SUPPORTING STATEMENT NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS: SECONDARY ALUMINUM PRODUCTION

PART A

1.0 Identification of the Information Collection
(a) Title and Number of the Information Collection.

“ National Emissi on Standards for Secondary Aluminum Production

. ” This is a new information collection request (ICR)

, and the EPA tracking number i s 2453.01

. (b) Short Characterization. This ICR covers information collection requirements i n the proposed amendments to the Secondary Aluminum NESHAP ( 40 CFR part 63, subpart RRR )

. The p otential respondents are owners or operators of any existing

, new , or reconstructed secondary aluminum production p lant

. Per the applicability section of subpart RRR , the following

affected sou rces at a secondary aluminum production plant are covered: aluminum scrap shredders ; thermal chip dryers ; scrap dryers/delacquering kilns/decoating kilns ; group 2 furnaces; sweat furnaces ;
dross

- only furnaces ; rotary dross coolers ; and secondary aluminum processing units, which includes group 1 furnaces and in

- line fluxers

. The secondary aluminum industry consists of approximately 161 secondary aluminum production facilities, of which the EPA estimates 53 to be major sources of HAP. The proposed amendmen ts would correct and clarify various rule requirements and provisions. Specifically, the proposed amendments would require selected affected sources to comply with the emissions limits at all times including periods of startup and shutdown;; add a requirem ent to report performance testing through the Electronic Reporting Tool (ERT); add provisions allowing owners and operators to change furnaces classifications ; add requirements for test ing uncontrolled furnaces; add requirements to test for hydrogen fluori de; add operating requirements such as monitoring of lime injection rates; add alternative operating requirements for sweat furnaces; and make corrections and clarifications to the applicability, definitions, operating, monitoring, and performance testing requirements. The information collection requirements associated with the proposed amendments to the

NESHAP are listed in Attachment 1

. 2. Need For and Use of the Collection
(a) Need/Authority for the Collection

. Section 112 of the C lean Air Act (C AA ) req uire s the EPA to establish NESHAP for both major and area sources of HAP that are listed for regulation under CAA section 112(c). A major source is a stationary source that emits or has the potential to emit more than 10 tons per year ( tpy ) of any single

1H AP or more than 25 tpy of any combination of HAP

. An area source is a stationary source that is not a major source (i.e., an area source does not emit and does not have the potential to emit more than 10 t py of any single HAP or more than 25 t py of any com bination of HAP )

. Both major and area sources are subject to subpart RRR

. For major sources, these technology

- based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non

air quality health and environmental impacts) and are commonly referred to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires the EPA to review these technology

based standards and to revise them “as necessary (taking into a ccount developments in practices, processes, and control technologies)” no less frequently than every 8 years. In addition, section 112(f) of

the CAA requires the EPA to determine for source categories subject to certain CAA section 112(d)

standards whethe r the emissions limitations provide an ample margin of safety to protect public health.

For MACT standards for HAP “classified as a known, probable, or possible human carcinogen ” that “ do not reduce lifetime excess cancer risks to the individual most expos ed to emissions from a source in the category or subcategory to less than 1

- in

- 1 million,” the EPA must promulgate residual risk standards for the source category (or subcategory) as necessary to provide an ample margin of safety to protect public

health. In doing so, the EPA may adopt standards equal to existing MACT standards, if the EPA determines that the existing standards are sufficiently protective. The EPA must also adopt more stringent standards, if necessary, to prevent an adverse environmental ef fect, but must consider cost, energy, safety and other relevant factors in doing so. Certain records and reports are nec essary for the Administrator to confir m the compliance status

of sources subject to NESHAP

, identify any new or reconstructed s ources s ubject to the standards, and

confirm that the standards are being achieved on a continuous basis. These recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean Air Act (42 U.S.C. 7414) and set

out in the part 63 NES HAP General Provisions

. The recordkeeping and reporting requirements for operating permits (i.e., t itle V permits ) are contained in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or record.
(b) Use/Users of the Data. The information will be used by the delegated authority ( s tate agency , or Regional Administrator if there is no delegated s tate agency) to ensure that the standards and other requirements are being

achieved. Based on review of the recorded information at the site and the reported information, the appropriate authority can identify facilities that may not be in compliance and decide which f acilitie s,

