**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing and Secondary Nonferrous Metals Processing Area Sources (40 CFR Part 63, Subparts RRRRRR,**  **SSSSSS, and TTTTTT) (Renewal)**
**1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NESHAP for Clay

Ceramics Manufacturing, Glass Manufacturing and Secondary N onferrous Metals Processing Area Sources (40 CFR Part 63, Subparts RRRRRR, SSSSSS, an d TTTTTT) (Renewal), EPA I CR Number 2274.0 4, OMB Control Number 2060

- 0606 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for C lay C eramics M anufacturing, G lass M anufacturing , and S econdary N onf errous M etals P rocessing Area S ources (40 CFR 63 : subparts RRRRRR, SSSSSS , and TTTTTT , respectively) were proposed on September 20, 2007, and promulgated on December 26, 2007 (72 FR 73180)

. These regulations apply

to both existing and new clay ceramics manufacturing facilities that process : 1) more than 50 tons per year (tpy) of wet clay and are an area sources of hazardous air pollutants (HAP); 2) glass manufacturing facilities that do not have the potential to emit any single HAP at a rat e of 10 tpy or more (or any combination of HAP at a rate 25 tpy or more), and use continuous furnaces to produce glass that contains HAP as raw materials; and 3) secondary nonferrous metals processing facilities that are area sources of HAP

. New facilitie s include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure co mpliance with 40 CFR part 63, subparts RRRRRR, SSSSSS, and TTTTTT

. In general, all NESHAP standards require initial notification report s, performance tests, and periodic reports b y 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 aff

ected facility , or any

period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office.
Over the next three ye ars , an average of 51 facilities per year for the Clay Ceramics Manufacturing area source category , 21 facilities per year for the Glass Manufacturing area source category , and 10 facilities per year for the Secondary Nonferrous Metals Processing area2

source category

will b e subject to the se standard s , and no additional respondents will become subject to the standard s
. Because the compliance date for each standard has passed, all existing facilities are expected to have complied with initial requirements. Clay ceramics m anufacturing facilities include facilities that manufacture pressed tile, sanitary ware, dinnerware, or pottery with an atomized glaze spray booth or kiln that f

ires glazed ceramic ware. Glass manufacturing facilities include facilities that manufacture fl at glass, glass containers, or pressed and blown glass b y melting a mixture of raw materials, to produce molten glass and form the molten glass into sheets, containers, or other shapes. Secondary nonferrous metals processing facilities means brass and bro nze ingot making, secondary magnesium processing, or secondary

zinc processing plant s that use furnace melting operations to melt post

consumer nonferrous metal scrap to make products including bars, ingots, blocks, or metal powders.
The Office of Management and Budget (OMB) approved the currentl y active Information Collection Request (I CR) without any ‘Terms of Clearance.”
The “Affected Public” are manufacturers, owners and operators of clay ceramics manufacturing, glass manufacturing, and secondary nonferrous metals processing facilities. The

“burden ” to the Affected Public may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing and Secondary Nonferrous Metals Processing Area Sources (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal). T he “burden ” to the Federal Government is attributed entirel y to work performed b y either F ederal employees or government contractor s
. This burden may be found below in Table 2: Ave rage Annual EPA Burden and Cost

– NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing and Secondary Nonferrous Metals Processing Area Sources (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (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, 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. Inaddition, 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 the3 Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impracti cal; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Admini strator may reasonabl y require. In the Administrator's judgment , HAP emissions from clay ceramics manufacturing, glass manufacturing, and secondary nonferrous metals processing area sources cause either or contribute to air pollution that may reasonabl y be anticipated to endanger public health and/ or welfare. Therefore, the NESHAP were promulgated for these source categories at 40 CFR part 63, subparts RRRRRR, SSSSS S , and TTTTTT. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standards ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard s. Continuous emission monitors are used to ensure compliance with the standard s at all times.
The notific ations required in the standard s are used to inform the A gency 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 properl y installed and operated and the standard s are bein g met. The performance test may also be observed.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping an d reporting are required under 40 CFR part 63, subparts RRRRRR, SSS S SS, and TTTTTT. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y 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, duplication does not exist.4

