SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing

, and Secondary

Nonferrous Metals Processing Area Sources (40 CFR Part 63, Subpart s RRR R RR,

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, Subpart RRRRRR, SSSSSS and TTTTTT )

(Renewal), EPA ICR Number 2274.05 , OMB Control Number 2060

- 0606

.

1(b) Short Characterization/Abstract

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

Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing

Area Sources ( 40 CFR Part 63, Su bparts RRRRR, SSSSSS and TTTTTT ) were proposed on

September 20, 2007

, and promulgated on December 26, 2007

. These regulations apply to the

following existing and new facilities : 1) clay ceramics manufacturing facilities that process 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, modification or reconstruction after the date of proposal. This

information is being collected to assure compliance with 40 CFR Part 63

, Subpart s RRRRRR,

SSS SSS and TTTTTT

.

Clay ceramics manufactur ing 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 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 plant s that use furnace melting operations to melt post

consumer nonferrous metal scrap to make products including bars, ingots, blocks, or metal

powders.

In general, all NESHAP standards require initial notification report s, 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

.2

Any owner/operator subject to the provisions of this part shall maintain a file containing

the se documents , and retain the file for at least five years following the generation date of such

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.

The “Affected Public” are owners and operators of clay ceramics manufacturing

facilities, glass manufacturing facilities and secondary nonferrous metals processi ng facilities.

None of the facilities in the United States are owned by either state, local, tribal or the Federal

government. They are all owned and operated by privately

- owned, for

- profit businesses. We

assume that they will all respond to EPA’s regulati ons

. 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 F ederal employees

or government contractors. The Federal Government ’s 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, SSSS SS, and TTTTTT) (Renewal).

Based on our consultations with industry representatives, there is an average of one affected facility at each clay ceramics and secondary non

- ferrous metals processing plant site and

1.3 affected facilities at each glass manuf acturing plant site and that each plant site has only one

respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 51 clay ceramics manufacturing facilities,

21 glass manufacturing facilities and 10 secondary nonferrous metals processing per year will

be subject to the se standard s , and no additional respondents per year will become subject to the se

same standard s

. Because the compliance date for each standard has passed, all existing facilities

are expected to have complied with initial requirements.

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

without any “ Terms of Clearance ”

.

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:3

(A) Establish and maintain such records; (B) ma ke 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 i n such manner as the

Administrator shall prescribe); (E) keep records on control

equipment parameters, production variables or other indirect data

when direct monitoring of emissions is impractical; (F) submit

compliance certifications in accordance with S ection 114(a)(3);

and (G) provide such other information as the Admini strator may

reasonably require.

In the Administrator's judgment

, HAP emissions from clay ceramics manufacturing, glass

manufacturing, and secondary nonferrous metals processing area sou rces either cause or

contribute to air pollution that may reasonably be anticipated to endanger public health and/ or

welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63,

Subpart s RRRRRR, SSSSSS and TTTTTT

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard s ensure compliance with

the applicable regulations which were promulgated in accordance with the Clean Air Act. The

collected information is also used for tar geting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility ’ s initial

capability to co mply with the emission standard s. Continuous emission monitors are used to

ensu re compliance with the se standard s at all times . During the performance test a record of the

operating parameters under which compliance was achieved may be recorded and used to

determine compliance in place of a continuous emission monitor.

The notific ations required in th e se standard s 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 an d operated, leaks are being detected and repaired and the se standards are being 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, Subpart s

RRRRRR, SSSSSS and TTTTTT

.

3(a) Non

- duplication

If the subject standards have not been delegated, the information is sent directly to the4

appropriate EPA regional office. Otherwise, the information is sent directly to the delega ted 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 t he Federal standards. Therefore, duplication does

not exist.

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 ( 80 FR 32116 ) on June 5, 2015

. No comments were received on the

burden published in the Federal Register

.

3(c) Consultations

The Agency has consulted i ndustry experts and internal data sources to project the

number of affected facilities and industry growth over the next three years. The primary source

of information as reported by industry, in compliance with the recordkeeping and reporting

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial

and government

- owned facilities. The growth rate for the industry is based on our consultations

with the Agen cy’s internal industry experts.

I ndustry trade association(s) and other interested parties were provided an opportunity to

comment on the burden associated with the standard as it was being developed and the se

standard s ha ve been reviewed previously to determine the minimum information needed for

compliance purposes. In developing this ICR, we contac ted : 1) Tile Council of North America

(TCNA), at (864) 646

- 8453 ( eastrachan@tileusa.com ) ; and 2) 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 f irst Federal Register n otice. (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 se standards. Requirements for information gathering and

recordkeeping are useful techniques to ensure that good oper ation 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 and the

possibility of detecting violation s would be less likely.5

3(e) General Guidelines

T hese 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. T he 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 enfor cement

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

.

