OMB­
83I
FORM
SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
NO.
2040.02
INFORMATION
COLLECTION
REQUEST
FOR
THE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
(
NESHAP)
FOR
THE
REFRACTORY
PRODUCTS
MANUFACTURING
SOURCE
CATEGORY
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
DECEMBER
2002
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
Refractory
Products
Manufacturing
NESHAP
(
40
CFR
63,
subpart
SSSSS)."
This
is
a
new
information
collection
request
(
ICR).

The
EPA
tracking
number
is
2040.2.

(
b)
Short
Characterization.

Potential
respondents
are
owners
or
operators
of
existing
facilities
that
manufacture
refractory
products.
A
refractory
products
manufacturing
facility
produces
refractory
bricks,

refractory
shapes,
kiln
furniture,
crucibles,
and
other
materials
used
as
linings
for
boilers,
kilns,

and
other
processing
units
and
equipment
where
extremes
of
temperature,
corrosion,
and
abrasion
would
destroy
other
materials.
The
rule
applies
to
facilities
that
manufacture
refractory
products
that
use
organic
hazardous
air
pollutants
(
HAP),
chromium
refractory
products,
and
clay
refractory
products.
The
affected
sources
include
new
and
existing
shape
dryers,
curing
ovens,

and
kilns
that
process
refractory
products
that
contain
organic
HAP;
new
and
existing
pitchimpregnated
refractory
products
shape
preheaters,
pitch
working
tanks,
defumers,
and
coking
ovens;
new
and
existing
chromium
refractory
products
kilns;
and
new
and
existing
clay
refractory
products
kilns.

Consistent
with
the
General
Provisions
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
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
HAP
emissions
or
any
facility
that
does
not
operate
affected
sources,
even
if
the
facility
is
a
major
source.

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;
develop
and
implement
an
operation,
maintenance,
and
monitoring
plan;
and
submit
semiannual
reports
of
any
event
where
the
plans
were
not
followed.
Semiannual
reports
for
periods
of
operation
during
which
the
monitoring
parameter
ranges
established
during
the
initial
compliance
test
are
exceeded
(
or
reports
certifying
that
no
exceedances
have
occurred)
also
are
required.
Some
plants
are
subject
to
limitations
on
the
type
of
fuel
that
can
be
used
to
fire
kilns.
If
those
plants
must
use
an
alternative
fuel,
they
must
submit
a
notification
of
intent
to
use
2
alternative
fuel
and
a
report
on
alternative
fuel
use.
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
total
of
5
years
(
2
years
at
the
site;
the
remaining
3
years
of
records
may
be
retained
off­
site).
The
files
may
be
maintained
in
electronic
form
such
as
microfilm,
computer
disks,
or
magnetic
tape.

The
Refractory
Products
Manufacturing
NESHAP
requires
respondents
to
monitor
the
operating
temperatures
of
control
devices
that
are
used
to
reduce
emissions
from
certain
types
of
sources.
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
(
a)
Need/
Authority
for
the
Collection.

The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
NESHAP
for
new
or
existing
major
sources
or
area
sources
that
reflect:

...
the
maximum
degree
of
reduction
in
emissions
of
[
HAPs]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
emission
reduction,
any
nonair
quality
health
and
environmental
reduction,
and
energy
requirements.
[
section
112(
d)(
2)]

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).
Certain
records
and
reports
are
necessary
for
the
Administrator
to
confirm
the
compliance
status
of
major
sources
and
identify
new
or
reconstructed
sources
subject
to
the
standards.
Specific
information
needed
by
EPA
for
the
Refractory
Products
Manufacturing
NESHAP
includes
whether
any
required
air
emission
controls
are
properly
installed,
operated,
and
maintained.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.
7414)
and
set
out
in
the
NESHAP
General
Provisions.

(
b)
Practical
Utility/
Users
of
the
Data.

