SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Primary Aluminum Reduction Plants

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Primary Aluminum Reduction Plants (40 CFR part 63, subpart LL) (Renewal)

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) standards for primary aluminum reduction plants 

were proposed on September 26, 1996, promulgated on October 7, 1997 and amended on November 2, 2005. These standards apply to 

the owner or operator of the affected facilities which include new or existing potlines, paste production plants, or anode bake furnaces 

associated with primary aluminum production and located at a major source, and for each new pitch storage tank associated with a 

primary aluminum reduction plant.

In general, all the NESHAP standards implement Section 12(b) of the Clean Air Act, as amended, and are based on the 

Administrator’s determination that primary aluminum reduction plants emit or have the potential to emit hazardous air pollutants 

(HAPs). The standards ensure that all major sources of air toxic emissions achieve a level of control at least as low as the better 

controlled and lower emitting sources in each category. This involves the installation, operation and maintenance of particulate 

control devices such as electrostatic precipitators or scrubbers.

The major HAPs emitted by these facilities include hydrogen fluoride (HF) measured as total fluorides (TF) and polycyclic 

organic matter (POM). In addition to HAPs, this standard addresses particulate matter smaller than 10 microns in diameter (PM10), 

which are controlled under the National Ambient Air Quality Standards (NAAQS).

All the NESHAP standards require initial notifications, performance tests, and periodic reports according to the general 

provisions specified in 40 CFR part 63, subpart A. With the exception of the performance specifications for continuous emission 

monitors (CEMs) in the general provisions, which are not applicable to HF CEMs because such specifications have not yet been 

developed for that device, all the general provisions requirements apply to sources subject to the NESHAP for primary aluminum 

reduction plants. Owners or operators 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 sources subject to the NESHAP 

standards.
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Any owner or operator subject to the provisions of this part will maintain a file of these measurements, and retain the file for at 

least five years following the date of such occurrence, measurement, maintenance, corrective action, report or record. 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 

EPA regional office.

Approximately 16 existing primary aluminum facilities major sources of hazardous air pollutants are currently subject to the 

standard, and it is estimated that there will be no new growth in the industry over the next three years. However, we expect that one 

source per year will become subject to the standard over the next three years due to the reconstruction of an existing affected facility. 

The number of facilities decreased for the renewal of this ICR due to more accurate estimates of the number of existing and new 

facilities and closure of a few facilities due to economic factors, including cost of energy and market dynamics related to the amount of 

aluminum being recovered to produce aluminum products. The average annual cost to industry over the next three years of this 

Information Collection Request (ICR) is estimated to be $7,130,009 (rounded).

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.”

The 16 major source facilities in the United States, which are respondents to this ICR, are publicly owned and operated by

primary aluminum reduction plants. None of the facilities are owned by either state, local and tribal agencies or the Federal 

Government.

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 or 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 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 hydrogen fluoride (HF), polycyclic organic matter (POM), and 
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particulate matter smaller than 10 microns in diameter (PM10) from primary aluminum reduction plants cause or contribute to air 

pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this 

source category at 40 CFR part 63, subpart LL.

2(b) Practical Utility/Users of the Data

The control of emissions of HAP emissions from HF, POM and PM10, and HAPs from primary aluminum reduction plants 

requires not only the installation of properly designed equipment, but also the operation and maintenance of that equipment. These 

emissions are the result of operation of specific point sources at these plants including potlines, paste production plants, pitch storage 

tanks and anode bake furnaces. The subject standards are achieved by the capture of particulate matter smaller than 10 microns in 

diameter from paste production plants.

The notifications required in the applicable regulations 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 regulations are being met. Performance test reports are needed as these are 

the Agency's record of a source's initial capability to comply with the emission standards, and serve as a record of the operating 

conditions under which compliance was achieved. The excess emissions reports are used for problem identification, as a check on 

source operation and maintenance, and for compliance determinations.

The information generated by the monitoring, recordkeeping and reporting requirements described in this ICR is used by the 

Agency to ensure that facilities affected by the NESHAP continue to operate the control equipment and achieve continuous 

compliance with the regulation. The semiannual reports are used for problem identification, as a check on source operation and 

maintenance, and for compliance determinations. Adequate monitoring, recordkeeping, and reporting are necessary to ensure 

compliance with the applicable regulations, as required by the Clean Air Act. The information collected from recordkeeping and 

reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, 

subpart LL.

