| Table 1: Annual Respondent Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal) |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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Person-hours per occurrence |
No. of occurrences per respondent per year |
Person-hours per respondent per year (C=AxB) |
Respondents per year a |
Technical person-hours per year (E=CxD) |
Management person-hours per year (Ex0.05) |
Clerical person-hours per year (Ex0.1) |
Total Cost per year, $ b |
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| 1. Applications |
N/A |
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Labor Rates |
| 2. Survey and Studies |
N/A |
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Technical |
$141.75 |
| 3. Reporting Requirements |
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Management |
$172.41 |
| A. Familiarization with the regulatory requirements c |
2 |
1 |
2 |
3 |
6 |
0.3 |
0.6 |
$945 |
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Clerical |
$71.36 |
| B. Required activities |
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| Develop an operation, maintenance, monitoring plan |
32 |
1 |
32 |
0 |
0 |
0 |
0 |
$0 |
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| Update operation, maintenance, monitoring plan d |
4 |
1 |
4 |
1 |
4 |
0.2 |
0.4 |
$630 |
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| Performance tests and reports e |
75 |
1 |
75 |
1.8 |
135 |
6.75 |
13.5 |
$21,263 |
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| Performance retests and reports e |
24 |
1 |
24 |
0.2 |
4.8 |
0.24 |
0.48 |
$756 |
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| Initial CMS performance evaluation f |
12 |
1 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| Initial CEMS demonstration g |
229 |
1 |
229 |
0 |
0 |
0 |
0 |
$0 |
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| Quarterly Appendix F audits of CEMS (THC) g |
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| a) RATA audit (one per year) |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| b) RAA audit (three per year) |
4 |
3 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| c) Daily calibration and operation |
1 |
365 |
365 |
0 |
0 |
0 |
0 |
$0 |
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| C. Create information |
See 3B |
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| D. Gather existing information |
See 3B |
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| E. Write report |
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| Notification of applicability |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of anticipated startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test e |
2 |
1 |
2 |
2 |
4 |
0.2 |
0.4 |
$630 |
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| Notification of compliance status |
16 |
1 |
16 |
2 |
32 |
1.6 |
3.2 |
$5,040 |
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| Notification of intent to use alternative fuel h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Request approval to bypass the control device for maintenance i |
1 |
6 |
6 |
1 |
6 |
0.3 |
0.6 |
$945 |
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| Semi-annual compliance report with deviations j |
16 |
1 |
16 |
2 |
32 |
1.6 |
3.2 |
$5,040 |
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| Semi-annual compliance report with no deviations k |
8 |
2 |
16 |
2 |
32 |
1.6 |
3.2 |
$5,040 |
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| Report of alternative fuel use l |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Subtotal for Reporting Requirements |
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294 |
$40,290 |
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| 4. Recordkeeping Requirements |
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| A. Familiarization with rule requirements |
See 3A |
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| B. Plan activities |
See 4E |
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| C. Implement activities |
See 4E |
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| D. Develop record system |
See 4E |
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| E. Time to enter information |
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| Records of all information required by standards m |
0.25 |
52 |
13 |
3 |
39 |
1.95 |
3.9 |
$6,143 |
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| F. Time to train personnel |
20 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
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| G. Time to transmit or disclose information n |
0.25 |
3 |
0.75 |
3 |
2.25 |
0.1125 |
0.225 |
$354 |
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| H. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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47 |
$6,497 |
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| TOTAL ANNUAL BURDEN AND COSTS (rounded): o |
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341 |
$46,800 |
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| TOTAL CAPITAL/O&M COST (rounded): o |
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$87,000 |
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18 |
Total responses per year |
| GRAND TOTAL (rounded): o |
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$134,000 |
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19 |
hr/resp |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to the rule will be three. There will be no additional new source per year that will become subject to the rule over the 3-year period of this ICR. |
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| b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. |
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| c We have assumed that the number of person-hours per occurrence is an average over 3 years of Year 1 (5), Year 2 (0.5), and Year 3(0.5) with more effort in Year 1. |
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| d We have assumed that all three facilities will need to update their plan, for an average number of respondents of 1 per year. |
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| e The person-hours per response account for tests on both continuous and batch sources. Tests for continuous sources may be shorter than average and tests for batch sources may be longer than average. In addition, we have assumed that the respondents per year is 1.8 for performance testing since there are effectively 9 separate sets of tests that would have to be done every 5 years across the three facilities. This estimate of 9 tests is based on EPA's previous estimate of 4 tests for 2 facilities plus 5 additional sources being tested based on industry comments received for the ICR renewal. We have also assumed that one test will need to be redone each five years, or 0.2 respondents per year. |
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| f We assume 12 hours are required to complete the CMS performance evaluation. This activity only applies to new sources. |
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| g We have assumed that there are no existing respondents required to comply using THC CEMS. |
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| h § 63.9812(f) states that on and after November 19, 2021, facilities may not use a fuel other than natural gas or equivalent to fire the affected kiln. |
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| i Facilities must request approval to bypass the control device for each instance of control device maintenance. The estimated number of requests per year is based on information from industry regarding the types of scheduled routine maintenance. |