3(f) Confidentiality

A ny 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 F R 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

T he reporting or recordkeeping requirements in the standard do not include sensitive

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are 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 P art 6 3

, S ubpart RRRRRR ) SIC Codes NAICS Codes

Pottery, Ceramics, and Plumbing Fixture

Manufacturing 3261, 3262, 3263,

3264, 3269,3299,5719 327110

Clay Building Material and Refectories

Manufacturing 3251, 3253, 3255,

3259, 3297 3271206

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

4(b) Information Requested

(i) Data Items

I n 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 mak e the following reports:

Notification s

Standard (40 CFR Part 63, Subpart RRRRRR)

Initial notification 63.11441(a), 63.9(b)(2)

Notification of applicability 63.9( a)

Notification of construction/reconstruction 63.9(b)(5)

Notification of special compliance requirements 63.9(d)

Notification of compliance status 63.1144 1 (b) , 63.9(h)

Notification of changes in information 63.9(j)

Request for extension of compliance 6 3.9(c)

Standard (40 CFR Part 63, Subpart SSSSSS )

Initial notification 63.11456(a), 63.9(b)

Notification of applicability 63.9(a)

Notification of construction/reconstruction 63.9(b)(5)

Notification of special compliance requirements 63.9(d)

Notification of compliance status 63.11456(b) , 63.9(h)

Notification of changes in information 63.9(j)7

Notification s

Request for extension of compliance 63.9(c)

Standard (40 CFR Part 63, Subpart TTTTTT)

Initial notification 63.11469(a), 63.9(b)(2)

Notification of applicability 63.9(a)

Notification of construction/reconstruction 63.9(b)(5)

Notification of special compliance requirements 63.9(d)

Notification of compliance status 63.11469(b) , 63.9(h)

Notification of changes in information 63.9(j)

Request for extension of compliance 6 3.9(c)

Reports

Standard (40 CFR Part 63, Subpart RRRRRR)

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)

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)

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 63.1144 2 (a)(1)

Records of measurements needed to document compliance 63.11442(a)(2)

Monitoring/inspection information 63.1144 0 ( d)8

Recordkeeping

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 (b)(2)

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)

C MS quality control plan 63.8(d)

CMS performance evaluation test plan 63.8(e)(3)

All required CMS measurements 6.10(c)(1)

Periods of excess emissions 6.10(c)(7),(8)

Standard (40 CFR Part 63, Subpart TTTTTT)

Records of notifications 63.11470(a)(1)

Monitoring/inspection information 63.11470(a)(2)

Monitoring: Visual inspection of capture device 63.1146 8 (a) (1)(i)

(existing sources)

Monitoring: Visible emissions check 63.1146 8 ( a ) (2)

(existing sources)

Monitoring: Visual bag inspection 63.1146 8(a ) (1)(ii)

(existing sources)

Monitoring: Bag leak detection system 63.1146 8 (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 r espondents 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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid

supply pressure for control device.

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 re quired 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 informat ion.

Transmit, or otherwise disclose the information.

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 :10

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions

reports, required to be submitted by industry.

Audit facility records.

Attend performance tests.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO)

and ICIS.

5(b) Collection Methodology and Management

Following notification of 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 com ply 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.

Information contained in the reports is reported by state and local governments in the

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is

EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial

and government

- owned facilities. EPA uses ICIS 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 regul ation 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.

There will not be adverse impacts on any small entities in the Clay Ceramics Manufacturing,

Glass Manufacturing, and Secondary Nonferrous Metals Pr oc essing 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 require s 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 f acilities is a small business. The fin al

Secondary Nonferrous Metals Processing rule does not create any new requirements or burdens11

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 rep orting 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. To the extent that larger businesses ca n use economies of scale to reduce their burden,

the overall burde n will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is

shown below in Table 1: Annual 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. Where 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

a nd reporting requirement s is estimated to be 1, 81 0 ( Total Labor Hours from Table 1). T hese

hours are based on Agency studies and background documen ts from the development of the

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $1 38.43 ($ 65.92 + 110%)12

Technical $ 10 6.45 ($4 50.69 + 110%)

Clerical $ 52.77 ($2 5.13 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics,

September 2015

, “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are

from column 1, “ Total compensation. ” The rates have been increase d 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 clay ceramics manufacturing area sources and secondary nonferrous metals

processing area sources , t here are no capital/startup or operation and maintenance costs.

