SUPPORTING STATEMENT

                                      ENVIRONMENTAL PROTECTION AGENCY

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

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart
SSSSS) (Renewal), EPA ICR Number 2040.04, OMB Control Number 2060-0515

	1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP),
for Refractory Products Manufacturing were proposed on June 20, 2002 (67
FR 42107), and promulgated on April 16, 2003 (68 FR 18729).  These
regulations apply to each existing refractory products manufacturing
which produces refractory bricks, refractory shapes, kiln furniture,
crucibles, and other materials used as linings for boilers, kilns, and
other processing units and equipment where extremes of temperature,
corrosions, and abrasion would destroy other materials.  The rule
applies to facilities that manufacture refractory products and use
organic hazardous air pollutant (HAP), chromium refractory, and clay
refractory products.  The new or reconstructed affected sources are
shape dryers, curing ovens, and kilns that are used to manufacture
refractory products that use organic HAP; shape preheaters, pitch
working tanks, defumers, and coking ovens used to produce
pitch-impregnated refractory products; kilns that are used to
manufacture chromium refractory products; and kilns that are used to
manufacture clay refractory products.  This ICR is for Hazardous Air
Pollutant (HAP) emission major sources in the refractory products
manufacturing source category.

	In general, all NESHAP standards require initial notifications,
compliance status report, and performance tests by the owners/operators
of the affected facilities.  They are also required to maintain records
of the occurrence and duration of any startup, shutdown, or malfunction
(SSM) in the operation of an affected facility, or any period during
which the monitoring system is inoperative.  These notifications,
reports, and records are essential in determining compliance, and are
required of all affected facilities subject to NESHAP.  Semiannual
summary reports are also required.

	Any owner/operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) regional office.

	Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

	An average of eight respondents will be subject to the regulation over
the period covered 

by this ICR, and it is estimated that no additional respondents will
become subject to the regulation in the next three years.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost – NESHAP for Refractory Products
Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal), attached below.
 The burden to the “Federal Government” is attributed entirely to
work performed by federal employees or government contractors; this
burden may be found in Table 2: Average Annual EPA Burden - NESHAP for
Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS)
(Renewal), attached below.

2.  Need for and Use of the Collection

	2(a)  Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and shall require the maximum degree of emission reduction. 
In addition, section 114(a) states that the Administrator may require
any owner/operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports;   (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3);    and (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, particulate matter emissions from
facilities in refractory products manufacturing cause or contribute to
air pollution that may reasonably be anticipated to endanger public
health or welfare.  Therefore, the NESHAP were promulgated for the
source category at 40 CFR part 63, subpart SSSSS.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The 

collected information is also used for targeting inspections and as
evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	The notifications required in the standard are used to inform either
the Agency or its delegated authority when a source becomes subject to
the requirements of the regulations.         The reviewing authority may
then inspect the source to check if the pollution control devices are
properly installed and operated, that leaks are being detected and
repaired, and that the standards are being met.  The performance test
may also be observed.

	The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Non-duplication, Consultations, and Other Collection Criteria

	The requested recordkeeping and reporting are required under 40 CFR
part 63, subpart SSSSS.

	3(a)  Non-duplication

	If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

	3(c)  Consultations

	Consultation with an industry representative (i.e., respondent) was
previously conducted to determine if there is anyway for EPA to reduce
the recordkeeping and reporting burden or improve the language in the
standard to make it easier to comply; additionally, the most recent ICR
was referenced, the preparer of the active ICR consulted, and other
references were used to obtain the most recent data available. 

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.  In this case, no comments were received.

3(d)  Effects of Less Frequent Collection

	Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and that emission limitations are met.  If the information
required by these standards was collected less frequently, the
likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.

	3(e)  General Guidelines

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

	These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the Part 70 permit program and the five-year statute of limitations
on which the permit program is based.  Also, the retention of records
for five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  If records were retained for less than five
years, EPA would be prevented from pursuing the worst violators due to
the destruction or nonexistence of records.

	3(f)  Confidentiality

	Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, part 2, subpart B -
Confidentiality of Business Information  (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 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/SIC Codes

The respondents to the recordkeeping and reporting requirements are
refractory products manufacturing.  The United States Standard
Industrial Classification (SIC) codes for the

respondents affected by the standards, which corresponds to the North
American Industry Classification System (NAICS) codes, are listed below
for source category descriptions.

