
facility.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection
and
would
not
need
to
be
routinely
reported
to
EPA.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.

The
information
required
by
the
BSCP
manufacturing
NESHAP
is
not
duplicated
by
existing
EPA
regulations
and
is
not
expected
to
be
required
by
any
other
EPA
rulemaking
currently
in
progress.
However,
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
the
Office
of
Management
and
Budget
(
OMB).

This
section
is
not
applicable
because
this
is
a
rule­
related
ICR.
A
public
review
and
comment
period
occurred
following
proposal
of
the
BSCP
manufacturing
NESHAP
in
the
Federal
Register.
6
(
c)
Consultations.

Representatives
of
the
industry
trade
associations
and
their
member
companies
were
consulted
during
the
development
of
the
rule,
and
several
meetings
have
been
held
with
them
during
this
time.
The
industry
trade
associations
include
the
Brick
Industry
Association
(
BIA)

and
the
National
Clay
Pipe
Institute.
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,
and
MACT
floor
approach.
No
specific
information
was
provided
to
the
representatives
with
respect
to
burden
estimates
prior
to
proposal
of
the
rule.

Others
consulted
for
information
during
the
development
process
for
the
proposed
standards
included
the
Institute
of
Clean
Air
Companies
and
several
individual
States,
including
Texas,

Pennsylvania,
North
Carolina,
South
Carolina,
and
Ohio.

The
EPA
provided
a
60­
day
public
comment
period
following
proposal
of
the
BSCP
manufacturing
NESHAP,
during
which
all
affected
parties
were
given
the
opportunity
to
comment
on
the
proposed
rule.
Comments
were
received
from
BSCP
industry
representatives,

brick
kiln
manufacturers,
air
pollution
control
device
vendors,
environmental
interest
groups,
and
State
and
local
agencies.
The
EPA
considered
the
comments
received
and,
as
appropriate,

incorporated
them
into
the
final
rule.
Specific
comments
on
the
burden
associated
with
these
information
collection
requirements
were
received
from
the
BIA
and
companies
in
the
BSCP
industry.
This
ICR
has
been
revised
to
incorporate
the
comments
received.

(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
was
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
the
facilities
are
applying
good
operation
and
maintenance
practices
and
meeting
the
emission
limitations
in
the
rule.
In
addition,
our
authority
to
take
administrative
action
would
be
significantly
reduced.
Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
violations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
administrative
proceedings
are
less
costly
and
require
use
of
fewer
resources
than
judicial
proceedings,
both
we
and
the
regulated
community
benefit
from
preservation
of
our
administrative
powers.
Also,
the
reporting
frequency
in
the
rule
is
consistent
with
the
7
requirements
of
Title
V
permit
programs.
Consequently,
less
frequent
reports
would
not
result
in
a
reduced
burden.

(
e)
General
Guidelines.

The
BSCP
manufacturing
NESHAP
requires
that
facilities
retain
records
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
specified
in
the
general
information
collection
guidelines
in
5
CFR
1320.6(
f)
of
OMB
regulations
implementing
the
Paperwork
Reduction
Act.

However,
the
5­
year
retention
period
is
consistent
with
the
retention
requirement
in
the
General
Provisions
in
subpart
A
of
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
under
40
CFR
part
70.
All
facilities
subject
to
this
rule
will
be
required
to
obtain
operating
permits
either
through
the
State­
approved
permitting
program
or,
if
one
does
not
exist,

in
accordance
with
the
provisions
of
40
CFR
part
71.
Thus,
the
5­
year
record
retention
requirement
of
the
rule
adds
no
additional
burden.
At
a
minimum,
respondents
will
be
required
to
retain
onsite
the
most
recent
2
years
of
data.
The
remaining
3
years
of
data
could
be
retained
at
a
readily
accessible
onsite
or
offsite
storage
facility.
None
of
the
other
guidelines
in
5
CFR
1320.6
are
being
exceeded.

(
f)
Confidentiality.

All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­­

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

amended
by
43
FR
39999,
September
28,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979.)

(
g)
Sensitive
Questions.

This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents
Standard
Industrial
Classification
(
SIC)
and
North
American
Industrial
Classification
System
(
NAICS)
Codes.

