SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Brick and Structural Clay Manufacturing (40 CFR Part 63,
Subpart JJJJJ) (Renewal) 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Brick and Structural Clay Manufacturing (40 CFR part 63,
subpart JJJJJ) (Renewal), EPA ICR Number 2022.04, OMB Control Number
2060-0508

1(b)  Short Characterization/Abstract

	The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for brick and structural clay manufacturing were proposed on July 22,
2002, (67 FR 47894), and promulgated on May 16, 2003, (68 FR 26690).  A
brick and clay structural manufacturing facility manufactures brick
including, but not limited to: facers; clay pipe; roof tile; extruded
floors and wall tile; and/or other extruded, dimensional clay products. 
Brick and structural clay products (BSCP) manufacturing facilities
typically process raw clay and shale, form the processed materials into
bricks or shapes, and dry and fire the bricks or shapes.  The rule
applies to existing large kilns, i.e., tunnel kilns with design
capacities of 10 tons per hour (tph) or more of fired product at these
facilities.  Each new or reconstructed tunnel kiln is an affected source
regardless of design capacity.  This information is being collected to
assure compliance with 40 CFR part 63, subpart JJJJJ.

In general, all NESHAP standards require initial notifications,
performance tests, notification of compliance status, and periodic
reports 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 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.  A semiannual report of compliance is 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 1.5 affected facilities 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 72 respondents will be subject to the regulation over the
period covered by this ICR, and it is estimated that one additional
respondent per year will also become subject to the standard.

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 Brick and
Structural Clay Manufacturing (40 CFR Part 63, Subpart JJJJJ) (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 Brick and Structural Clay Manufacturing (40 CFR
Part 63, Subpart JJJJJ) (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, hazardous air pollutants (HAP)
emissions from BSCP manufacturing facilities cause or contribute to air
pollution that may reasonably be anticipated to endanger public health
or welfare.  Therefore, the NESHAP were promulgated for this source
category at 40 CFR part 63, subpart JJJJJ.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where 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 the
Agency or 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 JJJJJ.

	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

	In previous renewals, consultation with an industry representative from
the Brick Industry Association (BIA) was conducted; additionally, the
most recent ICR was referenced, the preparer of the active ICR
consulted, and other resources 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.  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
brick and structural clay 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 JJJJJ)	SIC Codes	NAICS Codes

Brick and Structural Clay Tile Manufacturing	3251	327121

Ceramic Wall and Floor Tile Manufacturing	3253	327122

Other Structural Clay Product Manufacturing	3259	327123



	4(b)  Information Requested

	These reporting or recordkeeping requirements do not violate any of the
regulations that OMB established under 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 Brick and Structural Clay Manufacturing (40 CFR part 63,
subpart JJJJJ).

	A source must make the following reports:

Notifications	Standard Citation by Sections 

Initial notification (including construction/reconstruction)	63.5(b),
63.9(b), 63.8480(a)-(c)

Notification of performance test	63.7(b)-(c), 63.9(e), 63.8480(d)

Notification of compliance status	63.9(h), 63.10(d)(2), 63.8480(e)

Request for routine control device maintenance exemption	63.8480(f)

Request for extension of compliance date	63.9(c), 63.4283

First compliance report	63.10(e)(3), 63.8485(b)-(f)

Semiannual reports of no deviations	63.10(e)(3), 63.8485 (c)(6)-(7)

Semiannual report of deviations	63.10(e)(3), 63.8485(d)(e)

Startup, shutdown, malfunction (SSM) report	63.10(d)(5), 63.8485(c)(4)



	A source must make the following reports:

Recordkeeping 

Records supporting initial and compliance status notifications 
63.10(b)(2)(xiv), 63.8490(a)(1)

Records of performance tests	63.10(b)(2)(viii), 63.8490(a)(3)

Record of startup, shutdown, and malfunctions	63.6(e)(3)(iii)-(iv),
63.8490(a)(2)

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), 63.8490(b)-(c)

Records of SSM and operation, maintenance, and monitoring (OM&M) plans
63.6(e)(3), 63.8490(c)(6)

Records are required to be retained for five years	63.10(b)(1), 63.8495



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.

Install, calibrate, maintain, and operate CMS for opacity.

Perform initial performance test, Reference Method 5, and 26A tests, and
repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded.

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 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 Air Facility System (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.  The semiannual reports are used for problem identification,
as a check on source operation and maintenance, and for compliance
determinations.

	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.  EPA and its delegated Authorities can edit,
store, retrieve and analyze the data.