**3(b) P ublic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (78 FR 35023) on June 11, 2013

. No comments were received on the burden published in the Fed eral Register

. **3(c) Consultations** Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard s to make it easier to compl y. In developing this ICR, we contacted : 1) the Tile Council of North America (TCNA) , at (864) 646

- 8453 ( eastrachan@tileusa.com ) ; and 2) the Glass Manufacturing Industry Council (GMI C) , at (614) 818

- 9423 

### ( rwlipetz@gmic.org ). 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 firs t 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 emission limitations are met. I f the information required by these standards was collected less frequently , the proper operation and maintenance of control equipment , as well as the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 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

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five years allow s EPA to establish the compliance history of a source , any pattern of non - compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

.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 or recordkeeping requirements in the standard s 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 owners or operators of clay ceramics manufacturing, glass manufacturing, and secondary nonferrou s metals processing area sources. The United States Standard Industrial Classification (SI C) codes for the respondents affected, and their corresponding North American Industry Classification Sy stem (NAICS) codes, are found in the following table:

**Standard (40 CFR Part 63, Subpart** 

**RRRRRR) SIC Codes**  **NAICS Codes** Pottery , Ceramics, and Plumbing Fixture Manufacturing 3261, 3262, 3263, 326 4 , 32 6 9, 3299, 5719 32711 0 Clay Building Material and Refractories Manufacturing 3251, 3253, 3255, 3259, 3297 327120
**Standard (40 CFR Part 63, Subpart** 

**SSSSSS) SIC Codes**  **NAICS Codes** Flat Glass Manufacturing 3211 327211 Other Pressed and Blown Glass and Glassware Manufacturing 3229 327212 Glass Container Manufacturing 3221 327213 **Standard (40 CFR Part 63, Subpart** 

**TTTTTT) SIC Codes**  **NAICS Codes** Secondary

Smelting, Refining, and Alloying of Nonferrous Metal (except Copper and Aluminum) 3341, 3399 331492 Copper Rolling, Drawing, Extruding, and Alloying 3341, 3351, 3357, 3399 33142 06

**4(b) Information Requested**  **(i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing and Secondary Nonferrous Metals Processing Area Sources (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT)

. A source must make the following reports:

**Notification s**  **Standard (40 CFR Part 63, Subpart RRRRRR)** Notification of applicability Table 1 to subpart RRRRRR / 63.11442(a) Notification of construction/reconstruction 63.9(b)(5) Notification of special compliance requirements Table 1 to subpart RRRRRR Notification of performance test 63.9(e) Notification of opacity/VE observations 63.9(f) Additional CMS notifications 63.9(g) Notification of compliance status Table 1 to subpart RRRRRR / 63.11442(b) Notification of changes in information Table 1 to subpart RRRRRR **Standard (40 CFR Part 63, Subpart SSSSSS**  **)** Notification of applicability 63.11456(a) Notification of construction/reconstruction 63.9(b)(5) Notification of special compliance requirements 63.9(d) Notification of performance test 63.9(e) Notification of opacity/VE observations 63.9(f) Additional CMS notifications 63.9(g) Notification of compliance status 63.11456(b) Notification of changes in information 63.9(j) **Standard (40 CFR Part 63, Subpart TTTTTT**  **)** Notification of applicability Table 1 to subpart TTTTTT / 63.11469(a) Notification of construction/reconstruction 63.9(b)(5) Notification of special compliance requirements Table 1 to subpart TTTTTT Notification of performance test 63.9(e) Notification of opacity/VE observations 63.9(f) Additional CMS notifications 63.9(g) Notification of compliance status Table 1 to subpart TTTTTT /7