3(a) Nonduplication

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 their 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, no duplication exists.
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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 72 FR 10735 

on March 9, 2007. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The assumptions made in the development of this ICR, including the estimate on the number of primary aluminum reduction 

plants subject to the NESHAP subpart LL rule, were reviewed and updated by the Agency in consultation with Mr. Robert Strieter of 

the Aluminum Association, who in turn consulted with some of the committee members.

In addition, we consulted the Agency’s internal data sources including Donnalee Jones, the Agency contact for the residual risk 

rule on the primary aluminum industry sector, and the AFS (AIRS Facility Subsystem), which is the EPA database for the collection, 

maintenance, and retrieval of all compliance data. The information in AFS is reported by industry, in compliance with the 

recordkeeping and reporting provisions in the standard. AFS is operated and maintained by the Office of Compliance at EPA. We 

have estimated that there are approximately 16 existing respondents subject to the standard and no new sources will become subject to 

the standard over the three year period covered by this ICR.

The Agency also has the policy to respond after a thorough review of comments received from the public since the last ICR 

renewal as well as those submitted in response to the first Federal Register. 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 likelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease.

3(e) General Guidelines

None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, 

section 1320.5.

These standards require affected facilities 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 
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based. Also, the retention of records for five years would allow EPA to establish the compliance history of a source and any pattern of 

compliance for purposes of determining the appropriate level of enforcement action. Historically, EPA has found that the most 

flagrant violators frequently have violations extending beyond the five years. EPA would be prevented from pursuing the worst 

violators due to the destruction or nonexistence of records if records were retained for less than five years.

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

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are primary aluminum reduction facilities. The United States

Standard Industrial Classification (SIC) code for the respondents affected by the standards is SIC 3334 which corresponds to the North 

American Industry Classification System (NAICS) 331312 for Primary Production of Aluminum.

4(b) Information Requested

None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, 

section 1320.5.

(i) Data Items

All data in this ICR that are recorded and/or reported are required by National Emission Standards for Hazardous Air 

Pollutants for Primary Aluminum Reduction Plants (40 CFR 

part 63, subpart LL).

A source must make the following reports:
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Notifications

Notification and application of construction/reconstruction. 63.05

Notification of initial compliance status. 63.850(a)(6)

Notification of compliance approach. 63.850(a)(8)

Initial notification when source becomes subject to standard. 63.9(b) and 63.850(a)

One-time notification for each affected source of the intent to use an 

HF continuous emission monitor.

63.850(a)(7)

Performance test results/reports.

63.10(d)(2), 

63.850(a)(5) and 

63.850(b)

Initial performance test. 63.07(b) and 63.09(e)

Rescheduled initial performance test. 63.07(b)(2)

Demonstration of continuous monitoring system, if applicable. 63.09(g)

Compliance status including excess emissions report. 63.09(h)

Reports

Opacity or visible emissions.

63.10(d)(3), 

63.845(h),and 

63.845(i)

Periodic startup, shutdown, malfunction reports and, if applicable, 

implementation plan.

63.10(d)(5)(I) and 

63.850(c)

Semiannual reports are required for periods of operation during which 

measured emissions exceed an applicable limit. If control device 

operating parameters are outside of the established ranges, quarterly

reports are required as a result of excess emissions.

63.859(d)

A source must keep the following records:

Recordkeeping
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Recordkeeping

Startup, shutdown, malfunction periods where the continuous 

monitoring system is inoperative.

63.10(b)(2)

Emission test results and other data needed to determine emissions. 63.13(g)

All reports and notifications. 63.10(b)

A copy of the startup, shutdown, and malfunction plan and if 

applicable, of the implementation plan for emissions averaging.

63.850(e)(4)

Record of applicability. 63.10(b)(3)

Records for sources with continuous monitoring systems (CEMS) if it 

were used.

63.10(b)(3)

Records are required to be retained for five years. The most recent 

two years of records must be retained at the facility.