Respondents
are
owners
or
operators
of
BSCP
manufacturing
facilities
that
are
major
sources
of
HAP
emissions
and
use
existing
tunnel
kilns
with
design
capacities
of
10
tph
or
more
8
of
fired
product
or
new
tunnel
kilns
of
any
capacity.
Table
1
lists
the
SIC
and
NAICS
codes
used
to
classify
the
respondents
affected
by
the
BSCP
manufacturing
NESHAP.

TABLE
1.
SIC
AND
NAICS
CODES
USED
TO
CLASSIFY
RESPONDENTS
SIC
NAICS
Examples
of
potentially
regulated
entities
3251
327121
Brick
and
structural
clay
tile
manufacturing
facilities
3253
327122
Extruded
tile
manufacturing
facilities
3259
327123
Other
structural
clay
products
manufacturing
facilities
(
b)
Information
Requested.

(
i)
Data
items,
Including
Recordkeeping
Requirements.
Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
recordkeeping
and
reporting
requirements
including
the
required
retention
time
for
all
records.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
standards
in
the
first
3
years
following
the
effective
date
are
identified
in
Attachment
2,
Tables
1
through
3
and
are
introduced
in
Section
6(
a).

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
Agency
activities
in
the
first
3
years
following
the
effective
date
of
the
rule
is
provided
in
Attachment
2,
Tables
5
through
7
and
are
introduced
in
Section
6(
c).

(
b)
Collection
Methodology
and
Management.

Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
our
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Information
contained
in
the
periodic
reports
submitted
to
us
will
be
reviewed
for
accuracy
and
completeness.
Data
obtained
during
periodic
visits
by
our
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.

(
c)
Small
Entity
Flexibility.
9
Approximately
92
of
the
estimated
189
plants
that
make
up
the
BSCP
industry
are
owned
by
small
businesses
based
on
the
definition
used
by
the
Small
Business
Administration
(
500
or
750
or
fewer
company
employees
depending
on
the
companies
SIC/
NAICS
codes).
Information
available
to
the
EPA
indicates
that
15
of
these
plants
are
subject
to
the
NESHAP
because
they
are
major
sources
of
HAP
and
operate
kilns
with
capacities
of
10
tph
or
more.
The
EPA
gathered
input
from
small
entity­
owned
facilities
during
the
data
gathering
phase
of
the
proposed
rulemaking,
presented
the
regulatory
approach
to
the
trade
association
who
represents
most
small
businesses,
and
contacted
small
entity­
owned
facilities
projected
to
incur
compliance
costs
to
explain
the
regulatory
approach.
The
EPA
does
not
expect
that
any
affected
facilities,
including
small
businesses,
will
experience
adverse
impacts
due
to
the
cost
of
the
reporting
and
recordkeeping
requirements
of
the
rule.

The
rule
will
allow
the
affected
facilities
up
to
3
years
from
the
effective
date
of
the
rule
to
comply.
Under
section
112(
i),
the
Administrator
or
the
applicable
regulatory
authority
also
may
grant
one
additional
year
if
the
owner
or
operator
demonstrates
that
more
time
is
needed
to
install
controls
for
a
source.
This
additional
time
would
ease
capital
availability
problems
for
plants
in
marginal
economic
condition
that
need
to
purchase
and
install
new
or
upgraded
emission
controls.

(
d)
Collection
Schedule.

Collection
of
data
will
begin
after
the
effective
date
of
the
final
BSCP
manufacturing
NESHAP.
The
compliance
date
for
existing
sources
is
3
years
after
the
effective
date.
The
compliance
date
for
new
or
reconstructed
sources
is
the
effective
date
if
the
source
startup
date
is
before
the
effective
date,
or
upon
startup
if
the
startup
date
is
on
or
after
the
effective
date.
The
schedule
for
notifications
and
reports
required
by
the
rule
is
summarized
below.

For
facilities
with
existing
affected
kilns,
the
initial
notification
stating
that
the
facility
is
subject
to
the
rule
must
be
submitted
no
later
than
120
days
after
the
effective
date
of
the
rule.

