SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Clay Ceramics Manufacturing (40 CFR Part 63, Subpart KKKKK)
(Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NESHAP for Clay Ceramics Manufacturing (40 CFR Part 63, Subpart KKKKK)
(Renewal), EPA ICR Number 2023.04, OMB Control Number 2060-0513

	1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Clay Ceramics Manufacturing were proposed on July 22, 2002 (67 FR
47893), and promulgated on May 16, 2003 (68 FR 26738).  These standards
apply to owners or operators of new and existing clay ceramic
manufacturing facilities.  A clay ceramics facility manufactures pressed
floor tile, pressed wall tile, other pressed tile, or sanitaryware
(e.g., sinks and toilets).  Clay ceramics facilities typically form,
dry, and fire tile or sanitaryware products that are composed of clay,
shale, and various additives.  Glazes are applied to some tile and
sanitaryware products.  Consistent with the General Provision for NESHAP
for source categories (40 CFR part 63, subpart A), respondents do not
include the owner, or operator of any facility that is not a major
source of hazardous air pollutant (HAP) emissions, or any facility that
does not operate affected kilns, even if the facility is a major source.
 A major source of HAP is a plant site that emits or has the potential
to emit any single HAP at a rate of 10 tons or more per year, or any
combination of HAP at a rate of 25 tons, or more per year, and kilns are
used to fire the clay ceramic products.  The predominant HAP emitted
from clay ceramics manufacturing facilities includes hydrogen fluoride
(HF), hydrogen chloride (HCl), and metals (antimony, arsenic, beryllium,
cadmium, chromium, cobalt, mercury, manganese, nickel, lead, and
selenium).

	In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They also are 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.  Respondents also are required to
submit semiannual reports.

	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 appropriate 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 each plant site
has only one respondent (i.e., the owner/operator of the plant site).

	Approximately nine respondents that are existing sources will be
subject to the standard and one additional respondent per year will
become subject to the regulation over 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 below in Table 1:
Annual Respondent Burden and Cost – NESHAP for Clay Ceramics
Manufacturing (40 CFR Part 63, Subpart KKKKK) (Renewal).  The burden to
the “Federal Government” is attributed entirely to work performed by
federal employees or government contractors; this burden may be found
below in Table 2: Average Annual EPA Burden – NESHAP for Clay Ceramics
Manufacturing (40 CFR Part 63, Subpart KKKKK) (Renewal).                
 

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 (CAA), 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, HAP emissions from clay ceramics
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 KKKKK.

	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 also is
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.

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

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

	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, consultations with industry representatives
(i.e., respondents) were 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 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

	These reporting and recordkeeping requirements do not violate any of
the regulations promulgated by OMB at 5 CFR part 1320, section 1320.5.

	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

	The reporting and recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are clay
ceramics manufacturers.  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 KKKKK)	SIC Codes	NAICS Codes

Ceramic Wall and Floor Tile Manufacturing	3253	327122

Vitreous China Plumbing Fixtures and China and Earthenware Fittings and
Bathroom Accessories	3261	327111



	4(b)  Information Requested

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

		(i)  Data Items

In this ICR, all the data that is recorded or reported is required by
NESHAP for Clay Ceramics Manufacturing (40 CFR part 63, subpart KKKKK).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Notification of applicability	63.5

Initial notification (including construction/reconstruction)	63.9 (b),
and 63.8630(a)-(c)

Notification of performance test	63.7(b)-c). 63.9(e), and 63.8630(d)

Notification of compliance status (including, if applicable, performance
test results, operating parameter values, documentation of fuel used,
capture/collection system design information, bag leak detection system
documentation, operation, maintenance, and monitoring (OM&M) plan, and
startup, shutdown, and malfunction plan (SSMP)	63.9(h), 63.10(d)(2), and
63.8630(e)

Notification of alternative fuel use	63.8630(g)

Request for routine control device maintenance exemption	63.8630(f)

Semiannual compliance report	63.10(e)(3), and 63.8635(b)-(f)