**Notification s**  63.11469(b) Notification of changes in information Table 1 to subpart TTTTTT **Reports Standard (40 CFR Part 63, Subpart RRRRRR)**  Reports of deviation NA Semiannual monitoring reports NA Initial/repeat performance tests 63.7(e)(1), 63.6(h)(7) Quality assurance test plan 63.7(c) CMS performance evaluation/report 63.8(e)(5) SSM reports 63.6(e)(3) Excess emissions reports 63.10(e)(3) **Standard (40 CFR Part 63, Subpart SSSSSS**  **)** Reports of deviation N/A Semiannual monitoring reports N/A Initial/repeat performance tests 63.7(e)(1) / 63.6(h)(7) Quality assurance test plan 63.7(c) CMS performance evaluation/report 63.8(e)(5) SSM reports 63.6(e)(3) Excess emissions reports 63.10(e)(3) **Standard (40 CFR Part 63, Subpart TTTTTT**  **)** Reports of deviation NA Semiannual monitoring reports NA Initial/repeat performance tests 63.7(e)(1), 63.6(h)(7) Quality assurance test plan 63.7(c) CMS performance evaluation/report 63.8(e)(5) SSM reports 63.6(e)(3) Excess emissions reports 63.10(e)(3)
A source must keep the following records : **Recordkeeping Standard (40 CFR Part 63, Subpart RRRRRR)**  Records of notifications Table 1 to subpart RRRRRR / 63.11443(a)(1) Monitoring/inspection information Table 1 to subpart RRRRRR / 63.11443(a)(2) Monitoring: Kiln peak temperature 63.11440(a)8 **Recordkeeping** Monitoring: APCD parameter check 63.11440(b)(1) (new sources) Monitoring: Visible emissions test 63.11440(b)(2) (new sources) Monitoring: APCD inspection 63.11440(c)(1) (existing sources) Monitoring: Alternative monitoring technique Table 1 to subpart RRRRRR / 63.11440(b)(3) (new sources), 63.11440(c)(2) (existing sources) SSM plan 63.6(e)(3) Performance test plan 63.7(c)(2) CMS quality

control plan 63.8(d) CMS performance evaluation test plan 63.8(e)(3) **Standard (40 CFR Part 63, Subpart SSSSSS**  **)** Records of notifications 63.11457(a)(1) Records of startups, shutdowns and malfunctions 63.10 Records that demonstrate continuous compliance 63.11457(a)(3) Records of glass production 63.11457(a)(4) Monitoring/inspection information 63.11457(a)(5

- 8), 63.11457(c) Monitoring: Furnace ESP secondary voltage and current 63.11454(b) (existing sources),

63.11454(d) (new sources) Monitoring: Furnace fabric filter inlet temperature 63.11454(c) (existing sources), 63.11454(e) (new sources) SSM plan 63.6(e)(3) Performance test plan 63.7(c)(2) CMS quality

control plan 63.8(d) CMS performance evaluation test plan 63.8(e)(3) **Standard (40 CFR Part 63, Subpart TTTTTT**  **)** Records of notifications Table 1 to subpart TTTTTT / 63.11470(a)(1) Monitoring/inspection information Table 1 to subpart TTTTTT / 63.11470(a)(2) Monitoring: Visual inspection of capture device 63.11466(a) Monitoring: Visible emissions check 63.11466(b) (existing sources) Monitoring: Visual bag inspection 63.11466(b) (existing sources) Moni toring: Bag leak detection sy stem 63.11466(c) (new sources) SSM plan 63.6(e)(3) Performance test plan 63.7(c)(2) CMS quality

control plan 63.8(d) CMS performance evaluation test plan 63.8(e)(3)9

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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities** 

**Respondent Activities** Read instructions. Perform initial performance test, Reference EPA Method 1 or 1A; 2, 2A, 2C, 2F, or 2G; 3, 3A, or 3B; 4; 5 or 17; 22 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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 monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping.10

**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, analy sis, storage, and distribution of the required information :

**Agency Activities** Review notifications and reports, including performance test reports, initial notification of applicability , and notification of compliance status. Audit facility

records. Attend performance tests. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of any startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and oper ated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to co mpl y with the emission standard s and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collectio n, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility**
The Small Business Admin istration defines a small entity as a firm having no more than 500 to 750 employees for Clay Ceramics Manufacturing, less than 750 to 1,000 employees for Glass Manufacturing, and less than 750 employees for Secondary Nonferrous Metals Processing depending on the size definition for the affected NAI CS code. There will not be adverse impacts11

on any small entities in the Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing area source categories. The final Clay Ceramic s Manufacturing rule does not create any new requirements or burdens for existing sources other than minimal notification requirements. The final Glass Manufacturing rule will require additional costs for 21 glass manufacturing facilities, but only three of those facilities will be expected to install control devices and incur costs beyond those associated with annual inspections of control devices; only

one of these facilities is a small business. The final Secondary Nonferrous Metals Processing rule doe s not create any new requirements or burdens for existing sources , other than minimal notification requirements. 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. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. The overall burden will be reduced to the extent that larger businesses can use economies of scale to reduce their burden

. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing and Secondary Nonferrous Metals Processing Area Sources (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal). **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicab le to the industry for each of the subparts included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Re duction Act. Where ver 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 requirement s is estimated to be 1,763 hours (To tal Labor Hours from Table 1 below). Glass manufacturing is expect to contribute the entire burden while the other two industries are not expected to experience any additional burden from the current requirements. These hours are based on Agency studies and background documents from the development of12

the regulation, Agency

knowledge and experience with the NESHAP program, the previousl yapproved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR u ses the following labor rates: Managerial $1 2 3

. 04 ($5 8

. 59 + 110%) Technical $ 10 1

. 2 2 ($4 8

. 2 0 + 110%) Clerical $ 5 1

. 18 ($2 4

. 37 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** 
For both clay

ceramics manufacturing and secondary nonferrous metals processing, the only costs to the regulated industry that result from information collection activities , required b y the subject stand ards , are labor costs. There are no capital/startup or operation and maintenance costs. For glass manufacturing, the ty pe of industry

costs associated with the information collection activities in the subject standards are both labor costs , which are a ddressed elsewhere in this I CR , and the costs associated with continuous monitoring. The capital/startup costs are a one - time cost when a facility becomes subject to the regulation s . The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**
For both clay

ceramics manufacturing and secondary nonferrous metals processing, the only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs. For glass manufacturing, the capital/startup and operation and maintenance costs are summarized in the follo wing table:13 **Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent b (C)

Number of New Respondents (D)

Total Capital/ Startup Cost a (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)

Performance Tests $8,740 0 $0 NA NA Monitoring Equipment $5,603 0 $0 NA NA File Cabinets $235 0 $0 NA NA Other O&M c

- - - - 14 $9,854 Total $0 $ 9,854

a No new sources are expected and all existing sources have fully implemented capital costs to comply with the current standards. Therefore, no additional capital/start

- up costs are expected. b Annualized capital costs are $2,130 per performance test, $800 per monitoring equipment, and $26 per file cabinet. C osts 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). Performance tests: 5 y r life, 7% interest; CRF =0.2439 ; Monitoring equipment: 10 yr life, 7% interest; CRF =0.1424 ; File cabinets: 15 yr life, 7% interest; CRF =0.1098
c Costs of annual inspections of emission control systems, assuming 8 hr per inspection for each of the 14 affected f urnaces with a control device. There are no capital/startup costs for the three years covered b y this I CR. The total operation and maintenance (O&M) costs for this I CR are $ 9,854

. This is the total of column G. These costs are attributed to the glass manufacturing sector only (subpart SSSSSS). The average annual cost s for both capital/startup and operation and maintenance to the industry over the next three years of th is ICR is estimated to be $ 9,85 4

. These are the recordkeeping costs

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as th e examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 1,329

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% )14 Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% )
These rates are from the Office of Personnel Management (OPM) , 20 1 3 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing and Secondary Nonferrous Metals Processing Area Sources (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal). **6(d) Estimating th e Respondent Universe and Total Burden and Costs**  Based on our research for this I CR, on average over the next three ye ars, approximately : 51 existing respondents will be subject to the clay ceramics manufacturing area source standard; 21 existing respondents will be subject to the glass manufacturing area source standard; and 10 existing respondents will be subject to the secondary nonferrous metals processing area source standard. It is estimated that no additional respondents will become subject to the se standards. The overall average number of respondents, as shown in the table below, is : 51 for clay ceramics manufacturing area sources, 21 for glass manufacturing area sources, and 10 for secondary nonferrous metals processing area sources.
The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR : **Number of Respondents**

**( Clay Ceramics Manufacturing Area Sources**  **, Subpart RRRRRR)** Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D)