2records or processes may need inspection

. 3. Nonduplication, Consultations and Other Collection Criteria
(a) Nonduplication. A computer search of the EPA ’ s ongoing ICRs revealed no duplication of information

- gathering

efforts.
(b) Public Notice Required Prior to ICR Submission to OMB. This section is not applicable because this is a rule

- related ICR.
(c) Consultations.

The proposed amendments w ere developed in consultation with individual secondary aluminum production companies and trade associa tion s

. The non

- EPA persons consulted on the information

collection activities are identified in Table 1.

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact Organization Telephone No. Charles Johnson, Jr. The Aluminum Association

, Inc. 703

- 358

- 2981
Mike P alazzolo Alcoa , Inc. 412

- 553

- 4832 Gary Barnett Aleris International, Inc. 216

- 910

- 3697 Steve Royer Logan Aluminum, Inc. 270

- 755

- 6390

(d) Effects of Less Frequent Collection.

If the relevant information was collected less frequ ently, the delegated permitting authority ( s tate

or the EPA) w ill not be reasonably assured that a facility is in compliance with the standards.
(e) General Guidelines. None of the guidelines in 5 CFR 1320.6 are being exceeded. (f) Confidentiality.

All i nformation 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 (see 40 CFR 2; 41 FR 36902, Sep tember 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979). (g) Sensitive Questions. This section is not applicable because this ICR does not involve matters of a sensitive nature.

4. The Resp ondents and the Information Requested
(a) Respondents/NAIC S Codes

.

3Potential respondents under s ubpart RRR are owners or operators of any existing or new facility engaged in Secondary Aluminum Productions operations

. Secondary Aluminum Production facilitie s are primarily classified under NAICS code 33131 4
, Secondary Aluminum Production

. There are an

estimated 161 facilities that would be subject to the proposed amendments to the NESHAP.
(b) Information Requested.
(i) Data Items, Including Recordkeeping Re quirements. Attachment 1

, Information Requirements, summarize s the data items, including recordkeeping and reporting requirements , for the Secondary Aluminum Production s ource c ategor y

. (ii) Respondent Activities. The respondent activities that will be re quired by the proposed

amendments to the Secondary Aluminum Production NESHAP are identified in Table 2 an d are introduced in section 6(a).

5. The Information Collected

– Agency Activities, Collection Methodology and Information Management
(a) Agency Activit ies.

The Agency activities associated with the proposed amendments to the Secondary Aluminum

Production NESHAP are provided in Table 3 and are introduced in section 6(c).
(b) Collection Methodology and Management

. Data and records maintained by the respo ndents are tabulated and published for use in compliance and enforcement programs of the appropriate authority

. The EPA is the appropriate authority

until the s tate or local agency is delegated authority to implement the final amendments to the rule.

There fore, i nformation contained in any report submitted to the Regional Administrator will be entered into the Air Facility System (AFS), which is operated and maintained by the EPA ’ s Office of Compliance. AFS is the EPA’s database for the collection, maintena nce, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. The EPA uses the AFS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA r egional

offices and EPA head quarters. The EPA and its delegated a uthorities can edit, store, retrieve and analyze

the compliance data.
(c) Small Entity Flexibility. The Small Business Administration defines a small entity engaging in Secondary Aluminum

Production as a firm having no more than 750 employees

. Of the 28 entities affected by this proposed
rule, nine of them are small. Of these nine

, all of them are estimated to experience a negative cost (i.e., a cost savings) as a result of the proposed rule

. After considering the econo mic impacts of these proposed

4changes on small entities, this action will not have a significant economic impact on a substantial

number of small entities. To reduce impacts, we are propos ing new provisions that would increase the industry’s flexibility as to how they operate group 1 furnaces and sweat furnaces . In addition, we are correcting certain provisions of the rule as well as proposing revisions to help clarify the rule’s intent.
(d) Collection Schedule

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

Table 2 for the Secondary Aluminum Production s ource c atego ry.
6. Estimating the Burden and Cost of the Collection
(a) Estimating Respondent Burden.