Startup, shutdown, and malfunction reports	63.10(d)(5) and 63.8635(c)(4)

No deviation of compliance monitoring system (CMS)	63.8635(c)(6)-(7)

Deviation of CMS	63.8635(d)-(e)

Report of alternative fuel use	63.8635(g)



	A source must make the following reports:

Recordkeeping 

Record of startup, shutdown, and malfunctions	63.6(e)(3)(iii)-(iv), and
63.8640(a)(2)

Record of initial notification and compliance status	63.10(b)(2)(xiv),
and 63.8640(a)(1)

Records of SSMP and OM&M plan	63.6(e)(3), and 63.8640 (c)(6)

Record of performance tests	63.10(b)(2)(viii), and 63.8640(a)(3)

Records of CMS, production records, and gab leak detection system.
63.8(d)(3), 63.8(f)(6)(i), 63.8(g), 63.10(b)(2)(vi)-(xi), and
63.8640(b)-(c)

Records of fuel type used	63.8640(c)(7)

Records are required to be retained for five years	63.10(b), and 63.8645



Electronic Reporting

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

	Also, regulatory agencies, in cooperation with the respondents,
continue to create reporting systems to transmit data electronically. 
However, electronic reporting systems still are 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, 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 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.

	Information contained in the reports is entered into the Air Facility
System (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: the
promulgated rule notice in the Federal Register; the Economic Impact
Analysis of the Clay Ceramics Manufacturing NESHAP: Final Rule (2003);
and a search of publicly available current data sources.  The Economic
Impact Analysis document states: “Generally, the small business
analysis identifies the businesses that will be affected by this
proposed rule and provides an analysis to assist in determining whether
this rule is likely to impose a significant impact on a substantial
number of the small businesses within this industry … Since facilities
in the clay ceramics manufacturing source category face a MACT floor
that requires no control of existing sources, companies owning these
facilities face no compliance costs. In other words, for all of the
companies that own facilities included in the clay ceramics
manufacturing source category, all have compliance costs that are zero
percent of their sales. This rule is therefore not expected to have a
significant impact on a substantial number of 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 below in Table 1: Annual Industry Burden - NESHAP
for Clay Ceramics Manufacturing (40 CFR Part 63, Subpart KKKKK)
(Renewal).

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.

	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 527
hours (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 types of industry costs associated with the information collection
activities in the subject standard are both labor costs, which are
addressed elsewhere in this ICR, and the costs associated with
continuous monitoring.  The capital/startup costs are one-time costs
incurred 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 1	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondent with O&M	(G)

Total O&M,

(E X F)

Parameter monitoring	$2,468	1	$2,468	$78	9	$702

1 Capital cost for new respondent includes conducting performance tests,
visible emissions training for two individuals, and file cabinet.

The total capital/startup costs for this ICR are $2,468.  This is the
total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $702. 
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 $39,400 (rounded).  This cost is based on the average
hourly labor rate as follows:

		Managerial	$57.20   (GS-13, Step 5, $35.75 x 1.6)

		Technical	$42.45   (GS-12, Step 1, $26.53 x 1.6)

		Clerical	$22.96   (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2006
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear below in Table 2: Average Annual EPA
Burden - NESHAP for Clay Ceramics Manufacturing (40 CFR Part 63, Subpart
KKKKK) (Renewal).

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

	Based on our research for this ICR, approximately 10 respondents will
be subject to the standard over the next three years.  The rule
stipulates that only new sources with one-time-only report requirements
are subject to this subpart.  The overall average number of respondents,
as shown in the table below, is 10 sources 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	8	0	0	9

2	1	9	0	0	10

3	1	10	0	0	11

Average	1	9	0	0	10



	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 10.