The
information
will
be
used
by
Agency
enforcement
personnel
to:
(
1)
identify
major
sources
and
new,
modified,
or
reconstructed
sources
subject
to
the
standards;
(
2)
ensure
that
3
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.
Based
on
the
reported
information,
EPA
can
decide
which
plants,
records,
or
processes
should
be
inspected.
The
records
that
plants
maintain
will
indicate
to
EPA
whether
plant
personnel
are
operating
and
maintaining
control
equipment
properly.

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

A
search
of
existing
standards
and
outgoing
ICR's
revealed
no
duplication
of
information­
gathering
efforts.
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.
The
EPA
has
issued
guidance
to
State
and
local
agencies
encouraging
them
to
consolidate
duplicative
requirements
into
a
single
element
to
be
reported.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
This
section
is
not
applicable
because
this
is
a
rule­
related
ICR.

(
c)
Consultations.

Participants
in
the
development
process
for
this
final
NESHAP
included
The
Refractories
Institute,
the
Refractory
Ceramic
Fiber
Coalition,
the
National
Electrical
Manufacturers
Association,
and
representatives
from
numerous
refractory
products
manufacturing
companies.

These
participants
were
contacted
for
information
and
were
invited
to
meetings.
In
addition,

several
States
including
California,
Connecticut,
Illinois,
Indiana,
Kentucky,
Missouri,
New
York,

Ohio,
Pennsylvania,
Texas,
and
Utah,
were
contacted
for
information.
A
60­
day
public
comment
period
was
provided
after
proposal,
during
which
the
public
was
given
the
opportunity
to
comment
on
the
proposed
NESHAP.
All
comments
received
during
and
after
the
public
comment
period
were
considered,
and
some
were
incorporated
in
the
development
of
the
final
NESHAP.

(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
were
collected
less
frequently,
EPA
could
not
be
reasonably
assured
that
a
plant
is
in
compliance
with
the
standards.
In
addition,
our
authority
to
take
administrative
action
would
be
significantly
reduced.
Section
113(
d)
of
the
CAA
limits
the
4
assessment
of
administrative
penalties
to
violations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
administrative
proceedings
are
less
costly
and
require
use
of
fewer
resources
than
judicial
proceedings,
both
we
and
the
regulated
community
benefit
from
preservation
of
our
administrative
powers.
Also,
the
reporting
frequency
in
the
rule
is
consistent
with
the
requirements
of
Title
V
permit
programs.
Consequently,
less
frequent
reports
would
not
result
in
a
reduced
burden.

(
e)
General
Guidelines.

The
Refractory
Products
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
the
Office
of
Management
and
Budget
(
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
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,

Subpart
B
­­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,

1976;
amended
by
43
FR
39999,
September
28,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).
5
(
g)
Sensitive
Questions.

The
information
to
be
reported
consists
of
emissions
data
and
other
information
that
are
not
of
a
sensitive
nature.
Therefore,
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/
SIC
Codes.

Respondents
are
owners
or
operators
of
refractory
products
manufacturing
facilities
that
are
major
sources
of
HAP
emissions.
Eight
facilities
with
affected
sources
are
estimated
to
be
required
to
comply
with
the
monitoring,
recordkeeping,
and
reporting
requirements
in
the
final
rule.
No
new
refractory
products
manufacturing
facilities
are
expected
to
be
constructed
during
the
3­
year
ICR
clearance
period.
The
respondents
are
classified
under
the
Standard
Industrial
Classification
(
SIC)
codes
and
North
American
Industrial
Classification
System
(
NAICS)
codes
summarized
in
Table
1.
Only
certain
processes
classified
in
the
SIC
or
NAICS
codes
listed
above
will
be
regulated
by
the
Refractory
Products
Manufacturing
NESHAP.

(
b)
Information
Requested.

(
i)
Data
items,
Including
Recordkeeping
Requirements.
Attachment
1,
Summary
of
Reporting
and
Recordkeeping
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
are
identified
in
Table
2
and
introduced
in
Section
6(
a).
To
the
extent
practicable,
the
activities
required
by
respondents
were
designed
to
make
use
of
or
to
be
consistent
with
existing
reporting
and
recordkeeping
practices.