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

Number of Respondents (E=A+B+C

- D)
1 0 51 0 0 51 2 0 51 0 0 51 3 0 51 0 0 51 Average 0 51 0 0 51 1 New respondent include sources with constructed, reconstructed, and modified affected facilities. **Number of Respondents (**  **Glass Manufacturing Area Sources , Subpart SSSSSS)**  Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D)

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

Number of Respondents (E=A+B+C

- D)
1 0 21 0 0 21 2 0 21 0 0 21 3 0 21 0 0 21 Average 0 21 0 0 21 1 New respondent include sources with constructed, reconstructed, and modified affected facilities.15
**Number of Respondents (**  **Secondary Nonferrous Metals Processing Area Sources , Subpart TTTTTT)**  Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D)

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

Number of Respondents (E=A+B+C

- D)
1 0 10 0 0 10 2 0 10 0 0 10 3 0 10 0 0 10 Average 0 10 0 0 10 1 New respondent include sources with constructed, reconstructed and modified affected facilities. Column D is subtracted to avoid double

- counting respondents. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is : 51 for clay ceramic manufacturing area sources ; 21 for glass manufacturing area sources ; and 10 for secondary nonferrous metals processing area sources. The total number of annual responses per ye ar is calculated using the following tables:
**Total Annual Responses (**  **Clay Ceram ics Manufacturing Area Sources**  **, Subpart RRRRRR)** (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 Keeps records 0 0 n/a 1 0 **Total 0**  1 No responses are required for this activ ity after the first three years **Total Annual Responses (**  **Glass Manufacturing Area Sources , Subpart SSSSSS)**  (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 Keeps records 0 0 14 14 **Total 14** 

**Total Annual Responses (**  **Secondary Nonferrous Metals Processing Area Sources**  **, Subpart TTTTTT)**16 **Total Annual Responses (**  **Secondary Nonferrous Metals Processing Area Sources**  **, Subpart TTTTTT)** (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 Keeps records 0 0 n/a 1 0 **Total 0**  1 No responses are required for this activ ity after the first three years The number of Total Annual Responses is 14 and is attributable to glass manufacturing area sources exclusively . No responses are required from ceramics manufacturing and nonferrous metals manufacturing area sources.
The total annual labor costs are $172,447. All labor costs for this I CR are attributable to impact on the glass manufacturing area sources. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTT T) (Renewal)

. **6(e) Bottom Line Burden Hours 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 below , respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 1,763 at a cost of $172,447

. Details regarding these estimates m ay

be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 126 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $ 9,854

. 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 18 labor hours , at a cost of $1,329. See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Clay

Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous17

Metals Processing (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal)

. **6(f) Reasons for Change in Burden** There is no change in the labor hours in this I CR 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 ye ars ; and 2) the growth rate for the industry is non

existent, so there is no significant change in the overall burden. However, there is an adjustment increase in the respondent burden cost due to an update in labor rates. There is also an adjustment decrease in the total O&M costs due to a correction. The previous I CR i ncluded the annualized capital costs of initial performance tests and equipment as O&M costs. This I CR corrects the O&M costs to only include ongoing costs in order to maintain the monitors. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 126 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or discl ose or provide information either to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, proce ssing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 Co ntrol Number. The OMB Control Numbers for EPA 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 re spondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2013

- 0355. 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 sy stem , 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), WJC 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the te lephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,18

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 20 13

- 0355 and OMB Control Number 2060

- 0606 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.19

**Table 1: Annual Respondent Burden and Cost**

**– NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing, and**  **Secondary Nonferrous Metals Processing (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal)** 