The records required by this regulation must be retained by the
owner/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: promulgated
rule notice in the Federal Register; Economic Impact Analysis of the
Brick and Structural Clay Products Manufacturing NESHAP: Final Rule
(2003); and a search of publicly available current data sources.  The
Economic Impact Analysis document states: “Based on the SBA
definitions, the Agency identified 76 of the companies owning facilities
that produce [brick and structural clay products] as small (84 percent)
and 14 as large (15 percent)…”

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 Respondent Burden and Cost --
NESHAP for Brick and Structural Clay Manufacturing (40 CFR part 63,
subpart JJJJJ) (Renewal), attached below.

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and 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 14,086
(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 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 1	(D)

Total Capital/Startup Cost, 

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M 1	(G)

Total O&M,

(E X F)

Parametric monitoring 	$10,000	1	$10,000	$66	72	$4,752

   1   During the fourth year of this ICR, all existing facilities are
required to be in full compliance with the standard.

The total capital/startup costs for this ICR are $10,000.  This is the
total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $4,752.
 This is the total of column G.

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 $14,752.

	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 $18,658.  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 Brick and Structural Clay Manufacturing (40 CFR
part 63, subpart JJJJJ) (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 72 existing respondents will be subject to the
standard.  It is estimated that one additional respondent per year will
become subject.  The overall average number of respondents, as shown in
the table below is 72 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	1	70	0	0	71

2	1	71	0	0	72

3	1	72	0	0	73

Average	1	71	0	0	72



	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 72.

	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

Initial notification of applicability	1	1	0	1

Application of construction/reconstruction	1	1	0	1

Notification of anticipated startup	1	1	0	1

Notification of actual startup	1	1	0	1

Request air pollution control device maintenance exemption	1	1	0	1

Notification of performance test	1	1	0	1

Report of performance test	1	0.1	0	0.1

Notification of compliance status	1	1	0	1

Compliance report	1	1	0	1

Report of deviations	10.8	2	0	21.6

Report of no deviations	61.2	2	0	122.4

Startup, shutdown, malfunction report	7.2	2	0	14.4



	Total	166



	The number of Total Annual Responses is 166.

	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 $1,137,652 (rounded).  Details
regarding these estimates may be found in Table 1: Annual Respondent
Burden and Cost -- NESHAP for Brick and Structural Clay Manufacturing
(40 CFR part 63, subpart JJJJJ) (Renewal), attached below.  Furthermore,
the annual public reporting and recordkeeping burden for this collection
of information is estimated to average 85 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $14,752.  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 next three years is
estimated to be 460 labor hours at a cost of $18,658.  See Table 2:
Annual Agency Burden and Cost -- NESHAP for Brick and Structural Clay
Manufacturing (40 CFR part 63, subpart JJJJJ) (Renewal).

	

	6(f)  Reasons for Change in Burden

	There is no change in the 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.  Therefore, the labor hours and cost figures in the
previous ICR reflect the current burden to the respondents and are
reiterated in this ICR.  Apparent differences of less than 500 hours are
attributable to rounding; in previous years, hours were rounded to the
nearest thousand; this ICR presents more exact figures.

	

6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 85 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-2008-0367.  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-2008-0367 and OMB Control Number 2060-0508 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 Brick and
Structural Clay Manufacturing (40 CFR Part 63, Subpart JJJJJ) (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	0.5	72	36	1.8	3.6	$3,342.17

   B.  Required activities









       Develop startup, shutdown,                        malfunction
plan c, d	100	1	100	1	100	5	10	$9,283.80

       Develop operation, maintenance, and         monitoring plan c, d
100	1	100	1	100	5	10	$9,283.80

   C.  Create information	See 3B







	   D.  Gather existing information	See 3B







	   E.  Write report









       Initial notification of applicability c, e	2	1	2	1	2	0.1	0.2
$185.68

       Notification of construction/                      
reconstruction c, e	2	1	2	1	2	0.1	0.2	$185.68

       Notification of anticipated startup c, e 	2	1	2	1	2	0.1	0.2
$185.68

       Notification of actual startup c, e 	2	1	2	1	2	0.1	0.2	$185.68

       Request air pollution control device           maintenance
exemption c, e	2	1	2	1	2	0.1	0.2	$185.68

       Notification of performance test f	2	1	2	1	2	0.1	0.2	$185.68

       Notification of report of performance         test	2	0.1	0.2	1
0.2	0.01	0.02	$18.56

       Notification of compliance status f	16	1	16	1	16	0.8	1.6
$1,485.41

       First compliance report f	16	1	16	1	16	0.8	1.6	$1,485.41

       Report of deviations f, g,                            	20	2	40
10.8	432	21.6	43.2	$40,106.02