The annual burden estimates for the proposed amendmen ts to the Secondary Aluminum

Production NESHAP are shown in Table 2

. These numbers were derived from estimates based on the EPA’s experience with other standards. No burden estimates are provided for new sources because no new facilities are expected to be come affected sources during the three

- year implementation period of

this ICR.
(b) Estimating Respondent Costs.
(i) Estimating Labor Costs

. Table 2 presents estimated costs for the required data collection

activities. Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data. Technical, management and clerical average hourly rates for private industry workers and were taken from the United States Department of Labor, Bureau of Labor Statistics, September 20 11 , “Table 2.

Civilian W orkers, by occupational and industry group,” available at www.bls.gov/news.release/ecec.t02.htm. Wages for occupational groups are used as the basis for the labor rates with a total compensation of $ 47.21 per hour for technical, $ 57.82 per hour for manager ial
and $23. 72 per hour for clerical. These rates represent salaries plus fringe benefits and do not include the

cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully

- burdened hourly wage rates used to represent re spondent labor costs are: technical at $ 99.14 , management at $1 2 1 .42 and clerical at $4 9.81

. (ii) Estimating Capital and Operations and Maintenance (O&M) Costs

. An estimated 107

furnaces and 27 facilities would need to temporary hoods installed every 5 ye ars and testing conducted for a total capital cost of $17.3 million and a total annualized capital cost of $2.3 million. Total annualized cost per furnace would average $21,650 per year. As a result of the proposed requirement to
measure HF emissions, 8 af fected facilities would incur a total annual O&M cost of $ 11,000 . The proposed amendments would also allow owners/operators to switch furnace classifications , which would

5result in total annual O&M costs for testing of $500,000/yr or, for an estimated 50 f urnaces, a cost of $10,000 per furnace, or $14,706/yr per facility at 34 facilities.
(i ii ) Annualizing Capital Costs

. Annualized capital costs are approximately $ 2. 3 million or about
$ 85,8 00 /facility

. (c) Estimating Agency Burden and Cost

. Because the information collection requirements were developed as an incidental part of standards development, no costs can be attributed to the development of the information collection requirements. Because reporting and recordkeeping requirements on the part of the respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the part 63 NESHAP General Provisions, no operational costs w ill be incurred by the Federal Government. Publication and distribution of the information are part of the Compliance Data System, with the result that no Federal costs can be directly attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of sour ces that is part of the E PA’ s overall compliance and enforcement program, and, therefore, is not attributable to the ICR. The only costs that the Federal government w ill incur are user costs associated with the analysis of the reported information, as presented in Table 3

. The Ag ency labor rates are from the Office of Personnel Management (OPM) 20 1 1 General

Schedule

, which excludes locality rates of pay. These rates can be obtained from Salary Table 20 1 1

- GS
available on the OPM website, http://www.opm.gov/oca/11tables/pdf/gs_h.pdf

. The government employee labor rates are $ 15.63 /hour for clerical (GS

- 6, Step 3), $ 28.88 for technical (GS

- 12, Step 1)
and $ 38.92 /hr for management (GS

- 13, Step 5). These rates were increased by 60 percent to include fringe benefits and overhead. The fully

- burdened wage rates used to represent Agency labor costs are:
clerical at $ 25.01 /hour

, technical at $ 46.21 /hour and management at $ 62.27 /hour

. (d) Estimating the Respondent Universe and Total B urden and Costs

. There are an estimated 161 existing facilities that are currently subject to the Secondary

Aluminum Production NESHAP. No new major sources are expected the year following promulgation

of these amendments

. Consequently, the number of secon dary a luminum respondents in the year following promulgation is 161 respondents per year.