Standard (40 CFR Part 63, Subpart JJJJ)	SIC Codes	NAICS Codes

Clay refractory manufacturing	3255	327124

Nonclay refractory manufacturing	3297	327125



	4(b)  Information Requested

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

		(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NESHAP for Refractory Products Manufacturing (40 CFR part 63, subpart
SSSSS).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Initial notification	63.9(b)(2) and (3), 63.5, 63.9812(b)-(c)

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

Notification of compliance status	63.9(h), 63.10(d)(2), and 63.9812(e)

Notification of alternative fuel use	63.9812(f)

Startup, shutdown, malfunction	63.10(d)(5), 63.9814(c)(4)

No deviations/no continuous monitoring system (CMS) out of control
63.9814(c)(5)-(6)

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

Report of alternative fuel use	63.9841(g)



	A source must make the following reports:

Recordkeeping 

Record of startup, shutdown, and malfunctions	63.6(e)(3), 63.10(b)(2),
63.9816(a)(2)

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

Initial notification or notification of compliance status
63.10(b)(2)(xiv), 63.9816(a)(1)

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

Records are required to be retained for five years	63.10(b)(1)



Electronic Reporting

	At the present, respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

	Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

		(ii)  Respondent Activities	

Respondent Activities

Read instructions.

Perform initial performance test, Reference Methods 25A test, and repeat
performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.



	Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources still need
to evaluate the data, this type of monitoring equipment has
significantly reduced the burden associated with monitoring and
recordkeeping.

5.  The Information Collected: Agency Activities, Collection
Methodology, and Information Management

	5(a)  Agency Activities

	EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

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

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS).



	5(b)  Collection Methodology and Management

	Following notification of startup, the reviewing authority might
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 capability to comply with
the emission standard.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.

	Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA regional offices
and EPA headquarters.  Both the EPA and its delegated Authorities can
edit, store, retrieve and analyze this data.

	The records required by this regulation must be retained by the
owner/operator for five years.

	5(c)  Small Entity Flexibility

A majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  The number of small entities affected by this rule could
not be determined, based on review of the following sources: the
promulgated rule notice in the Federal Register; the Economic Impact
Analysis of the Refractory Product Manufacturing NESHAP: Final Report
(2001); and a search of publicly available current data sources.  The
Economic Impact Analysis document states: “The Agency conducted a
screening analysis to assess the impacts of the proposed rule on small
businesses and to compare the impacts on small businesses with the
impacts on large businesses.”  Of 80 total companies analyzed, 58
(72.5%) were considered small businesses.

Due to technical considerations involving the process operations and the
types of control equipment employed, the recordkeeping and reporting
requirements are the same for both small and large entities.  The Agency
considers these requirements the minimum needed to ensure compliance
and, therefore, cannot reduce them further for small entities.  To the
extent that larger businesses can use economies of scale to reduce their
burden, the overall burden will be reduced.

	5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Refractory Products Manufacturing (40 CFR part 63, subpart SSSSS)
(Renewal), attached below.

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and the

reporting requirements applicable to the industry for the subpart
included in this ICR.  The individual burdens are expressed under
standardized headings believed to be consistent with the concept of
burden under the Paperwork Reduction Act.  Where appropriate, specific
tasks and major assumptions have been identified.  Responses to this
information collection are mandatory.  The Agency may not conduct or
sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB Control Number.

	6(a)  Estimating Respondent Burden

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 338
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
regulation, Agency knowledge and experience with the NESHAP program, the
previously approved ICR, and any comments received.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs 

 

	This ICR uses the following labor rates: 

		Managerial	$97.46   ($46.41 + 110%)

		Technical	$83.71   ($39.86 + 110%)

		Clerical	$42.55   ($20.26 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “Table 2: Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

		

                        (ii)  Estimating Capital/Startup and Operation
and Maintenance Costs

	The type of industry costs associated with the information collection
activities in the subject standard are labor costs which are addressed
elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs (O&M) are the ongoing costs to maintain the monitor
and other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents 	(D)

Total Capital/Startup Cost,

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

Continuous parameter monitoring system	$16,820	0	$0	$380	8	$3,040



The total capital/startup costs for this ICR are zero.  This is the
total of column D in the above table.

