Burden Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	331
Number of Respondents	3
Total Estimated Burden Hours	2,650
Total Estimated Costs	$458,000
Annualized Capital O&M	$124,000
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Clay Ceramics (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
2. Survey and Studies
3. Reporting requirements
A. Familiarize with regulatory requirements c	1	1	1	3	3	0	0	$435.03
B. Required Activities											Labor Rates
i. Develop OM&M plan d	200	1	200	0	0	0	0	$0			Management	$163.17
ii. Update OM&M plan	10	1	10	3	30	2	3	$4,350.29			Technical	$130.28
iii. Conduct control device maintenance / inspections	30	1	30	3	90	5	9	$13,050.86			Clerical	$65.71
iv. Conduct shuttle kiln maintenance/ inspections	160	1	160	3	480	24	48	$69,604.56
C. Create Information	See 3B
D. Gather existing information	See 3B
E. Write Report
i. Initial notification of applicability d	6	1	6	0	0	0	0	$0
ii. Notification of construction/reconstruction d	28	1	28	0	0	0	0	$0
iii. Notification of anticipated startup d	3	1	3	0	0	0	0	$0
iv. Notification of actual startup d	3	1	3	0	0	0	0	$0
v. Request to use control device maintenance alternative standard d	4	1	4	0	0	0	0	$0
vi. Notification of performance test l	6	1	6	0.6	3.6	0.18	0.36	$522.03
vii. Notification of compliance status d,e	24	1	24	0.6	14	0.72	1.44	$2,088.14
viii. Report of performance test (through ERT)	20	1	20	0.6	12	0.6	1.2	$1,740.11
ix. Notification of alternative fuel use f	2	1	2	0.3	0.6	0.03	0.06	$87.01
x. First compliance report	30	1	30	0	0	0	0	$0
xi. Semi-annual compliance reports
Deviations g	30	2	60	0.45	27	1.35	2.70	$3,915.26
No deviations g	12	2	24	2.55	61	3.06	6.12	$8,874.58
xii. Report of alternative fuel use f	4	2	8	0.3	2.4	0.12	0.24	$348.02
Subtotal for Reporting Requirements					833			$105,016
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities
i. Prepare for initial performance test	24	1	24	0.6	14	0.72	1.44	$2,088.14
ii. Prepare for repeat performance test h	24	1	24	0.06	1.4	0.072	0.144	$208.81
C. Implement activities
i. Attend initial performance test	34	2.5	85	0.6	51	2.55	5.1	$7,395.48
ii. Attend repeat performance test h	34	2.5	85	0.06	5	0.255	0.51	$739.55
D. Develop record system	60	6	360	0	0	0	0	$0.00
E. Time to enter information
i. Records of compliance data	8	52	416	3	1,248	62.4	124.8	$180,971.86
ii. Records of alternative fuel use	1	12	12	0.3	4	0.18	0.36	$522.03
iii. Records of APCD maintenance/ inspections	See 3B
iv. Records of compliance with work practices	See 3B
v. Records of deviations	2	12	24	3	72	3.6	7.2	$10,440.68
F. Time to train personnel i
i. Initial training	48	6	288	0	0	0	0	$0
ii. Annual training	10	6	60	3	180	9	18	$26,101.71
G. Time to transmit/disclose information j	0.25	1	0.25	3	0.8	0.04	0.08	$108.76
Subtotal for Recordkeeping Requirements					1,813			$228,577		331	hr/response
Total Labor Burden and Costs (rounded) k					2,650			$334,000
Total Capital and O&M Cost (rounded) k								$124,000
GRAND TOTAL (rounded) m								$458,000
Assumptions:
a We assume that an average of 3 respondents will be subject to this rule, and that no new sources will become subject to the rule over the three-year period of the ICR.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70+ 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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.
c We have assumed that existing respondents will have to familiarize with the regulatory requirements each year.
d One-time only activities.
e The notification of compliance status includes the performance test report and documentation of any other initial compliance demonstration.
f Assumes 10% of facilities will use an alternative fuel once per year.
g Assumes 15% of respondents have deviations to report in semiannual compliance reports, and 85% report no deviations.
h We have assumed that an average of 3 respondents will conduct performance tests once every five years, for an average of 0.6 sources per year (3 sources/5 years = 0.6 sources per year). Assumes 10% of plants fail initial performance test and must repeat it. Based on comments from industry, an average of 2.5 plant personnel attend performance tests. Assume no travel for plant personnel. Repeat testing is also required 5 years following initial testing.
i Based on comments from industry, assumes 48 hours of initial training and 10 hours of annual training for 6 plant personnel.
j Time associated with transmitting reports. Equal to the number of respondents submitting reports.
k Based on estimates in Clay Ceramics Monitoring and Testing Requirements and Costs Memo. Stack testing costs assume EPA Method 5 or 29 for PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl, and EPA Method 23 for dioxins/furans. VE testing costs assume EPA Method 22.
l We have assumed that an average of 3 respondents will conduct performance tests once every five years, for an average of 0.6 sources per year (3 sources/5 years = 0.6 sources per year). We have also assumed 10% of plants will fail an initial performance test and must repeat it.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Clay Ceramics (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. Attend initial performance test c	24	1	24	0.06	1.44	0.072	0.144	$88.03
2. Attend repeat performance test c,d
Retesting preparation	8	1	8	0.006	0.048	0.0024	0.0048	$2.93
Retesting	24	1	24	0.006	0.144	0.0072	0.0144	$8.80
3. Litigation e	2,080	1	2080	0.03	62.4	3.12	6.24	$3,814.70
4. Excess emissions enforcement activities f	48	1	48	0.15	7.2	0.36	0.72	$440.16
5. Report review												Labor Rates
Initial notification of applicability	2	1	2	0	0	0	0	$0.00				Management	$73.46
Notification of constr./reconstr.	2	1	2	0	0	0	0	$0.00				Technical	$54.51
Notification of anticipated startup	2	1	2	0	0	0	0	$0.00				Clerical	$29.50
Notification of actual startup	2	1	2	0	0	0	0	$0.00
Request to use APCD maintenance alternative standard	2	1	2	0	0	0	0	$0.00
Notification of performance test	2	1	2	0.6	1.2	0.06	0.12	$73.36
Notification of compliance status g	60	1	60	0.6	36	1.8	3.6	$2,200.79
Notification of alternative fuel useh	2	1	2	0.3	0.6	0.03	0.06	$36.68
Repeat performance test report d	40	1	40	0.06	2.4	0.12	0.24	$146.72
First compliance report	4	1	4	0	0	0	0	$0.00
Semi-annual compliance reports:
Deviations i	8	2	16	0.45	7.2	0.36	0.72	$440.16
No deviations i	2	2	4	2.55	10	0.5	1	$623.56
Report of alternative fuel use h	1	1	1	0.3	0.3	0.015	0.03	$18.34
TOTAL BURDEN AND COST (SALARY)(rounded) j					149			$7,890
Travel Expenses for Tests Attended k								$48
TOTAL ANNUAL COST (SALARY + EXPENSES)(rounded) k								$7,940
Assumptions:
a We assume that an average of 3 respondents will be subject to this rule, and that no new sources will become subject to the rule over the three-year period of the ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 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.
c We have assumed that an average of 3 respondents will conduct performance tests once every five years, for an average of 0.6 sources per year (3 sources/5 years = 0.6 sources per year). We have also assumed Agency personnel will attend performance tests at 10% of plants (0.6 sources per year * 10% = 0.06).
d Assumes 10% of plants will fail an initial performance test and must repeat it and assumes Agency personnel attend 10% of the repeat tests.
e Assumes 1% of plants will be involved in litigation.
f Assumes 5% of the plants are required to retest as a result of excess emissions and assumes Agency personnel attend all of the retests.
g Notification of compliance status includes the performance test report.
h Assumes 10% of facilities will use an alternative fuel once per year.
i Assumes 15% of the plants report deviations semiannually and 85% report no deviations.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
k Assumes Agency personnel (1 person) will spend 2 days per plant plus time for travel, at $166 per diem per day, and $400 transportation expense per round trip to attend performance tests.