For the proposed amendments to the Secondary Aluminum Production NESHAP , the components of the total annual burden attributable to this ICR include reading the amendm ents to the

NESHAP ; monthly verification of lime injection rates ; analysis of performance test samples for HF; construction of temporary hooding and performing emissions test s on uncontrolled group 1 furnaces; and

6when a furnace classification is being cha nged, the requisite reporting and emissions testing to demonstrate compliance. A ll other recordkeeping and reporting activities are already accounted for in

the ICR for the NESHAP.
(e) Bottom Line Burden Hours and Cost Tables.
(i) Respondent tally. The bot tom line respondent burden hours and costs presented in Table 2 are calculated by adding person

- hours per year down each column for technical, managerial and clerical staff, and by adding down the cost column. The average annual burden for the recordkeepin g and reporting requirements in the proposed amendments t o subpart RRR for the 161 existing facilities that are subject to the Secondary Aluminum Production NESHAP is 1,695 person

- hours

, with an annual average

cost of $ 162,379

. The estimated annual operatio ns and maintenance costs (O&M) as a result of these
amendments is $ 511,000. Estimate d annualized c apital costs to the industry for the proposed

amendments are $ 2.3 million for a total estimated annualized costs ( annualized capital and O&M) of
$ 2.8 million

. (ii) The Agency tally. The average annual Federal Go vernment cost is $ 12,231 for 271 hours for the proposed amendments to subpart RRR

. The bottom line Agency burden hours and costs presented in

Table 4 are calculated by adding person

- hours per year down each column for technical, managerial and clerical staff and by adding down the cost column.
(iii) Variations in the annual bottom line. This section does not apply since no significant variation is anticipated. (f) Reasons for Change in Burden.

The EPA p rovides an adjustment to this ICR that estimates the costs of the notification, recordkeeping and reporting requirements associated with the proposed amendments that would add provisions allowing owners and operators to change furnaces classifications ; add requirements for

test ing uncontrolled furnaces; add requirements to test for hydrogen fluoride; and add requirements for

the monitoring of lime injection rates.
(g) Burden Statement The average annual respondent burden for the proposed amendments to the Secondary

Aluminum Production NESHAP is estimated at 11 p erson

- hours

. 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 utilize technology and systems for the purposes of collecting, validating and verifying information, processing and maintaining information,

7and disclosing and providing information; ad just 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

oth erwise 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 currently valid OMB control number. The OMB control numbers for the

EPA ’ s regulations in 40 CFR part 63 are listed in 40 CFR part 9. To comment on the Agency’s need for this information

, the accuracy of the provided burden estimates and any suggestions for minimizing respondent burden, including through the use of automated collection techniques

, the EPA has established a public docket for this ICR under Docket ID

No. EPA

- HQ

- OAR

- 20 10

- 0544 which is available for online viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation D ocket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room B

- 102, 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 Air Docket is (202) 566

- 1927

. An e lectronic version of the public docket is available at http://www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public 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 above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17 th Street, NW, Washington, DC 20503, Attention Desk

Officer for EPA. Please include the relevant Docket ID Number ( EPA

- HQ

- OAR

- 2011

- 0797 ) in any

c orrespondence.

8PART B This section is not applicable because statistical methods are not used in data collection

associated with the proposed rule

.