Facilities
with
new
or
reconstructed
affected
kilns
for
which
startup
occurs
on
or
after
the
effective
date
must
submit
the
initial
notification
no
later
than
120
days
after
the
source
becomes
subject
to
the
rule.
Facilities
may
choose
to
submit
a
request
for
a
routine
control
device
maintenance
exemption
30
days
prior
to
the
compliance
date.
Facilities
required
to
conduct
a
performance
test
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
10
days
before
the
performance
test
is
scheduled
to
begin.
For
each
initial
compliance
demonstration
that
includes
a
performance
test,
facilities
must
submit
an
initial
notification
of
compliance
status
no
later
than
60
days
following
the
completion
of
the
performance
test.
Records
necessary
to
determine
compliance
must
be
compiled
on
a
daily
basis,
and
compliance
reports
must
be
submitted
to
the
Administrator
on
a
semi­
annual
basis.
Repeat
performance
tests
are
to
be
conducted
every
5
years
to
ensure
ongoing
compliance.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
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
Attachment
2,
Tables
1
through
3.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts.
In
addition,
comments
and
information
received
from
the
BIA
and
other
BSCP
companies
was
incorporated
into
the
burden
estimates.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
sources
subject
to
the
standards
are
presented
in
Tables
1
through
3
in
Attachment
2.
The
total
cost
for
each
respondent
activity
includes
labor
costs,
capital/
start­
up
costs,
and
operating
and
maintenance
(
O&
M)
costs.
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)
(
http://
www.
bls.
gov/
ncs/
ect/
home.
htm).

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
June
2002
(
the
most
recent
rates
available)
are
$
30.89
per
hour
($
30.89/
hr)
for
technical
personnel,
$
49.66/
hr
for
managerial
personnel,
and
$
21.14/
hr
for
clerical
personnel.
The
base
labor
rates
were
adjusted
by
an
overhead
rate
of
167
percent.
The
final
total
labor
rates
are
$
51.59
for
technical
personnel,

$
82.93
for
management,
and
$
35.30
for
clerical.
Capital/
startup
costs
include
the
costs
of
conducting
performance
tests,
attending
a
visible
emissions
training
course,
and
purchasing
file
cabinets
for
storing
records.
Operation
and
maintenance
costs
include
photocopy
and
postage
costs
associated
with
reporting
requirements.
The
monitoring
equipment
needed
to
monitor
11
parameters
other
than
visible
emissions
(
e.
g.,
limestone
or
lime
feed
rate)
is
included
as
part
of
the
control
system
and
therefore
adds
no
additional
capital
or
O&
M
cost.
There
is
no
O&
M
cost
associated
with
visible
emissions
monitoring
other
than
the
training
costs.
The
capital/
startup
costs
were
estimated
and
annualized
as
described
in
the
footnotes
to
Tables
1
through
3
in
Attachment
2.

(
c)
Estimating
Agency
Burden
and
Cost.

No
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements
because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
the
AFS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program.
Therefore,
this
examination
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Tables
5
through
7
Attachment
2.
Labor
rates
for
Federal
employees
are
based
on
the
January
2002,
Office
of
Personnel
Management
labor
rates
for
General
Schedule
employees
(
http://
www.
opm.
gov/
oca/
02tables/
02gsh.
pdf).
The
base
labor
rates
are
$
27.13/
hr
for
technical
personnel
(
GS­
12,
step
5),
$
44.85
for
management
personnel
(
GS­
15,
step
5),
and
$
15.29/
hr
for
clerical
personnel
(
GS­
7,
step
5).
The
base
labor
rates
were
multiplied
by
the
standard
government
benefits
multiplication
factor
of
1.6.
The
resulting
average
hourly
labor
costs
are
$
43.41
for
technical
personnel,
$
71.76
for
management,
and
$
24.46
for
clerical.
12
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs.

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

the
total
burden
and
cost
must
be
calculated
for
all
respondents
and
for
the
Agency.
To
calculate
the
total
burden
and
costs,
the
number
of
respondents
needed
to
complete
each
information
collection
activity
must
be
estimated.
The
total
number
of
respondents
is
also
referred
to
as
the
"
respondent
universe."

The
EPA
has
identified
189
facilities
that
are
involved
in
BSCP
production
processes.

Based
on
analyses
of
information
collected
from
industry
surveys
and
operating
permits,
EPA
estimates
that
169
of
the
facilities
may
be
major
sources.
However,
only
those
existing
facilities
that
operate
tunnel
kilns
with
capacities
of
10
tph
or
more
are
required
to
comply
with
the
monitoring,
recordkeeping,
and
reporting
requirements
of
the
rule.
There
are
68
existing
major
source
facilities
with
affected
tunnel
kilns.
In
addition,
major
source
facilities
with
new
tunnel
kilns
of
any
capacity
are
required
to
comply
with
the
monitoring,
recordkeeping,
and
reporting
requirements
of
the
rule.
It
is
projected
that
three
new
tunnel
kilns
will
be
constructed
each
year
to
accommodate
trends
in
increasing
production
of
BSCP.
For
purposes
of
developing
conservative
estimates
of
respondent
burden
and
costs,
it
is
assumed
that
the
new
kilns
would
be
constructed
at
facilities
that
otherwise
would
not
have
been
subject
to
the
rule
(
e.
g.,
at
a
new
plant
or
a
plant
with
existing
kilns
below
the
size
cutoff).
Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
to
Tables
1
through
3
in
Attachment
2.