For glass manufacturing area sources

, the type of industry costs associated with the

information collection act ivities in the subjec t standards are both labor costs which are addressed

elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup

costs are one

- time costs when a facility becomes subject to the regulation. The annual operation

and mainten ance costs are the ongoing costs to maintain the monitor(s) and other costs su ch as

photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

For both clay ceramics manufacturing facilities and secondary nonferrous metals

processing facilities , 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 an d 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 a (C)

Number of

New

Respondents (D)

Total

Capital/Startu

p Cost b

(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 $0 0 $0

Monitoring

Equipment $5,603 0 $0 $0 0 $0

File Cabinets $235 0 $0 $0 0 $0

Inspection of

Emission Control

Systems c $0 0 $0 $703.86 14 $9,854

Total d $0 $9,850

a 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)x(1+i) t /((1+i) t

- 1), where i = interest r ate

(%) and t = equipment life (years). Performance tests: 5 yr life, 7% interest; CFR = 0.02439; Monitoring equipment: 10 yr lif e,

7% interest; CFR = 0.1424; File Cabinets: 15 yr life, 7% interest; CFR = 0.1098

b No new sources are expected and all existing sources have fully implemented capital costs to comply with thte current

standards. Therefore, no additional capital/start

- up costs are expected.

c We estimate 21 glass manufacturing facilities with 27 affected furnaces. It is assumes that 13 of the 27 furnaces can meet the

emission limit without installation of a control device. It is assumes that each of the remaining 14 affected furnaces have

automotive monitoring and recording systems. We a ssumes annual insp ections of emission control systems, 8 hr per inspection

for each of the 14 affected furnaces with a control device.

d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $ 0

. This is the total o f column D in the

above table.

The total operation and maintenance ( O&M) costs for this ICR are $ 9,850

. This is the

total of column G.

The average annual cost for capital/startup and operation and maintenance costs to

industry over the next three years of the ICR is estimated to be $ 9,850

. These are 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 overal l compliance and enforcement program i ncludes activities such as the

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 Agen cy cost during the three years of the ICR is estimated to be

$ 1,3 5 0

.14

This cost is based on the average hourly labor rate as follows:

Managerial $ 6 4.16 (GS

- 13, Step 5, $ 40.10 + 60% )

Technical $ 4 7.62 (GS

- 12, Step 1, $ 2 9

. 76 + 60% )

Clerical $2 5. 76 (GS

- 6, Step 3, $ 1 6.10 + 60% )

These rates are from the Office of Personnel Management (OPM)

, 20 1 6 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 thre e 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 per year will become subject. The overall

average number of responden ts, as shown in the table below, is 82 per year ( 51 for clay ceramics

manuf acturing 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.

Numb er of Respondents

Respondents That Submit Reports Respondents That Do

Not Submit Any Reports

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)

Clay Ceramics Manufacturing Area Sources (Subpart RRRRRR)

1 0 51 0 0 51

2 0 51 0 0 51

3 0 51 0 0 51

Average 0 51 0 0 51

Glass Manufacturing Area Sources (Subpart SSSSSS)

1 0 21 0 0 2115

Numb er of Respondents

2 0 21 0 0 21

3 0 21 0 0 21

Average 0 21 0 0 21

Secondary Nonferrous Metals Processing Area Sources (Subpart TTTTTT)

1 0 10 0 0 10

2 0 10 0 0 10

3 0 10 0 0 10

Average 0 10 0 0 10

Average

Total 0 82 0 0 82

1 New respondents include sources with constructed, reconstructed and modified affected facilities.

C olumn 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 82 ( 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 table:

Total Annual Responses

(A)

Information Collection Activity (B)

Number of

Respondents (C)

Number of

Responses (D)

Number of Existing

Respondents That

Keep Records But Do

Not Submit Reports (E)

Total Annual Responses

E=(BxC)+D

Clay Ceramics Manufacturing Area Sources (Subpart RRRRRR)

Keeps Records 0 0 N/A 1 0

Total 0

Glass Manufacturing Area Sources (Subpart SSSSSS)

Keeps Records 0 0 14 2 14

Total 14

Secondary Nonferrous Metals Processing Area Sources (Subpart TTTTTT)

Keeps Records 0 0 N/A 1 0

Total 0

Total Responses for

All Area Sources 14

1 No responses are required for this activ ity after the first three years

2 We estimate 21 glass manufacturing facilities with 27 affected furnaces. Of these, 14 furnaces have automatic

monitoring and recording systems.16

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 $ 187 ,000

. 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 below in Tables 1 and 2

, respectively , and summarized below.

(i) Respondent Tally

The total annual labor hours are 1, 81 0

. Details regarding these estimates may be found 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)

.

We assume that burdens for managerial tasks take 5 % of the time required for technical

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens

are assumed to take 10% of the time required for technical tasks because the typical duties of

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of

information is estimated to average 1 2 9 hours per response

.