63.850(e)(1-2)

Aluminum production rate and anode production. 63.850(e)(4)

Records associated with an owner or operator request to monitor 

similar potlines, to perform reduced sampling, or to establish and 

alternative limit for a HF CEM system.

63.850(e)(4)

Design information for paste production plant capture systems and 

alternative control devices.

63.850(e)(4)

Emissions values from process and control devices. 63.859(e)(4)

Documentation that daily inspections of process and control devices 

were performed and corrective action(s) taken as required.

63.859(e)(4)

Electronic Reporting

Currently, sources are using monitoring equipment that provides parameter data in an automated way, e.g., hydrogen fluoride and 

polycyclic organic matter emit HAPs from these facilities. 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. In addition, electronic 

reporting is increasingly allowed by regulatory agencies which, in turn, reduces the reporting burden. At this time, it is estimated that 

approximately 50 percent of the respondents use electronic recordkeeping.

(ii) Respondent Activities

Respondent Activities
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Respondent Activities

Read instructions.

If approved by the appropriate regulatory agency, a respondent may install, calibrate, maintain, 

and operate an HF CMS for the monitoring of TF secondary emissions as an alternative 

method.

Install, calibrate, maintain, and operate a continuous parameter monitor for each emission 

control device including dry alumina scrubbers, dry coke scrubbers, wet scrubbers, 

electrostatic precipitators and wet roof scrubbers.

Perform performance test using reference methods specified in Appendix A of 40 CFR part 60 

including initial performance test. An alternative test method for TF and POM emissions may

be used provided the owner or operator has demonstrated the equivalency of the alternative 

method to a specific plant and has received previous approval from the applicable regulatory

authority for its use, or it meets the criteria specified in sections 63.848(d)(1) and (d)(3) 

through (d)(6).

Comply with emission monitoring requirements to measure TF, POM and opacity as required.

Write the notification and reports listed above.

Enter information required to be recorded above.

Develop, acquire, install, and utilize technology and systems for the purpose of 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.

Transmit, or otherwise disclose the information.

Currently, sources are using automated monitoring equipment that provides parameter data. 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.

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.
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Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control 

devices are properly installed and operated. Performance test reports conducted for anode bake furnaces and potlines, as well as for 

primary and secondary control systems, are used to discern the source’s initial capability to comply with the standards and note the 

operating conditions under which compliance will be achieved. The regulatory authority will use performance test reports or design 

evaluation findings for pitch storage tanks to determine initial compliance with the standard. The semiannual emission reports, unless 

quarterly reports are required as a result of excess emissions, are used by the regulatory authority for problem identification, as a check 

on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into the AFS which is operated and maintained by EPA's Office of Compliance. 

AFS is EPA’s database for the collection, maintenance, and retrieval of compliance and annual emission inventory data for more than 

100,000 industrial and government-owned facilities. EPA uses the AFS 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 or operator for five years.

5(c) Small Entity Flexibility

A majority of the affected facilities are large entities (e.g., 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 requirements the minimum needed to ensure compliance and, therefore, cannot 

reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the 

overall burden will be reduced.
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5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in Table 1: Annual Respondent 

Cost and Burden: NESHAP for Primary Aluminum Reduction Plants (40 CFR part 63, subpart LL).

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 the subpart 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, we have identified the specific tasks 

and the underlying assumptions. 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 80,046 hours (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents 

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 $105.86 ($50.41 + 110%) 

Technical $92.61 ($44.10 + 110%)

Clerical $45.32 ($21.58 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2006, 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.
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(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the subject standards are labor costs which are 

addressed elsewhere in the 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 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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondent

s 

(D)

Total 

Capital/Startup 

Cost

(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)

HF CEMs 

(similar 

potlines)

$100,000 0 $0 $1,669 16 $26,704

Method 14 

(manifolds 

at potlines)

$200,000 0 $0 $3,339 12 $40,068

Method 14A 

(alcan 

cassettes)

$92,000 0 $0 $1,536 16 $24,576

Total $0 $91,348

There is no annualized capital/startup cost for this ICR, as identified in the total of column D of the above table. The total 

operation and maintenance (O&M) cost for this ICR are $91,348, as identified in the total of column G of the above table. Therefore, 

the total annualized capital/startup cost and the operation and maintenance cost to industry over the next three years of the ICR is 

estimated to be $91,348. 