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

(
i)
Respondent
tally.
The
bottom
line
annual
respondent
burden
hours
and
costs,

presented
in
Tables
1
through
3
of
Attachment
2
(
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
of
Attachment
2
summarizes
the
burden
hours
and
costs
for
each
of
the
three
years
and
presents
the
total
and
average
burden
over
the
three­
year
period.
The
total
number
of
responses
over
the
3­
year
period
is
221,
with
an
average
of
74
responses
per
year.
The
estimated
total
burden
for
the
3­
year
period
is
52,412
labor
hours
at
a
labor
cost
of
$
2,700,984.
The
average
bottom
line
annual
burden
over
the
3­
year
period
is
13
17,471
labor
hours
at
a
labor
cost
of
$
900,328.
The
estimated
total
capital/
startup
costs
that
would
be
incurred
are
$
489,445,
with
an
average
of
$
163,148
incurred
during
each
of
the
3
years
following
promulgation.
The
total
annualized
capital/
startup
costs
are
$
115,111,
with
an
average
of
$
38,370
incurred
during
each
of
the
3
years
following
promulgation.
The
total
annual
O&
M
cost
is
estimated
to
be
$
4,853,
with
an
average
of
$
1,618
incurred
each
year
in
the
3
years
following
promulgation.
The
total
annualized
cost
(
including
the
annualized
capital/
startup
and
O&
M
costs)
is
$
119,964.
The
total
annualized
cost
averaged
over
the
3­
year
period
is
$
39,988.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Tables
5
through
7
of
Attachment
2,
are
calculated
as
in
the
respondent
table,
by
adding
personhours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,
total
cost
is
the
sum
of
this
total
salary
cost
and
total
travel
expenses
for
tests
attended.
The
total
hours
during
the
3­
year
ICR
review
period
are
1,680,
with
an
average
of
560
hours
per
year.
The
total
cost
over
the
3­
year
period
is
$
73,184.
The
average
annual
cost
incurred
during
each
year
is
$
24,395.

(
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
promulgation,
(
2)
different
one­
time
activities
would
be
conducted
during
the
first
years
following
promulgation,
and
(
3)
new
facilities
would
continue
to
start
up
each
year.
Because
existing
facilities
are
not
required
to
come
into
full
compliance
with
the
BSCP
standards
until
3
years
after
promulgation,
much
of
the
respondent
burden
does
not
occur
until
the
fourth
year
following
promulgation.
Attachment
3
contains
tables
showing
respondent
and
Agency
burden
estimates
for
the
fourth,
fifth,
and
sixth
years
following
promulgation.
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
installing
monitoring
systems,
developing
their
SSM
and
OM&
M
plans,
and
training
personnel
on
how
to
record
information.
Facilities
may
also
choose
to
submit
a
request
for
a
routine
control
device
maintenance
exemption
during
the
third
year.
During
the
fourth
year
when
existing
facilities
are
required
to
come
into
full
compliance,
the
facilities
would
submit
a
14
notification
of
intent
to
conduct
a
performance
test,
conduct
an
initial
performance
test,
submit
a
notification
of
compliance
status,
and
submit
their
first
compliance
report.
During
subsequent
years
existing
facilities
would
keep
records
and
submit
semi­
annual
reports.
After
the
fourth
year,
burden
estimates
are
not
expected
to
vary
considerably
from
year
to
year
because
facilities
will
be
conducting
ongoing
activities
(
e.
g.,
semi­
annual
compliance
reports,
recordkeeping,

retesting
every
5
years)
as
opposed
to
the
one­
time
activities
(
e.
g.,
developing
SSM
plan,

notifications)
that
occur
in
the
first
four
years
following
promulgation.

(
f)
Reasons
for
Change
in
Burden.

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

(
g)
Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
236
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2002­
0054,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,

1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
and
Information
Center
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
15
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.

Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.

Please
include
the
EPA
Docket
ID
No.
OAR­
2002­
0054
in
any
correspondence.

PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirements
Regulation
Reference
Respondent
burden
tables
cross
reference*
Agency
burden
tables
cross
reference*

Notifications
Initial
notifications
(
including
construction/
reconstruction)
63.5,
63.9(
b),
and
63.8480(
a)­(
c)
4.
E
5
Notification
of
performance
test
63.7(
b)­(
c),
63.9(
e),
and
63.8480(
d)
4.
E
5
Notification
of
compliance
status
(
including
performance
test
results,
operating
parameter
values,

capture/
collection
system
design
information,
bag
leak
detection
system
documentation,
OM&
M
plan,

and
SSMP)
63.9(
h),
63.10(
d)(
2),
and
63.8480(
e)
4.
B,
4.
E,
5.
B,
5.
C,
5.
E,
and
"
annual
capital
costs"

summary
5
Request
for
routine
control
device
maintenance
exemption
63.8480(
f)
4.
E
5
Records
Record
retention
63.10(
b)(
1)
and
63.8495
Not
applicable
Not
applicable
Documentation
supporting
initial
notifications
and
notifications
of
compliance
status
63.10(
b)(
2)(
xiv)
and
63.8490(
a)(
1)
5.
E
Not
applicable
SSMP
and
OM&
M
plan
63.6(
e)(
3)
and
63.8490(
c)(
6)
5.
E
Not
applicable
Records
related
to
startup,
shutdown,
and
malfunction
63.6(
e)(
3)(
iii)­(
iv)
and
63.8490(
a)(
2)
5.
E
Not
applicable
Records
of
performance
tests
63.10(
b)(
2)(
viii)
and
63.8490(
a)(
3)
5.
E
Not
applicable
Records
for
each
continuous
monitoring
system
(
CMS),
production
records,
and
bag
leak
detection
system
records
63.8(
d)(
3),
63.8(
f)(
6)(
i),
63.8(
g),

63.10(
b)(
2)(
vi)­(
xi),
and
63.8490(
b)­

(
c)
5.
E
Not
applicable
Requirements
Regulation
Reference
Respondent
burden
tables
cross
reference*
Agency
burden
tables
cross
reference*

Reports
First
compliance
report
Semi­
annual
compliance
report:

­
No
deviations/
no
out­
of­
control
CMS
­
Deviations/
out­
of­
control
CMS
Startup,
shutdown,
and
malfunction
reports
63.10(
e)(
3)
and
63.8485(
b)­(
f)

63.10(
e)(
3)
and
63.8485(
b)­(
f)

63.8485(
c)(
6)­(
7)

63.8485(
d)­(
e)

63.10(
d)(
5)
and
63.8485(
c)(
4)
4.
E
5
*
Rows
in
the
respondent
burden
tables
(
Tables
1
through
3
in
Attachment
2)
and
in
the
Agency
burden
tables
(
Tables
5
through
7
in
Attachment
2)
that
correspond
to
the
requirement.
ATTACHMENT
2
Table
1.
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
of
the
Standard
­
Year
1
Table
2.
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
of
the
Standard
­
Year
2
Table
3.
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
of
the
Standard
­
Year
3
Table
4.
Summary
of
Respondent
Burden
and
Cost
­
Years
1
to
3
Table
5.
Annual
Federal
Government
Burden
and
Cost
of
the
Standard
­
Year
1
Table
6.
Annual
Federal
Government
Burden
and
Cost
of
the
Standard
­
Year
2
Table
7.
Annual
Federal
Government
Burden
and
Cost
of
the
Standard
­
Year
3
Table
8.
Summary
of
Federal
Government
Burden
and
Cost
for
the
Standards
­
Years
1
to
3
ATTACHMENT
3
Table
9.
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
of
the
Standard
­
Year
4
Table
10.
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
of
the
Standard
­
Year
5
Table
11.
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
of
the
Standard
­
Year
6
Table
12.
Summary
of
Respondent
Burden
and
Cost
­
Years
4
to
6
Table
13.
Annual
Federal
Government
Burden
and
Cost
of
the
Standard
­
Year
4
Table
14.
Annual
Federal
Government
Burden
and
Cost
of
the
Standard
­
Year
5
Table
15.
Annual
Federal
Government
Burden
and
Cost
of
the
Standard
­
Year
6
Table
16.
Summary
of
Federal
Government
Burden
and
Cost
for
the
Standards
­
Years
4
to
6