 

	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	1	1	0	1

Notification of construction/reconstruction	1	1	0	1

Notification of anticipated startup	1	1	0	1

Notification of actual startup	1	1	0	1

Request for APCD maintenance exemption	1	1	0	1

Notification of performance test	2.8	1	0	2.8

Notification of repeat of performance tests	0.3	1	0	0.3

Notification of compliance status	2.8	1	0	2.8

Notification of alternative fuel use	1	1	0	1

Report of deviation	1.4	1	0	1.4

Report of no deviation	7.7	2	0	15.4

Report of startup, shutdown, malfunction	0.9	2	0	1.8

Report of alternative fuel use	1	1	0	1



	Total	31



	The number of Total Annual Responses is 31.

	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 are summarized below.

		(i) Respondent Tally

The total annual labor costs are $42,532.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Clay Ceramics Manufacturing (40 CFR Part 63, Subpart
KKKKK) (Renewal).  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 17 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $3,000 (rounded).  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 951 labor hours at a cost of $39,380.  See below
Table 2: Annual Agency Burden and Cost -      NESHAP for Clay Ceramics
Manufacturing (40 CFR Part 63, Subpart KKKKK) (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: 
1) the regulations have not changed over the past three years and are
not anticipated to change over the next three years; and 2) 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.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 17 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-2008-0369.  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-2008-0369 and OMB Control Number 2060-0513 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 Clay Ceramics
Manufacturing (40 CFR Part 63,  Subpart KKKKK) (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	10	5	0.25	0.5	$464.18

   B.  Required activities









       Startup, shutdown, malfunction plan	32	1	32	1	32	1.6	3.2
$2,970.82

       Operation, maintenance, and                     monitoring plan
32	1	32	1	32	1.6	3.2	$2,970.82

   C.  Create information	See4B







	   D.  Gather existing information	See 4B







	   E.   Write report









      Notification of  applicability c	2	1	2	1	2	0.1	0.2	$185.67

      Notification of                                          
construction/reconstruction c	2	1	2	1	2	0.1	0.2	$185.67

      Notification of anticipated startup c	2	1	2	1	2	0.1	0.2	$185.67

      Notification of actual startup c	2	1	2

2	0.1	0.2	$185.67

      Request for APCD maintenance               exemption c	2	1	2	1





      Notification of performance test d	2	1	2	2.8	5.6	0.28	0.56	$519.90

      Repeat of performance test	2	1	2	0.3	0.6	0.03	0.06	$55.70

      Notification of compliance status d	16	1	16	2.8	44.8	2.24	4.48
$4,159.14

      Notification of alternative fuel use e	2	1	2	1.8	3.6	0.18	0.36
$334.22

      Semiannual compliance reports









          Deviations f	16	1	16	1.4	22.4	1.12	2.24	$2,079.56

          No deviation  g	2	2	4	7.7	30.8	1.54	3.08	$2,857.41

          Startup, shutdown, malfunction h	8	2	16	0.9	14.4	0.72	1.44
$1,336.86

          Report of alternative fuel use i	8	1	8	0.9	7.2	0.36	0.72
$668.43

SUBTOTAL Reporting



	237.36	$19,159.72

4.  Recordkeeping requirements









   A.  Read instructions 	4	1	4	10	40	2	4	$3,713.52

   B.  Plan activities	Included in 4E







	   C.  Implement activities 	Included in 4E







	   D.  Develop record system	Included in 4E





	 

   E.  Time to enter information









      Records of fuel use – new kilns j	1.5	52	78	1	78	3.9	7.8
$7,241.36

      Records of fuel use – existing kilns k	1	12	12	9	108	5.4	10.8
$10,026.50

   F. Time train personnel l	20	1	20	1	20	1	2	$1,856.76

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







	  H. Time to transmit/disclose                          information
0.25	2.3	0.575	10	5.75	0.29	0.575	$534.06

  I.  Time to audit	N/A







	SUBTOTAL Recordkeeping



	289.52	$23,372.20

Subtotals Labor Burden and cost  



	458.15	22.91	45.815	$42,531.92

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	527	$42,532



Assumptions:

    a  We have assumed that the average number of respondents that will
be subject to the rule is 10, with one additional new source per year
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  This is a one-time only activity.