The total annual capital/startup and O&M costs t o the regulated entity are $9,850

. 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 $ 1,3 5 0

. See below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Non ferrous

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

.

We assume that burdens for managerial tasks take 5% of the time required for technical

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens

are assumed to take 10% of the time required for technical tasks because the typical duties of

clerical staff are to proofread the reports, make copies and maintain records.17

6(f) Reasons for Change in Burden

There is an adjustmen t increase in respondent labor hours and costs in this ICR from the

most recently approved ICR. This is not due to any program change s . The increase occurred

because this ICR assumes all existing respondents will take some time each year to re

- familiarize

with the regulatory requirements. Additionally, there is a small decrease of $4 in the estimated

O&M cost due to rounding. This ICR rounds all calculated burden and costs to three significant

digits. There is no change in the methodology or assumptions use d to calculate the O&M cost.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 1 2 9 hours per response

. “ Burden ” means the total time, effort, or

financial resources expended by persons to generate, maintain, retain, or disclose or provide

information to or for a Federal agency. This includes the time needed to review instructions;

develop, acquire, install, and uti lize 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

instructi ons 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 n either conduct n or spons or, 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 t his 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 informat ion, 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 identif ied

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 Cen ter 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 i s (202) 566

- 17 52

. Also, you can send comments to the Office of

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,

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

Number EPA

- HQ

- OECA

- 2013

- 0355 and OMB Control Number 2060

- 0606 in any

correspondence.18

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=AxB) (D)

Number of

Respondents

per Year

(E)

Technical

Hours

per Year

(E=CxD) (F)

Management

Hour s per

Year

(F=Ex0.05) (G)

Clerical

Hours per

Year

(G=Ex0.1) (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. Familiarize with regulatory

requirements b 2 1 2 21 42 2.1 4.2 $4,983.24

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 48 $4,983

5. Recordkeeping Requirements

A. Familiarize with regulatory

requirements e See 4A

B. Plan activities See 5E

C. Implement activities See 5E20

D. Record data f, i 0.1 1,095 109.5 14 1,533 76.65 153.3 $181,888.15

E. Time to transmit or disclose

information g, i 0.25 3.3 0.83 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 $181,888

TOTAL LABOR BURDEN

AND COST (rounded) j 1, 810 $187,000

TOTAL CAPITAL AND O&M

COST (rounded) j $9,850

GRAND TOTAL (rounded) j $ 197 ,000

Assumptions:

a This ICR uses the following labor rates: $138.43 for managerial labor, $106.45 for technical labor, and $52.77 for clerical labor. These rates are from the

United States Department of Labor, Bureau of Labor Statistics, September 2015, “Table 2. Civilian Worke rs, 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 availa ble to those employed by private

industry.

b There are an estimated 21 exi sting glass manufacturing facilities, 51 existing clay manufacturing facilities, and 10 existing secondary nonferrous metals

processing facili ties that use HAP metals. We a ssume all existing respondent will have to re

- fam i liarize with regulatory requireme nts each year. No new facilities

are expected in any of the industries.

c After full implementation, existing facilities are no longer required to submit an Initial Notification.

d After full implementation, existing facilities are no longer required to submit Notifications of Compliance Status.

e After full implementation, existing facilities are no longer required to keep records of the notifications.

f We estimate 21 glass manufacturing facilities with 27 affected furnaces. It is assumed that 13 of the 27 affected furnaces can m eet the emission limit without

installation of a control device. It is assumed that each of the remaining 14 affected furnaces ha ve automatic monitoring and recording systems.

g Since Initial Notification and Notifications of Compliance Status are not expected for existing facilities after full impleme ntation, 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.

j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.21

Table 2: Average Annual EPA Burden and Cost

– NESHAP for Clay Ceramics Manufacturing, Gl ass 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=AxB) (D)

Plants

per

Year (E)

Technical

Hours

per Year

(E=CxD) (F)

Management

Hours per

Year

(F=Ex0.05) (G)

Clerical

Hours per

Year

(G=Ex0.1) (H)

Costs per

Year a

Attend performance test b 16 1 16 1 16 0.8 1.6 $854.46

Report review:

Initial notification of applicability c 2 1 2 0 0 0 0 $0.00

Notification of performance test d

Notification of compliance status e 4 1 4 0 0 0 0 $0.00

Travel expenses for tests attended f $500

TOTAL ANNUAL BURDEN (rounded) g 18 $1,350

Assumptions:

a This ICR uses the following average hourly labor rates: $64.16 for managerial (GS

- 13, Step 5, $40.10×1.6), $47.62 (GS

- 12, Step 1, $29.76×1.6) for technical

and $25.76 (GS

- 6, Step 3, $16.10×1.6) for clerical. These rates are from the Office of Personnel Manage ment (OPM), 2016 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.

g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.