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 $10,247. This cost is based on the average 
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hourly labor rate as follows:

Managerial $58.18 (GS-13, Step 5, $36.36 + 60%)

Technical $43.17 (GS-12, Step 1, $26.98+ 60%)

Clerical $23.36 (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) 2007 General Schedule which excludes locality rates of pay. Details 

upon which this estimate is based appear in Table 2: Annual Burden and Cost to the Federal/State Government: NESHAP for Primary

Aluminum Reduction Plants (40 CFR part 63, subpart LL).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately 16 existing primary aluminum reduction plants are currently subject to the 

standard. It is estimated that no expected additional sources per year will become subject to the standard in the next three years.

The number of respondents over the three years period of this ICR is calculated using the following table:

Number 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)

1 1 16 0 1 16

2 1 16 0 1 16

3 1 16 0 1 16

Average 1 16 0 1 16

As shown in the above table, the average Number of Respondents over the three-year period of this ICR is 16. Please note that 

new respondents include sources with constructed, reconstructed and modified affected facilities. To avoid double-counting 

respondents, the total number of respondents that are also new respondents in column D is subtracted. In this standard, existing 

respondents that are also new respondents are required to submit initial notifications. 

The average number of annual responses over the three year period of this ICR is calculated using the following table:
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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

Notification of applicability 1 1 N/A 1

Notification of 

construction//reconstruction 1 1 N/A 1

Notification of actual startup 1 1 N/A 1

Notification of initial 

performance test 1 1 N/A 1

Notification of compliance 

status/approach 1 1 N/A 1

Semiannual report of monitoring 

exceedances 1.6 2 N/A 3.2

Semiannual report of no excess 

emissions 14.4 2 N/A 28.8

Startup, shutdown, malfunction 

report 1.6 2 N/A 3.2

Total 40.2

As shown on the above table, the Total Annual Responses is 40 (rounded). This estimate is based on the assumption that the 

results from the monthly, quarterly and annual performance tests will be submitted with the semiannual compliance reports. 

The total annual labor burden and costs to industry are 80,046 hours and $7,130,009, respectively. The details regarding the 

respondent total labor burden and costs are found in Table 1. Annual Respondent Burden and Cost: NESHAP for Primary Aluminum 

Reduction Plants (40 CFR part 63, subpart LL), attached. 

The total annual capital/startup and O&M costs to the regulated entity are $91,348, as discussed in Section 6(b)(iii), 

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

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the respondents are attached. The annual public 

reporting and recordkeeping burden for this collection of information is estimated to average 2,001 (rounded) hours per response.

6(f) Reasons for Change in Burden
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The decrease in labor burden to industry from the most recently approved ICR is due a decrease in the number of existing 

primary aluminum reduction plants that are subject to NESHAP subpart LL. The number of facilities decreased for the renewal of this 

ICR due to a more accurate estimate of the number of existing facilities subject to the rule and closure of a few facilities due to 

economic factors, including cost of energy and market dynamics related to the amount of aluminum being recovered to produce 

aluminum products. The reduction in the number of respondents to this ICR also resulted in a decrease on the average annual cost for 

capital/startup and operation and maintenance costs to industry over the next three years of the ICR.

In addition, there was a decrease in the burden to the Federal/State government in the renewal of the ICR is due to the decrease 

in the number of respondents. The costs associated with regulators attending performance tests were also removed from this ICR 

because this is an enforcement activity related to case development and, therefore, exempt from the requirements of the Paperwork 

Reduction Act. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 2,001 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; to 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; to adjust the existing ways to comply with any previously applicable 

instructions and requirements; to train personnel to be able to respond to a collection of information; to search data sources; complete 

and review the collection of information; and to 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’s 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-2007-0127. 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), EPA West, Room 3334, 1301 Constitution Avenue, 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, Washington, DC 20503, 
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Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2007-0127 and OMB Control Number 

2060-0360 in any correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.
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Table 1. Annual Respondent Burden and cost: NESHAP for Primary Aluminum Reduction Plants (40 CFR Part 63, Subpart LL)