9TABLE 2

. ANNUAL RESPONDENT BURDEN AND COST

– PROPOSED AM ENDMENTS TO SECONDARY ALUMINUM NESHAP a

Burden item (A) Person

- hours per

occurrence (B) No. of

occurrences per respondent (C) Person

- hours per respondent (C=A*B) (D) Respondents

per year (E) Technical
person - hours

per year (E=C*D) (F) Management person - hour s

per year (E*0.05) (G) Clerical
person - hours

per year (E*0.1) (H) Cost 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 b 4 1 4 161 644 32.2 64.4 $70, 964 B. Required activities C. Create information N/A D. Gather existing information N/A E. Write report (changing furnace classification ) c 2 1 2 50 100 5 10 $1 1,019

5. Recordkeeping Requirements A. Read instructions See 4A B. Plan activities N/A C. Implement activities Verify lime injection rate 0.1 36 3.6 161 579.6 28.98 57.96 $63, 867 Changing furnace classification 2 1 2 50 100 5 10 $1 1,019 D. Develop record system N/A E. Time to enter information See 4C F. Time to train personnel N/A G. Time to adjust existing ways to comply with previously applicable requirements N/A

H. Time to transmit or disclo se information 1 1 1 50 50 2.5 5 $5, 510 I. Time for audits N/A TOTAL ANNUAL LABOR BURDEN AND COST (SALARY) 1473.6 73.68 147.36 $ 162,379 ANNUAL COSTS (O&M) HF testing d $1 1 ,000 Changing furnace classification , testing c $500,000 ANNUAL IZED CAPITAL COSTS e $ 2,316,550 TOTAL ANNUALIZED COSTS (annualized capital cost and annual O&M costs) $ 2,82 7 ,550 N/A = not applicable.

a T his ICR uses the following labor rates : $ 1 21.42 for managerial labor, $ 9 9.14 for technical labor, and $ 49.81 for clerical labor. These rates are based on the U.S. Department of Labor,

Bureau of Labor Statistics, Occupational Employment and Wages, September, 2011

. 10b There is an estimated 1 61 existing facilities; no new facilities are expected

.

c An estimated 50 facilities would change furnace classifications once per year. Testing for furnace changing is estimated at a cost of $10,000 per facility.

d An estimated 8 facilities would be required to test HF with a total cost of $1 1 ,000 /yr

.

e 27 facilities would be required to construct temporary hoods for testing at $ 226,000 /facility every 5 years

.

11TABLE 3

. ANNUAL BURDEN AND COST TO THE AGENCY

– PROPOSED AMENDMENTS TO PRIMARY SECONDARY NESHAP

Burden item (A) Person

- hours per occurrence (B) Occurrences per responde nt (C) EPA person

hours/year (C=A*B) (D) Facilities
per year (E) Technical person

hours/year ( E = C * D ) (F) Management person - hours/year ( F =0.05* E ) (G) Clerical person

hours/year ( G =0.1* E ) (H) Cost a , $

Report Review:

Review performance test reports and reports from facilities changing furnace classification b 4 1 4 59 236 11.8 23.6 $ 12,231

TOTAL BURDEN AND COST $ 12,231

a This ICR uses the followin g average hourly labor rates: $ 62.27 for m anagerial (GS

- 13, Step 5), $4 6.21 (GS

- 12, Step 1 ) for te chnical

, and $2 5.01 (G S

- 6, Step 3) for c lerical. These rates

are from the Office of Personnel Management (OPM) 20 1 1 General Schedule

, which excludes locality rates of pay

.

b Assumes a gency will review all of the annual reports

- including the 4 H F tests/yr , 5 tests/yr for uncontrolled furnaces and 50 reports/yr for changing furnace classification

.

12ATTACHMENT 1. INFORMATION REQUIREMENTS

– PROPOSED AMENDMENTS TO SECONDARY ALUMINUM NESHAP

Requirement Citation for existing sources Citation for new sources Gene ral Provisions citation

Lime injection rate v erificatio n § 63.1510(i)(4) § 63.1510(i)(4)

Measurements of HF in a ddition to HCl § 63.1503, 63.1505, 63.1511(c)(9), 63.1513 § 63.1503, 63.1505, 63.1511(c)(9), 63.1513

Uncontrolled furnaces that do not comply with ACGIH hooding g uidelines § 63.1512(e)(4) § 63.1512(e)(4)

Changing furnace classification § 63.1514 § 63.1514

13