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| j We have assumed that two respondents will report a deviation once per year. |
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| k We have assumed that one respondent will report no deviations on a semi-annual basis and the other two respondents will report no deviations for one of the two semi-annual reports per year. |
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| l § 63.9814(g) states that on and after November 19, 2021, facilities may not use a fuel other than natural gas or equivalent to fire the affected kiln. |
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| m We have assumed that information will be recorded once per week for 52 weeks per year. |
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| n We have assumed that it will take 0.25 hours for information to be transmitted or disclosed, and two semi-annual reports with at least one more report (e.g. notification of fuel change) will be submitted annually. |
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| o Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal) |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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EPA person-hours per occurrence |
No. of occurrences per plant per year |
EPA person-hours per plant per year (C=AxB) |
Plants per year a |
Technical person-hours per year (E=CxD) |
Management person-hours per year (Ex0.05) |
Clerical person-hours per year (Ex0.1) |
Total Cost per year, $ b |
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| Attend initial performance test |
48 |
1 |
48 |
1.8 |
86.4 |
4.32 |
8.64 |
$5,530 |
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Labor Rates |
| Attend repeat performance test |
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Managerial |
$76.91 |
| Retesting preparation |
8 |
1 |
8 |
0.2 |
1.6 |
0.08 |
0.16 |
$102 |
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Technical |
$57.07 |
| Retesting |
20 |
1 |
20 |
0.2 |
4 |
0.2 |
0.4 |
$256 |
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Clerical |
$30.88 |
| Report review |
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| Notification of applicability |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of anticipated startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test |
2 |
1 |
2 |
2 |
4 |
0.2 |
0.4 |
$256 |
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| Notification of compliance status |
2 |
1 |
2 |
2 |
4 |
0.2 |
0.4 |
$256 |
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| Notification of intent to use alternative fuel c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Request for approval to bypass the control device for maintenance |
2 |
6 |
12 |
1 |
12 |
0.6 |
1.2 |
$768 |
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| Review performance test report |
40 |
1 |
40 |
2 |
80 |
4 |
8 |
$5,120 |
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| Semi-annual compliance reports |
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| Deviation d |
16 |
1 |
16 |
2 |
32 |
1.6 |
3.2 |
$2,048 |
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| No Deviation e |
8 |
2 |
16 |
2 |
32 |
1.6 |
3.2 |
$2,048 |
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| Report of alternative fuel use f |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| TOTAL ANNUAL BURDEN AND COST (rounded) g |
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294 |
$16,400 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to the rule will be three. There will be no additional new source per year that will become subject to the rule over the 3-year period of this ICR. |
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| b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. |
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| c § 63.9812(f) states that on and after November 19, 2021, facilities may not use a fuel other than natural gas or equivalent to fire the affected kiln. |
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| d We have assumed that two respondents will report deviations once a year. |
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| e We have assumed that one respondent will report no deviations twice a year and that the other two respondents will report no deviations for one of the two semi-annual reports. |
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| f § 63.9814(g) states that on and after November 19, 2021, facilities may not use a fuel other than natural gas or equivalent to fire the affected kiln. |
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| g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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| Capital/Startup vs. Operation and Maintenance (O&M) Costs |
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| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
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CEPCI Index |
| Continuous Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
Total Capital/Startup Cost, (B x C) |
Annual O&M Costs for One Respondent a |
Number of Respondents with O&M |
Total O&M, (E x F) |
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2009 |
521.9 |
| Continuous parameter monitoring system b |
$25,715 |
0 |
$0 |
$581 |
3 |
$1,743 |
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2021 |
708 |
| Visible emissions checks c |
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$12,645 |
2 |
$25,289 |
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2023 |
797.9 |
| Performance Testing d |
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$60,000 |
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| Total (rounded) e |
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$60,000 |
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$27,000 |
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$87,000 |
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| a Capital/Startup and Annual O&M costs have been updated from 2009 to 2023 (Continuous parameter monitoring system) and 2021 to 2023 (Visible emissions checks) using the CEPCI Index. |
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| b It is assumed that no existing sources have installed CEMS. |
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| c Required for compliance with the proposed particulate matter standards for clay refractory kilns. There are two facilities with clay refractory kilns. |
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| d Respondents with affected sources are required to conduct performance testing to demonstrate compliance every 5 years. Across the 3 years of the ICR, the cost of the tests conducted in each year is estimated to be $60,000 per year. |
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| e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Total Annual Responses |
| (A) |
(B) |
(C) |
(D) |
(E) |
| Information Collection Activity |
Number of Respondents |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
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 |
2 |
1 |
0 |
2 |
| Notification of compliance status |
2 |
1 |
0 |
2 |
| Notification of intent to use alternative fuel |
0 |
1 |
0 |
0 |
| Request approval to bypass the control device for maintenance |
1 |
6 |
0 |
6 |
| Semi-annual compliance report with deviations |
2 |
1 |
0 |
2 |
| Semi-annual compliance report with no deviations |
2 |
2 |
0 |
4 |
| Report of alternative fuel use |
0 |
1 |
0 |
0 |
| Performance testing results |
2 |
1 |
0 |
2 |
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Total |
18 |