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(E=0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Total Cost

per year, $

a

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, Installation, and

 Utilization of Technology and

 Systems

8 1 8 1 b8.0 0.4 0.8 819.48

4. Reporting Requirements

A. Read instructions 4 1 4 1 b21.2 1.1 2.1 409.74

B. Required activities

 Initial performance test 100 c1 100 1

b

120 6.0 12.0 12,292.20

 Annual performance test 100 c5.1 d510 16 e8160.0 408.0 816.0 835,,869.60

 Monthly performance test

 (Method 13/14)

200 f12 2400 12 g28800.0 1440.0 2880.0 2,950,128.00

 Monthly performance test

 (CEM or Alcan cassette)

40 h18 i720 16 11520.0 800.0 1600.0 1,180,051.20

 Quarterly performance test 200 j16 k3200 2

l

6400.0 320.0 640 655,584.00

 Daily monitoring 2 365 730 16 11,680.0 584.0 1,168.0 1,196,440.80

C. Create information See 4B

D. Gather existing information See 4B

E. Write report

 Notification of applicability 2 1 2 1 b2.0 0.1 0.2 204.87

 Notification of 

 

 construction./reconstruction 

2 1 2 1

b 2.0 0.1 0.2 204.87

 Notification of actual startup 2 1 2 1

b

2.0 0.1 0.2 204.87
17

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(E=0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Total Cost

per year, $

a

 Notification of special 

 compliance requirements N/A

 Notification of performance test 2 1 2 16 b32.0 1.6 3.2 3,277.92

 Notification of compliance 

 

 

 status

4 1 4 16 b64.0 3.2 6.4 6,555.84

 NESHAP waiver application N/A

 Report of performance test See 4B

 Report of monitoring 

 exceedances 16 2

m

32 1.6 n51.2 2.56 5.1 5,244.67

 Report of no excess emissions 8 2

m

16 14.4 o230.4 11.5 23.0 23,601.02

 Startup, shutdown, malfunction

 report

8 2

m

16 1.6 

p

25.6 1.3 2.6 2,622.34

 Startup, shutdown, malfunction

 plan

40 1 40 1 b0.0 0.0 0.0 0.00

5. Recordkeeping Requirements

A. Read instructions See 4B

B. Plan activities N/A

C. Implement activities See 4B

D. Develop record system N/A

E. Time to enter information

 Records of all information 

 required by standards 3

q

52 q156 16 2496.0 124.8 249.6 255,677.76

F. Time to train personnel N/A

G. Time to adjust existing ways t

 to comply with previously

applicable requirements

N/A
18

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(E=0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Total Cost

per year, $

a

H. Time to transmit or disclose

Information

0.25 r2

m

0.5 16 8.0 0.4 0.8 819.48

I. Time for audits N/A

Subtotal 69,605.2 3,480.3 6,960.5 7,130,008.66

TOTAL LABOR BURDEN AND 

COST (Rounded) 80,046 7,130,009

Assumptions:

a This ICR uses the following labor rates: $105.86 for Managerial labor, $92.61 for Technical labor, and $45.32 for Clerical labor. These rates are from the United 

States Department of Labor, Bureau of Labor Statistics, December 2006, ATable 10. Private industry, by occupational and industry group.@ The rates are from 

column 1, ATotal compensation.@ The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.

b Assumes that one plant per year will have to comply with initial rule requirements due to a reconstruction of an affected facility (i.e., pitch storage tank). It is 

assumed that the plant has a startup, shutdown and malfunction plan in place.

c Assumes it takes 100 hours each for Method 13 and Method 315 for primary controls of potlines and bake furnaces.

d Assumes 59 Method 13 tests and 22 Method 315 tests will be conducted each year (primary control systems) for a total of 81 tests for 16 respondents (81/16 = 

5.1 per respondent).

e Assumes that there are 16 primary aluminum plants subject to this standard. f Assumes it takes 200 hours for Method 13/14 for secondary emissions from 

potlines.

g Assumes that 12 potlines must perform manual sampling as a result of the NESHAP. Testing was already required by the States for other potlines.

h Assumes it takes 40 hours for testing of similar potlines (CEM or Alcan cassette).

i Assumes that 24 potlines will be monitored under the alternative monitoring provisions for similar potlines. This is 18 per respondent (24*12/16 = 18).