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

A
list
of
Agency
activities
is
provided
in
Table
3
and
introduced
in
Section
6(
c).

(
b)
Collection
Methodology
and
Management.

Information
contained
in
the
one­
time
only
and
in
the
periodic
reports
submitted
to
us
will
be
reviewed
for
accuracy
and
completeness.
Data
obtained
during
periodic
visits
by
our
6
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.

(
c)
Small
Entity
Flexibility.

Approximately
71
of
the
estimated
147
plants
that
make
up
the
refractory
products
manufacturing
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
three
of
these
plants
are
subject
to
the
NESHAP
because
they
are
major
sources
of
HAP.
The
EPA
does
not
expect
that
any
affected
facilities,
including
the
three
small
businesses,
will
experience
adverse
impacts
due
to
the
cost
of
the
reporting
and
recordkeeping
requirements
of
the
final
rule.

The
NESHAP
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
Refractory
Products
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.
No
new
or
reconstructed
sources
are
anticipated
during
the
3­
year
ICR
clearance
period.
The
schedule
for
notifications
and
reports
required
by
the
rule
is
summarized
below.

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

Facilities
with
new
or
reconstructed
affected
sources
for
which
startup
occurs
on
or
after
the
effective
date
must
submit
the
initial
notification
no
later
than
120
days
after
the
source
becomes
subject
to
the
rule.
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
7
begin.
For
each
initial
compliance
demonstration
that
does
not
include
a
performance
test,

facilities
must
submit
an
initial
notification
of
compliance
status
no
later
than
30
days
following
the
completion
of
the
initial
compliance
demonstration.
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.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.

The
annual
burden
estimates
for
reporting
and
recordkeeping
are
presented
in
Table
2.

These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
sources
subject
to
the
standards
are
presented
in
Table
2.
Because
much
of
the
data
are
already
collected
by
respondents
or
required
by
existing
law,
minimal
respondent
development
costs
are
associated
with
the
information
collection
activities
for
the
standards.
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://
stats.
bls.
gov/
news.
release).
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
March
2000
(
the
most
recent
rates
available)
are
$
28.59
per
hour
($
28.59/
hr)
for
technical
personnel,
$
43.46/
hr
for
managerial
personnel,
and
$
18.07/
hr
for
clerical
personnel.
The
base
labor
rates
were
adjusted
by
an
overhead
and
profit
rate
of
167
percent.
The
final
total
labor
rates
are
$
48
for
technical
personnel,
$
73
for
management,
and
$
30
for
clerical.

In
addition
to
labor
costs,
capital/
startup
costs
include
the
costs
of
conducting
performance
tests,

installing
the
necessary
monitoring
equipment,
and
purchasing
file
cabinets
for
storing
records.

Operation
and
maintenance
(
O&
M)
costs
include
the
costs
for
monitoring
equipment
and
photocopy
and
postage
costs
associated
with
reporting
requirements.
The
capital/
startup
costs
were
estimated
and
annualized
as
described
in
the
footnotes
to
Table
2.
8
(
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.
The
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
the
General
Provisions
for
the
MACT
standards.
Because
the
respondent
burden
has
already
been
applied
under
the
General
Provisions,
no
additional
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
the
Compliance
Data
System,
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,
and,
therefore,
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
Table
3.
Labor
rates
for
Federal
employees
are
based
on
the
January
2001,
Office
of
Personnel
Management
labor
rates
for
General
Schedule
employees
(
http://
www3.
opm.
gov/
oca/
01tables/
gshrly/
html/
01gshr.
htm).
The
base
labor
rates
are
$
26.19/
hr
for
technical
personnel
(
GS­
12,
step
5),
$
43.29
for
management
personnel
(
GS­
15,
step
5),
and
$
14.76/
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
$
42
for
technical
personnel,
$
69
for
management,
and
$
24
for
clerical.