**Burden Item (A)**  **Respondent Hours per**  **Occurrence (B)** 

**Number of Occurrences**  **per Respondent**  **per Year**

**(C) Hours per**  **Respondent per Year**  **( C=A x B)**  **(D)**

**Number of Respondents**  **per Year**

**(E) Technical**  **Hours per Year**  **(E=C x D) (F)** 

**Managem ent**  **Hours per Year**  **(F= E x 0.05) (G)** 

**Clerical Hours per**  **Year (G= E x 0.1)**  **(H)**

**Total Labor Costs per**  **Year a** 
1. Applications N/A 2. Surveys and Studies N/A 3. Acquis ition, i nstall ation, and util ization of technology and s ystems N/A 4. Reporting Requirements A. Read instructions b 2 1 2 0 0 0 0 $0 B. Required activities Initial notification of applicability c 2 1 2 0 0 0 0 $0 Notification of compliance status d 4 1 4 0 0 0 0 $0 C. Create information See 4B D. Gather existing information See 4B E. Write report See 4B **Subtotal for Reporting Requirements 0**  **$0** 5. Recordkeeping Requirements A. Read instructions e 2 1 2 0 $0 B. Plan activities See 5E C. Implement activities See 5E D. Record data f, i 0.1 1,095 109.5 14 1,533 76.7 153.3 $172,447.17 E. Time to transmit or disclose information g, i 0.25 3.3 0.8 0 0 0 0 $0 F. Time to train personnel h, i 12 1 12 0 0 0 0 $0 G. Time for audits i N/A **Subtotal for Recordkeeping Requirements 1,763**  **$172,447 TOTAL LABOR BURDEN AND COST**  **(rounded) 1,763**  **$172,447**
**Assu mptions:** 
a This ICR uses the following labor rates: $123.04 for managerial labor, $101.22 for technical labor, and $51.18 for clerical l abor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, “Table 2. Civilian Worke rs, by Occupational and Industry group.” The rates are20

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. b There are an estimated 21 exi sting glass manufacturing facilities, 51 clay manufacturing facilities, and 10 secondary nonferrous metals processing facilities that use HAP metals. Only new facilities are expected to read instructions and no new facilities are expected in either industry. c After full implementation, existing facilities are not longer required to submit an Initial Notification. d After full implementation, existing facilities are not longer required to submit Notifications of Compliance Status.
e After full implementation, existing facilities are not longer required to keep records of the notifications or to read instructions

. f We estimate 21 glass manufacturing facilities with 27 affected furnaces. It is assumed that 13 of the 27 affected furnaces can meet the emission limit without installation of a control device. It is assumed that each of the remaining 14 affected furnaces have automatic monitoring an d recording systems. g Since Initial Notification and Notifications of Compliance Status are not expected for existing facilities after full implementation, transmittal of these items is not expected. h After full implementation, training is not expected to occur at existing facilities. i Because the data are already collected by respondents as required by the existing permit requirements, no costs or burden are associated with these information collection activities for clay ceramics manufacturing and secondary nonferrous metals processing.21

**Table 2: Average Annual EPA Burden and Cost**

**– NESHAP for**  **Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing (40 CFR**  **Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal)**

**Burden Item (A)**  **EPA Hours per**  **Occurrence (B)** 

**Number of Occurrences**  **per Plant**  **per Year (C)** 

**EPA Hours per Year**  **(C=A x B) (D)** 

**Plants per Year**  **(E)**

**Technical Hours per Year**  **(E=C x D) (F)** 

**Managem ent**  **Hours per Year (F= E x 0.05)**  **(G)**

**Clerical Hours per Year**  **(G= E x 0.1) (H**  **)**

**Costs per Year**  **a**
Attend performance test b 16 1 16 1 16 0.8 1.6 $829 .20 Report review: Initial notification of applicability c 2 1 2 0 0 0 0 $0 Notification of performance test d Notification of compliance status e 4 1 4 0 0 0 0 $0 Travel expenses for tests attended f $500 **TOTAL ANNUAL BURDEN (rounded)**  **18 $1,329** 
**Assu mptions:** 
a This ICR uses the following average hourly labor rates: $62.27 for managerial (GS

- 13, Step 5, $38.92×1.6), $46.21 (GS

- 12, Step 1, $28.88×1.6) for technical and $25.01 (GS

- 6, Step 3, $15.63×1.6) for clerical. These rates are from the Office of Personnel Manage ment (OPM), 2013 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to governme nt employees. b Assumes Agency personnel will attend the performance test for on e affected source per year. This only applies for glass manufacturing area sources.
c After full implementation, existing facilities are not required to submit Initial Notifications.. d Not required
e After full implementation, existing facilities are not required to submit Notifications of Compliance Status. f Assumes Agency personnel (1 person) will spend 2 days per plant, at $50 per diem per day, and $400 transportation expense per round trip to attend performance tests.