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Sheet 4: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
CAPITAL COSTS:
Initial performance tests a, b	$65,500	0	$0	$65,500	0.6	$39,300
Repeat performance tests a, b	$65,500	0	$0	$65,500	0.06	$3,930
Photocopy/postage c				$145	3	$435
Visible emissions tests a,c	$26,858	0	$0	$26,858	3	$80,574
Totals (rounded) d			$0			$124,000
a Based on estimates in Clay Ceramics Monitoring and Testing Requirements and Costs Memo. Stack testing costs assume EPA Method 5 or 29 for PM, EPA Method 29 for metals, EPA Method 26A for HF and HCl, and EPA Method 23 for dioxins/furans. VE testing costs assume EPA Method 22. Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)t/((1+i)t-1) where i = interest rate (%) and t = equipment life (years).
b We have assumed that an average of 3 repsondents will conduct performance tests once every five years, for an average of 0.6 sources per year (3 sources/5 years = 0.6 sources per year). Assumes 10% of plants will fail an initial performance test and must repeat it.
c O&M costs for photocopying and postage are estimated as $145 per year per respondent. The monitoring equipment needed to monitor parameters other than visible emissions (e.g., lime feed rate) is included as part of the control system and therefore adds no additional capital or O&M cost. The O&M cost associated with VE monitoring includes VE training for two people every 5 years, conducting the 15-minute VE test, and preparing for/documenting the VE test (occurs after 3-year ICR clearance period).
d Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

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Sheet 5: Responses

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
Initial 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
Request to use APCD maintenance alternative standard	0	1	0	0
Notification of performance test	0.6	1	0	0.6
Notification of compliance status	0.6	1	0	0.6
Report of performance test (through ERT)	0.6	1	0	0.6
Notification of alternative fuel use	0.3	1	0	0.3
First compliance report	0	1	0	0
Semi-annual compliance reports:
Deviation	0.45	2	0	0.9
No deviation	2.55	2	0	5.1
Report of alternative fuel use	0.3	1	0	0.3
			Total (rounded)	8

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	3	0	0	3
2	0	3	0	0	3
3	0	3	0	0	3
Average	0	3	0	0	3
a New respondents include sources with constructed and reconstructed affected facilities.