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

The
EPA
has
identified
147
facilities
that
currently
manufacture
refractory
products.

Based
on
analyses
of
information
collected
from
industry
surveys
and
operating
permits,
the
Agency
estimates
that
eight
of
the
facilities
may
be
major
sources.
These
existing
facilities
are
required
to
comply
with
the
monitoring,
recordkeeping,
and
reporting
requirements
of
the
rule,

and
six
of
the
eight
facilities
will
be
required
to
conduct
performance
tests.
In
addition,
three
facilities
are
subject
to
limitations
on
the
type
of
fuel
that
can
be
used
in
certain
kilns.
If
any
of
those
facilities
need
to
use
an
alternative
kiln
fuel
due
to
the
interruption
of
natural
gas
supply,

separate
notification
and
reporting
will
be
required.
No
new
refractory
products
manufacturing
facilities
are
anticipated
to
be
constructed
during
the
3­
year
ICR
clearance
period.
Details
on
the
9
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
2.

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

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
Table
2,
are
calculated
by
adding
person­
hours
per
year
down
each
column
for
technical,

managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
The
total
annual
number
of
responses
is
24.
The
estimated
total
annual
hours
are
726
at
an
annual
labor
cost
of
$
31,459.

The
estimated
total
capital/
startup
costs
that
would
be
incurred
during
each
of
the
3
years
following
promulgation
are
$
197,033.
The
annualized
capital/
startup
costs
are
$
45,393.
The
total
annual
O&
M
cost
is
estimated
to
be
$
1,043.
The
total
annualized
cost
requested
(
including
the
annualized
capital/
startup
and
O&
M
costs)
is
$
46,436.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Table
3,
are
calculated
as
in
the
respondent
table,
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,
total
cost
is
the
sum
of
this
total
salary
cost
and
total
travel
expenses
for
tests
attended.
The
total
annual
hours
are
326.
The
total
annual
cost
is
$
15,084.

(
iii)
Variations
in
the
annual
bottom
line.
This
section
does
not
apply
since
no
significant
variation
is
anticipated.

(
f)
Reasons
for
Change
in
Burden.

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

(
g)
Burden
Statement
The
average
annual
respondent
burden
for
the
eight
existing
affected
refractory
products
manufacturing
is
estimated
at
726
hours.
This
estimate
includes
time
for
preparing
and
submitting
notices,
gathering
information
(
e.
g.,
conducting
emission
performance
tests),
submitting
reports,

and
maintaining
records.

Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
30.25
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
10
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
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,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2002­
0088,
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
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
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
0088).
11
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
12
TABLE
1.
SIC
AND
NAICS
CODES
SIC
NAICS
Examples
of
respondents
3255
327124
Clay
refractories
manufacturing
facilities
3297
327125
Nonclay
refractories
manufacturing
facilities
13
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
FINAL
RULE
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
a)
(
E)
Technical
person­
hours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,$
(
b)

1.
Applications
NA
2.
Survey
and
Studies
NA
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
54
1
54.0
2.0
108.0
5.4
10.8
$
5,902
4.
Reporting
Requirements
A.
Read
instructions
0.5
1
0.5
2.7
1.3
0.1
0.1
$
73
B.
Required
activities
Startup,
shutdown,
malfunction
plan
32
1
32.0
2.7
85.3
4.3
8.5
$
3,153
Operation,
maintenance,
monitoring
plan
32
1
32.0
2.7
85.3
4.3
8.5
$
3,153
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Notification
of
applicability
2
1
2.0
2.7
5.3
0.3
0.5
$
291
Notification
of
construction/
reconstruction
2
1
2.0
0
0
0.0
0.0
Notification
of
anticipated
startup
2
1
2.0
0
0
0.0
0.0
Notification
of
actual
startup
2
1
2.0
0
0
0.0
0.0
Notification
of
performance
test
2
1
2.0
2.0
4.0
0.2
0.4
$
219
Notification
of
compliance
status
16
1
16.0
2.7
42.7
2.1
4.3
$
2,332
Notification
of
intent
to
use
alternative
fuel
(
c)
2
1
2.0
3.0
6.0
0.3
0.6
$
33,28
$
328
Semi­
annual
compliance
reports:

°
Deviations
(
d)
16
1
16.0
1.0
16.0
0.8
1.6
$
874
°
No
deviations
(
e)
8
2
16.0
4.5
72.0
3.6
7.2
$
3,935
°
Startup,
shutdown,
malfunction
report
(
f)
8
1
8.0
1.0
8.0
0.4
0.8
$
437
Report
of
alternative
fuel
use
(
c)
4
1
4.0
3.0
12.0
0.6
1.2
$
656
5.
Recordkeeping
Requirements
A.
Read
instructions
4
1
4
2.7
10.7
0.5
1.1
$
583
B.
Plan
activities
See
5E
C.
Implement
activities
See
5E
D.
Develop
record
system
See
5E
E.
Time
to
enter
information
Records
of
all
info.
required
by
standards
(
g,
h)
1.5
52
78.0
1.7
132.6
6.6
13.3
$
7,247
F.
Time
to
train
personnel
20
1
20.0
2.0
40.0
2.0
4.0
$
2,186
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
NA
H.
Time
to
transmit
or
disclose
information
(
i)
0.25
3.3
0.8
2.0
1.7
0.1
0.2
$
90
I.
Time
for
audits
NA
Total
Annual
Burden
and
Cost
(
Salary)
631
31.5
63.1
$
31,459
14
TABLE
2.
(
CONTINUED)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
a)
(
E)
Technical
person­
hours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,$
(
b)

Total
Annual
Number
of
Responses
(
j)
18
Annual
Capital
Costs:

Performance
tests
(
k)
$
178,273
Monitoring
equipment
(
l)
$
18,133
File
cabinets
(
m)
$
627
Total
annual
capital
$
197,033
Annualized
Capital
Costs:
(
n)

Performance
tests
(
5
year
life,
7%
interest
­>

CRF=
0.24)
$
42,786
Monitoring
equipment
(
10
year
life,
7%
interest
­

>
CRF=
0.14)
$
2,539
File
cabinets
(
15
year
life,
7%
interest
­>

CRF=
0.11)
$
69
Total
annualized
capital
$
45,393
Total
Annual
Costs
(
O
&
M)
(
o)
$
1,043
Total
Annualized
Costs
(
Ann
capital
+
O&
M
costs)
$
46,436
(
a)
Total
of
eight
major
source
plants
with
37
affected
sources
total
are
expected
to
comply
during
the
3­
year
ICR
clearance
period
for
an
average
of
8/
3=
2.7
plants
per
year.
All
plants
must
perform
reporting
and
recordkeeping
annually,
for
an
average
of
8/
3=
2.7
plants
and
37/
3=
12.3
affected
sources
per
year.
Two
plants
will
not
be
required
to
submit
notifications
of
performance
tests.
No
facilities
and
no
new
affected
sources
are
expected
to
be
reconstructed
or
constructed
during
the
ICR
clearance
period.

(
b)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
48,
management
at
$
73,
and
clerical
at
$
30.
Management
person­
hours
and
clerical
person­
hours
are
assumed
to
be
5
percent
and
10
percent
of
technical
person­
hours,
respectively.

(
c)
Assumes
three
plants
will
use
alternative
fuel
once
per
year
and
will
have
to
submit
notification
of
intent
to
use
alternative
fuel
and
report
of
alternative
fuel
use.

(
d)
Assumes
one
respondent
reports
deviations
once
a
year.

(
e)
Assumes
four
respondents
report
no
deviations
semiannually,
and
one
respondent
reports
no
deviations
during
1
semi­
annual
period.

(
f)
Assumes
one
respondent
per
year
will
have
a
startup,
shutdown,
or
malfunction
occur
that
is
not
managed
according
to
the
plan.

(
g)
Assumes
1.5
hours
per
affected
source.