       Report of no deviations f, h, j	8	2	16	61.2	979.2	48.96	97.92
$90,906.97

       Startup, shutdown, malfunction f, i, j     	20	2	40	7.2	288	14.4
28.8	$26,737.34

SUBTOTAL Reporting



	2,276.31	$183,763.56

4.  Recordkeeping requirements









   A. Read instructions 	4	1	4	72	288	14.4	28.8	$26,737.34

   B. Plan activities









       Prepare for initial performance test f, 	24	1	24	24	576	28.8	57.6
$53,474.69

       Prepare for repeat performance

       test f, i,  k	24	1	24	2.4	57.6	2.88	5.76	$5,347.57

   C.  Implement activities 









       Initial performance test f	24	2.5	60	24	1,440	72	144	$133,686.72

       Repeat performance test f, 	24	2.5	60	2.4	144	7.2	14.4	$13,368.67

   D.  Develop record system	See 4E





	 

   E.  Time to enter information









       Records of all information required            by standards l	2
52	104	72	7,488	374.4	748.8	$695,170.94

   F.  Time to train personnel m	40	6	240	1	240	12	24	$22,761.12

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







	  H. Time to transmit or disclose                        information n
0.25	2	0.5	72	36	1.8	3.6	$3,342.17

   I. Time for audits 	N/A







	SUBTOTAL Recordkeeping



	11,810.04	$953,889.22

Subtotals Labor Burden and cost  



	12,249	612.45	1,224.9	$1,137,652.78

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	14,086	$1,137,652



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 72.  There will be one additional new source
per year that will become subject to the rule per year. 

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  This is a one-time only activity.

d  We have assumed that it will take 100 hours for each respondent to
complete the required activity.

e  We have assumed that each respondent will take two hours each to
write report.

f  During the fourth year of this renewal ICR, all existing facilities
are required to be in full compliance with the standard.

g  We have assumed that 15 percent of respondent will report deviations.

h  We have assumed that 85 percent of respondents will report deviation.

i  We have assumed that 10 percent of respondents will file a startup,
shutdown, malfunction report.

j   Semiannual reports are required.

k  We have assumed that 10 percent of respondents will have to repeat
the performance test.

l  It is assumed that all of the respondents will be required to record
information on a weekly basis.

m  It is assumed that it will take 40 hours to train each personnel.

n  It is assumed that respondents will be required to transmit/disclose
information on a semiannual basis. 

Table 2:  Average Annual EPA Burden - NESHAP for Brick and Structural
Clay Manufacturing (40 CFR Part 63, Subpart JJJJJ) (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

1.   Attend Initial performance test 	24	1	24	0	0	0	0	$0

2.   Attend repeat performance









         Retesting preparation	8	1	8	0	0	0	0	$0

         Retesting	24	1	24	0	0	0	0	$0

3.  Report review









        Initial notification of applicability	2	1	2	1	2	0.1	0.2	$93.24

        Notification of  construction/ c                reconstruction	2
1	2	1	2	0.1	0.2	$93.24

        Notification of anticipated startup c	2	1	2	1	2	0.1	0.2	$93.24

        Notification of actual startup c	2	1	2	1	2	0.1	0.2	$93.24

        Request for APCD maintenance c           exemption	2	1	2	1	2	0.1
0.2	$93.24

        Notification of performance test d	2	1	2	1	2	0.1	0.2	$93.24

        Notification of report of                          performance
tests	2	0.1	0.2	1	0.2	0.01	0.02	$9.32

        Notification of compliance status d	60	1	60	1	60	3	6	$2,797.26

        Repeat performance test report d, e	40	1	40	0.1	4	0.2	0.4
$186.48

        First compliance report	8	1	8	0	0	0	0	$0

        Semiannual compliance reports









             Deviation reports f, g	8	2	16	10.8	172.8	8.64	17.28
$8,056.11

             No deviation reports f	2	2	2	61.2	122.4	6.12	12.24
$5,706.41

       Review of startup, shutdown, f, h             malfunction reports
2	2	4	7.2	28.8	1.44	2.88	$1,342.69

Subtotals Labor Burden and cost



	400.2	20.01	40.02	$18,657.71

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	460	$18,658



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 72.  There will be one additional new source
per year that will      become subject to the rule per year. 

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  This is a one-time only activity.    

    d  During the fourth year of the ICR, all existing facilities are
required to come in full compliance with the standard.

e  We have assumed that 10 percent of respondents will review the repeat
performance test report

f  Semiannual reports are required.

g  We have assumed that 15 percent of respondents will have to review
the deviation report.

h  We have assumed that 10 percent of respondents will be engaged in the
reviewing of the startup, shutdown, malfunction reports.

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