    d  We have assumed that it will take 2 hours for each respondent to
write compliance status report for existing facilities.  Performance
tests must be conducted initially and thereafter, every five years (1
new + (0.20x9existing))=2.8.  We have assumed that 10 percent of the
performance tests are repeated.

    e  We have assumed that 10 percent of respondents will use an
alternative fuel once per year.

    f  We have assumed that 15 percent of respondents will report
deviation once a year.

   g  We have assumed that 85 percent of respondents will report no
deviation.

   h  We have assumed that 10 percent of respondents will have a
startup, shutdown, malfunction occur.

   i  We have assumed that 10 percent of respondents will report
alternative fuel use.

   j  We have assumed that it will take each new respondent 1.5 hours to
record information on fuel use.

   k  We have assumed that it will take each existing respondent 1 hour
to record information on fuel use.

   l  We have assumed that it will take 20 hours to train personnel.

  m  We have assumed  that it will take 0.25 hours for respondents to
transmit/disclose information.

Table 2:  Average Annual EPA Burden - NESHAP for Clay Ceramics
Manufacturing (40 CFR Part 63, Subpart KKKKK) (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  Initial performance test 	40	1	40	2.8	112	5.6	11.2	$5,331.87

2  Repeat performance test c	40	1	40	0.3	12	0.6	1.2	$571.27

3  Report review









        Notification of applicability d	2	1	2	8	16	0.8	1.6	$761.70

        Notification of  construction/                  reconstruction e
2	1	2	1	2	0.1	0.2	$95.21

        Notification of anticipated

        startup e, f	2	1	2	1	2	0.1	0.2	$95.21

        Notification of actual startup e, f	2	1	2	1	2	0.1	0.2	$95.21

        Request APCD maintenance                   exemption	2	1	2	1	2
0.1	0.2	$95.21

        Notification of performance tests e	2	1	2	2.8	5.6	0.28	0.56
$266.60

        Notification of compliance status g	60	1	60	2.8	168	8.4	16.8
$7,997.81

        Notification of alternative fuel use 	2	1	2	10	20	1	2	$952.12

        Performance test reports h	40	1	40	2.8	112	5.6	11.2	$5,331.87

        Semiannual compliance reports









            Deviations i	20	1	20	1.4	28	1.4	2.8	$1,332.97

            No deviations j	20	2	40	7.7	308	15.4	30.8	$14,662.65

            Startup, shutdown, malfunction               report k	20	2
40	0.9	36	1.8	3.6	$1,713.82

        Report of alternative fuel use l	2	1	2	1	2	0.1	0.2	$95.21

Subtotals Labor Burden and cost



	827.2	41.36	82.72	$39,398.72

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	951.28	$39,400



Assumptions:

    a  We have assumed that the average number of respondents that will
be subject to the rule is 10, with one additional new source per year
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 $57.20 (GS-13, Step 5, $35.75 x 1.6),
Technical rate of $42.45 (GS-12, Step 1, $26.53 x 1.6), and Clerical
rate of $22.96 (GS-6, Step 3, $14.35 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2006 General Schedule” which
excludes locality rates of pay.

c  We have assumed that 10 percent of initial performance test will have
to be repeated.

d  We have assumed that it will take 2 hours to review report of
applicability.

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

f  Performance tests must be conducted upon startup and every five years
thereafter, (1 new + (0.20x9 existing)) = 2.8

g  We have assumed that it will take 60 hours for new respondent to
review report on notification of compliance status.

h  We have assumed that it will take 40 hours to review the repeat
performance test report.

i  We have assumed that 15 percent of respondents will report deviations
once a year.

j  We have assumed that 85 percent of respondents will report no
deviations on a semiannual basis.

k  We have assumed that no deviation occurred from the fuel-type work
practice standard for existing kilns.  

l  We have assumed that 10 percent of respondents will report using
alternative fuel once a year.

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