 

The total operation and maintenance (O&M) costs for this ICR are $3,040.
 This is the total of column G.

The total respondent costs in block 14 have been calculated as the
addition of the capital/startup costs, and the annual operation and
maintenance costs.  The average annual cost for capital/startup and
operation and maintenance costs to industry over the next three years of
the ICR is estimated to be $3,000 (rounded).

	6(c)  Estimating Agency Burden and Cost

	The only costs to the Agency are those costs associated with analysis
of the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $7,273.  This cost is based on the average hourly labor
rate as follows:

		Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

		Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

		Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005
General Schedule”, which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden, NESHAP for Refractory Products Manufacturing (40 CFR part 63,
subpart SSSSS) (Renewal), attached below.

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

	Based on our research for this ICR, on average over the next three
years, approximately eight existing respondents will be subject to the
standard.  It is estimated that no additional respondent per year will
become subject.  The overall average number of respondents, as shown in
the table below is eight per year.

	The number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of New Respondents	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	(E)

Number of Respondents(E=A+B+C-D)

1	0	8	0	0	8

2	0	8	0	0	8

3	0	8	0	0	8

Average	0	8	0	0	8



	To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is eight.

 

	The total number of annual responses per year is calculated using the
following table: 

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses

E=(BxC)+D

Notification of applicability	0	1	0	0

Notification of construction/reconstruction	0	1	0	0

Notification of anticipated startup	0	1	0	0

Notification of actual startup	0	1	0	0

Notification of performance test	0	1	0	0

Notification of compliance status	0	1	0	0

Notification of intent to use alternative fuel	3	1	0	3

Report of deviations	1	1	0	1

Report of no deviations	7	2	0	14

Startup, shutdown, malfunction report	1	1	0	1

Report of alternative fuel use	3	1	0	3



	Total	22



	The number of Total Annual Responses is 22.

	6(e)  Bottom Line Burden Hours Burden and Cost Tables

	The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

		(i) Respondent Tally

The total annual labor costs are $27,304.  Details regarding these
estimates may be found in Table 1: Annual Respondent Burden and Cost,
NESHAP for Refractory Products Manufacturing (40 CFR part 63, subpart
SSSSS) (Renewal), attached below.  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 15 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $3,040.  The cost calculations are detailed in Section 6(b) (iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

		(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is
estimated to be 179 labor hours at a cost of $7,273.  See Table 2:
Annual Agency Burden and Cost, NESHAP for Refractory Products
Manufacturing (40 CFR part 63, subpart SSSSS) (Renewal), attached below.

	

	6(f)  Reasons for Change in Burden

There is no change in the estimation methodology for labor hours or cost
to the respondents in this ICR compared to the previous ICR.  This is
due to two considerations.  First, the regulations have not changed over
the past three years and are not anticipated to change over the next
three years.  Secondly, the growth rate for respondents is very low,
negative, or non-existent.  

The previous approved ICR renewal indicated 470 annual labor hours;
after review of the burden tables, we have determined that the number of
indicated hours was an error.  A decimal was misplaced in Table 1:
Subtotals Labor burden and cost (“147” in Column F should have been
“14.7”).  The slight decrease in burden is due to a correction in
the labor hours from 470 to 338 per year.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 15 hours per response.
 Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to: review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2008-0292.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1927.  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
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2008-0292 and OMB Control Number 2060-0515 in any
correspondence.

Part B of the Supporting Statement

	This part is not applicable because no statistical methods were used in
collecting this information.