(
h)
Assumes
information
is
entered
1
time
per
week
for
52
weeks/
yr.

(
i)
Assumes
typical
plant
transmits
one­
time
notifications
of
applicability,
initial
performance
test,
and
compliance
status
(
including
performance
test
report);
the
Startup,
Shutdown,
and
Malfunction
Plan;
and
6
semi­
annual
reports
of
excess
emissions
(
or
no
excess
emissions)
over
the
3­
year
period,
for
a
total
of
10
items
or
an
average
of
3.3
items
per
year.

(
j)
The
total
annual
number
of
responses
is
calculated
by
summing
the
product
of
columns
B
and
D
for
each
of
the
reports
listed
in
4E.

(
k)
Assumes
emission
test
to
be
conducted
on
an
average
of
11.3
affected
sources
per
year
using
Method
25A
for
an
average
cost
of
$
14,300
per
test,
and
10%
of
affected
sources
will
fail
initial
test
and
must
repeat
the
performance
test.

(
l)
The
costs
for
monitoring
equipment
is
estimated
at
$
1,600
per
affected
source.

(
m)
Assumes
one
standard
four­
drawer
file
cabinet
per
facility
at
a
cost
of
$
235
per
cabinet.

(
n)
Annualized
costs
are
calculated
by
multiplying
the
capital
recovery
factor
(
CRF)
by
the
capital
cost.
CRF=(
i)*(
1+
i)^
t/((
1+
i)^
t­
1)
where
i
=
interest
rate
(%)
and
t
=
equipment
life
(
years)

(
o)
O&
M
costs
include
the
following:
(
1)
O&
M
for
monitors
estimated
as
20%
of
the
annual
cost
for
monitors,
and
(
2)
photocopy
and
postage
costs
estimated
as
$
22/
report.

N/
A
=
Not
Applicable.
15
TABLE
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
OF
THE
FINAL
RULE
Activity
(
A)

EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)

EPA
personhours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
(
a)
(
E)
Technical
person­
hours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,$
(
b)

Attend
initial
performance
test
(
c)
40
1
40.0
1.0
40.0
2.0
4.0
$
1,914
Attend
repeat
performance
test
(
c,
d)
­
­
­
­

Retesting
preparation
8
1
8.0
1.0
8.0
0.4
0.8
$
383
Retesting
40
1
40.0
1.0
40.0
2.0
4.0
$
1,914
Litigation
(
e)
2,080
0
­
­
­
­
­

Excess
Emissions
Enforcement
Activities
(
f)
48
1
48.0
0.07
19.2
1.0
1.9
$
919
Report
Review
­
­
­
­

Notification
of
applicability
2
1
2.0
2.7
5.3
0.3
0.5
$
255
Notification
of
construction/
reconstruction
2
1
2.0
­
­
­
­

Notification
of
anticipated
startup
2
1
2.0
­
­
­
­

Notification
of
actual
startup
2
1
2.0
­
­
­
­

Notification
of
initial
performance
test
2
1
2.0
2.0
4.0
0.2
0.4
$
191
Notification
of
compliance
status
(
g)
4
1
4.0
2.7
10.7
0.5
1.1
$
510
Notification
of
intent
to
use
alternative
fuel
(
h)
2
1
2.0
3.0
6.0
0.3
0.6
$
287
Repeat
performance
test
report
(
d)
40
1
40.0
1.0
40.0
2.0
4.0
$
1,914
Semi­
annual
compliance
reports:

Deviations
(
i)
16
1
16.0
1.0
16.0
0.8
1.6
$
766
No
deviations
(
j)
8
2
16.0
4.5
72.0
3.6
7.2
$
3,445
Startup,
shutdown,
malfunction
report
(
k)
16
1
16.0
1.0
16.0
0.8
1.6
$
766
Notification
of
alternative
fuel
use
(
h)
2
1
2.0
3.0
6.0
0.3
0.6
$
287
Total
Burden
and
Cost
(
Salary)
283.2
14.2
28.3
$
13,551
Travel
Expenses
for
Tests
Attended
(
l)
$
1,533
Total
Annual
Cost
(
Salary
+
Expenses)
$
15,084
(
a)
Total
of
eight
major
source
plants
with
37
affected
sources
total
are
expected
to
comply
during
the
3­
year
ICR
clearance
period
for
an
average
of
8/
3=
2.7
plants
per
year.
All
plants
must
perform
reporting
and
recordkeeping
annually,
for
an
average
of
8/
3=
2.7
plants
and
37/
3=
12.3
affected
sources
per
year.
Two
plants
will
not
be
required
to
submit
notifications
of
performance
tests.
No
facilities
and
no
new
affected
sources
are
expected
to
be
reconstructed
or
constructed
during
the
ICR
clearance
period.

(
b)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
42,
management
at
$
69,
and
clerical
at
$
24.
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
for
one
affected
source
per
year.

(
d)
Assumes
one
plant
will
fail
an
initial
performance
test
for
one
affected
source
and
must
repeat
it.

(
e)
Assumes
no
plants
will
be
involved
in
litigation.

(
f)
Assumes
one
plant
over
3
years
is
required
to
retest
as
a
result
of
excess
emissions.

(
g)
Notification
of
compliance
status
includes
performance
test
report.

(
h)
Assumes
three
plants
will
use
alternative
fuel
once
per
year
and
will
have
to
submit
notification
of
intent
to
use
alternative
fuel
and
report
of
alternative
fuel
use.

(
i)
Assume
one
plant
reports
a
deviation
once
a
year.

(
j)
Assumes
four
plants
will
file
no
deviation
reports,
and
one
plant
will
file
a
no
deviation
report
for
one
semi­
annual
period
per
year.

(
k)
Assumes
one
respondent
will
have
a
startup,
shutdown,
or
malfunction
occur
in
a
year
that
is
not
managed
according
to
the
plan.

(
l)
Assumes
Agency
personnel
(
1
person)
will
spend
2
days
per
plant,
at
$
50
per
diem
per
day,
and
$
400
transportation
expense
per
round
trip
to
attend
performance
tests.
16
N/
A
=
Not
applicable.
ATTACHMENT
1
SUMMARY
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
Summary
of
Recordkeeping
and
Reporting
Requirements
Requirements
Regulation
Reference
Notifications
Initial
notifications
(
including
construction/
reconstruction)
63.5,
63.9(
b),
and
63.9812(
b)­(
c)

Notification
of
performance
test
63.7(
b)­(
c),
63.9(
e),
and
63.9812(
d)

Notification
of
compliance
status
63.9(
h),
63.12(
d)(
2),
and
63.9812(
e)

Notification
of
alternative
fuel
use
63.9812(
f)

Records
Record
retention
63.10(
b)(
1)
and
63.9818(
a)­(
c)

Documentation
supporting
initial
notifications
and
notifications
of
compliance
status
63.10(
b)(
2)(
xiv)
and
63.9816(
a)(
1)

Records
related
to
startup,
shutdown,
and
malfunction
63.6(
e)(
3)
and
63.9816(
a)(
2)

Records
of
performance
tests
63.10(
b)(
2)(
viii)
and
63.9816(
a)(
3)

Records
for
each
CMS
63.8(
d)(
3),
63.8(
f)(
6)(
i),
63.8(
g),
63.10(
b)(
2)(
vi)­(
xi),
and
63.9816(
c)

Reports
Semi­
annual
compliance
report:
°
Startup,
shutdown,
and
malfunction
reports
°
No
deviations/
no
out­
of­
control
CMS
°
Deviations/
out­
of­
control
CMS
63.10(
e)(
3)
and
63.9814(
b)­(
c)
63.10(
d)(
5)
and
63.9814(
c)(
4)
63.9814(
c)(
5)­(
6)
63.9814(
d)­(
f)

Report
of
alternative
fuel
use
63.9814(
g)
