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 

Nonferrous Metals Processing Area Sources (40 CFR Part 63, Subparts RRRRRR, SSSSSS, 

and TTTTTT) (Renewal), EPA ICR Number 2274.04, OMB Control Number 2060-0606

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Clay

Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing 

Area Sources (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 rate 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 facilities include 

those that commenced construction or reconstruction after the date of proposal. This information 

is being collected to assure compliance with 40 CFR part 63, subparts RRRRRR, SSSSSS, and 

TTTTTT.

In general, all NESHAP standards require initial notification reports, performance tests, 

and periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

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 U. S.

Environmental Protection Agency (EPA) regional office.

Over the next three years, 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 area 
2

source category will be subject to these standards, and no additional respondents will become 

subject to the standards. Because the compliance date for each standard has passed, all existing 

facilities are expected to have complied with initial requirements. 

Clay ceramics manufacturing facilities include facilities that manufacture pressed tile, 

sanitaryware, dinnerware, or pottery with an atomized glaze spray booth or kiln that fires glazed 

ceramic ware. Glass manufacturing facilities include facilities that manufacture flat glass, glass 

containers, or pressed and blown glass by 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 bronze ingot making, secondary magnesium 

processing, or secondary zinc processing plants that use furnace melting operations to melt postconsumer nonferrous metal scrap to make products including bars, ingots, blocks, or metal 

powders. 

The Office of Management and Budget (OMB) approved the currently active Information 

Collection Request (ICR) 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). The “burden” to the Federal Government is attributed entirely to work 

performed by either Federal employees or government contractors. This burden may be found 

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).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 
3

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, 

glass manufacturing, and secondary nonferrous metals processing area sources cause either 

or contribute to air pollution that may reasonably 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, SSSSSS, 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 standards. Continuous emission monitors are used to 

ensure compliance with the standards at all times.

The notifications required in the standards 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 and 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, subparts 

RRRRRR, SSSSSS, and TTTTTT.

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, 

duplication does not exist.
4

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 (78 FR 35023) on June 11, 2013. No comments were received on the 

burden published in the Federal 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 standards to make it easier to comply. 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 (GMIC), 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 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 emission limitations are met. If 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 by 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-year records retention requirement is consistent with

the Part 70 permit program and the five-year statute of limitations on which the permit program 

is based. The retention of records for five years allows 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 

years. 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 standards 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 nonferrous metals 

processing area sources. The United States Standard Industrial Classification (SIC) codes for the 

respondents affected, and their corresponding North American Industry Classification System 

(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, 3264, 

3269, 3299, 5719 327110

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 331420
6

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by 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: 

Notifications

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

Notifications

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)

Monitoring: Bag leak detection system 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 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 are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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 

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 monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system). Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

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, analysis, 

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, analyze, and maintain data in the Online Tracking Information System (OTIS). 

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 properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standards 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.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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

The Small Business Administration 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 NAICS code. There will not be adverse impacts 
11

on any small entities in the Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary

Nonferrous Metals Processing area source categories. The final Clay Ceramics 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 does 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 types 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 applicable to the industry for each of the subparts 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. Wherever appropriate, specific tasks 

and major assumptions have been identified. Responses to this information collection are 

mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 1,763 hours (Total 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 of 
12

the regulation, Agency knowledge and experience with the NESHAP program, the previouslyapproved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 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 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

For both clay ceramics manufacturing and secondary nonferrous metals processing, the 

only costs to the regulated industry that result from information collection activities, required by 

the subject standards, are labor costs. There are no capital/startup or operation and maintenance 

costs. 

For glass manufacturing, the type of industry costs associated with the information 

collection activities in the subject standards are both labor costs, which are addressed elsewhere 

in this ICR, and the costs associated with continuous monitoring. The capital/startup costs are a 

one-time cost when a facility becomes subject to the regulations. 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 following 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. 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). Performance tests: 5 yr 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 furnaces with a 

control device.

There are no capital/startup costs for the three years covered by this ICR. 

The total operation and maintenance (O&M) costs for this ICR 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 costs for both capital/startup and operation and maintenance to the 

industry over the next three years of this ICR is estimated to be $9,854. These are the 

recordkeeping costs.

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 

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 hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)
14

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (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 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 the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, 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 these 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 

years covered by this ICR: 

Number of Respondents 

(Clay Ceramics Manufacturing Area Sources, Subpart RRRRRR)

Year (A)

Number of New 

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 New 

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 New 

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-year 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 year is calculated using the following tables:

Total Annual Responses 

(Clay Ceramics 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 10

Total 0

1 No responses are required for this activity 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 10

Total 0

1 No responses are required for this activity 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 ICR 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 TTTTTT) (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 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 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 Nonferrous 
17

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 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 the industry is nonexistent, 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 ICR included the

annualized capital costs of initial performance tests and equipment as O&M costs. This ICR 

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 by persons to generate, maintain, retain, or disclose 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 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 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-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 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), 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 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information 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-2013-0355 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) 

Management 

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. Acquisition, installation, and utilization of 

technology and systems

N/A

4. Reporting Requirements

A. Read instructions b2 1 2 0 0 0 0 $0 

B. Required activities

Initial notification of applicability c2 1 2 0 0 0 0 $0

Notification of compliance status d4 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 e2 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, i0.25 3.3 0.8 0 0 0 0 $0 

F. Time to train personnel h, i12 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 

Assumptions:

a

 This ICR uses the following labor rates: $123.04 for managerial labor, $101.22 for technical labor, and $51.18 for clerical labor. 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 
20

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 existing 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 and 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) 

Management 

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 b16 1 16 1 16 0.8 1.6 $829.20

Report review:

Initial notification of applicability c2 1 2 0 0 0 0 $0

Notification of performance test d

Notification of compliance status e4 1 4 0 0 0 0 $0

Travel expenses for tests attended f

$500

TOTAL ANNUAL BURDEN (rounded) 18 $1,329 

Assumptions:

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 Management (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 government employees.

b

 Assumes Agency personnel will attend the performance test for one 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.