Table 1:  Annual Respondent Burden and Cost – NESHAP for Refractory
Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal) 

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $  b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting Requirements









   A.  Read instructions 	0.5	1	4	0	0	0	00	$0

   B.  Required activities









        Startup, shutdown, malfunction plan	32	1	32	0	0	0	0	$0

        Operation, maintenance, monitoring         plan 	32	1	32	0	0	0	0
$0

   C.  Create information	See 3B







	   D.  Gather existing information	See 3B







	   E.   Write report









        Notification of applicability	2	1	2	0	0	0	0	$0

        Notification of construction/                     reconstruction
2	1	2	0	0	0	0	$0

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

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

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

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

        Notification of intent to use                       alternative
fuel c	2	1	2	3	6	0.3	0.6	$557.03

        Report of deviations d	16	1	16	1	16	0.8	1.6	$1,485.41

        Report of no deviations e	8	2	16	7	112	5.6	11.2	$10,397.86

        Startup, shutdown, malfunction                 report f	8	1	8	1
8	0.4	0.8	$742.70

        Report of alternative fuel use g	4	1	4	3 	12	0.6	1.2	$1,114.06

SUBTOTAL Reporting



	177.1	$14,297

4.  Recordkeeping Requirements









    A.  Read instructions h	4	1	4	8	32	1.6	3.2	$2,970.82

    B.  Plan activities	See 4E







	    C.  Implement activities 	See 4E







	    D.  Develop record system	See 4E





	 

    E.  Time to enter information









        Records of all information required          by standards i	0.25
52	13	8	104	5.2	10.4	$9,665.15

    F.  Time to train personnel	20	1	20	0	0	0	0	$0

    G. Time to adjust existing ways to                 comply with
previously applicable            requirements	N/A







	    H. Time to transmit or disclose                      information j
0.25	2	0.5	8	4	0.2	0.4	$371.35

     I. Time for audits 	N/A







	SUBTOTAL Recordkeeping



	161	$13,007.32

Subtotals Labor Burden and cost  



	294	14.7	29.4	$27,304.38

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	338	$27,304



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be eight.  There will be no additional new
source per year that will become subject to the rule over the three-year
period of this ICR. 

b  This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2: Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110% to
account for the benefit packages available to those employed by private
industry.

c  We have assumed that three respondent will use alternative fuel once
per year and will have to submit notification of intent to use
alternative fuel.

d  We have assumed that one respondent will report deviation once a
year.

e  We have assumed that seven respondents will report no deviation on a
semiannual basis.

f  It is assumed that one respondents will have a startup, shutdown,
malfunction occur.

g  We have assumed that three respondents will report on alternative
fuel usage once a year.

h  We have assumed that it will take 4 hours for each respondent to read
instructions.

i  We have assumed that  information will be recorded once per week for
52 weeks per year.

j  We have assumed that it will take 0.25 hours for information to be
transmitted or disclosed.



Table 2:  Average Annual EPA Burden - NESHAP for Refractory Products
Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

 per year	

(C)

EPA person

hours per

plant  per year

(C=AxB)	

(D)

Plants per 

year  a	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $ b

Attend initial performance test	40	1	40	0	0	0	0	  $0

Attend repeat performance test









    Retesting preparation	8	1	8	0	0	0	0	$0

    Retesting	40	1	40	0	0	0	0	$0

Report Review









    Notification of applicability	2	1	2	0	0	0	0	$0

   Notification of construction/

    reconstruction	2	1	2	0	0	0	0	$0

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

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

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

    Notification of compliance status     	2	1	2	0	0	0	0	$0

    Notification of intent to use alternative     fuel c	2	1	2	3	6	0.3
0.6	$279.73

    Repeat performance test report 	40	1	40	0	0	0	0	$0

    Semiannual compliance reports









         Deviation d	16	1	16	1	16	0.8	1.6	$745.94

         No Deviation e	8	2	16	7	112	5.6	11.2	$5,221.55

    Startup, shutdown, malfunction report f	16	1	16	1	16	0.8	1.6	$745.94

    Notification of alternative fuel use g	2	1	2	3	6	0.3	0.6	$279.73

Subtotals Labor Burden and cost



	156	7.8	15.6	$7,272.89

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	

179	

$7,273



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be eight.  There will be no additional new
source per year that will become subject to the rule over the three-year
period of this ICR.

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2005 General Schedule” which
excludes locality rates of pay.

  c  We have assumed that three respondent will use alternative fuel
once per year and will have to submit notification of intent to use
alternative fuel.

  d  We have assumed that one respondent will report deviation once a
year.

  e  We have assumed that seven respondents will report no deviation on
a semiannual basis.

  f  It is assumed that one respondents will have a startup, shutdown,
malfunction occur.

  g  We have assumed that three respondents will report on alternative
fuel usage once a year.

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