j Assumes it takes 200 hours for a Method 315 test for secondary emissions.

k Assumes that a total of 8 Soderberg potlines at two plants, this is 16 per respondent (8*4/2 = 16).

l Assumes that two Soderberg plants will conduct quarterly performance tests.

m This rule requires that all existing respondents submit semiannual reports. Performance test results will be submitted with the semiannual reports.

n Assumes that 10 percent fail to meet the standard (0.1 x 16).

o Assumes that 90 percent meet the standard (0.9 x16).

p Assumes that 10 percent must file startup, shutdown, malfunction report (0.1 x 16).

q Assumes it takes 3 hours per week per plant to enter monitoring data into records.

r Assumes it takes 15 minutes to transmit recorded information.

N/A = Not Applicable. 
19

Table 2. Annual Burden and Cost to the Federal/State Government: NESHAP for Primary Aluminum Reduction Plants (40 CFR part 63, subpart LL)

Burden Item

(A)

Person 

Hours Per 

Occurrence

(B)

Number of 

Occurrences 

Per Plant 

Per Year

(C)

Person 

Hours Per 

Plant Per 

Year

(C=AxB)

(D)

Plants Per 

Year 

(E)

Technical 

Hours Per 

Year

(E=CxD)

(F)

Management 

Hours Per 

Year

(F=0.05xE)

(G)

Clerical 

Hours Per 

Year

(G=0.1xE)

(H)

Total Costs 

 

Per Year, $

a

New or reconstructed Facilities

Notification of applicability 2 1 2 1 b2.0 0.1 0.2 96.83

Notification of construction 

 and reconstruction

2 1 2 1 b

2.0 0.1 0.2 96.83

Notification of actual startup 2 1 2 1 b2.0 0.1 0.2 96.83

Notification of special 

compliance requirements

N/A

Notification of initial 

performance test

2 1 2 1 b

2.0 0.1 0.2 96.83

Notification of compliance 

status

8 1 8 1 b

2.0 0.1 0.2 96.83

Existing Facilities

Review of performance 

test report

8 1 8 16 d

128.0 6.4 12.8 6,197.12

Review of excess emissions 

report

8 1 8 1.6 c

12.8 0.6 1.3 617.85

Review of no excess 

emissions report

2 2 4 14.4 e 57.6 2.9 5.8 2,790.80 

Review of NESHAP waiver 

application

N/A

Review of startup, shutdown, 

malfunction report

2 1 2 1.6 f

3.2 0.2 0.3 156.79

Subtotal 211.6 10.6 21.2 10,246.71
20

Burden Item

(A)

Person 

Hours Per 

Occurrence

(B)

Number of 

Occurrences 

Per Plant 

Per Year

(C)

Person 

Hours Per 

Plant Per 

Year

(C=AxB)

(D)

Plants Per 

Year 

(E)

Technical 

Hours Per 

Year

(E=CxD)

(F)

Management 

Hours Per 

Year

(F=0.05xE)

(G)

Clerical 

Hours Per 

Year

(G=0.1xE)

(H)

Total Costs 

 

Per Year, $

a

TOTAL LABOR BURDEN 

and COST (rounded) 243 10,247

Assumptions:

a This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $58.18 for 

Managerial (GS-13, Step 5, $36.36 + 60%), $43.17 for Technical (GS-12, Step 1, $26.98+ 60%) and $23.36 Clerical (GS-6, Step 3, $14.60 + 60%). These rates 

are from the Office of Personnel Management (OPM) A2007 General Schedule@ which excludes locality rates of pay. 

b Assumes that one plant per year over the next three years will install a new or reconstructed pitch storage tank.

c Assumes that 10 percent of the 16 plants (1.6) will have excess emissions.

d Assumes that EPA/State personnel will review summary of performance tests requirements to be submitted by all 16 existing plants on an annual basis for 

purposes of calculating the burden. However, plants are expected to submit performance test results with the semiannual reports. 

e Assumes that the remaining 90 percent of the 16 plants (14.4) will not have excess emissions.

f Assumes that 10 percent of plants per year (1.6) will report a startup, shutdown, malfunction incident.

N/A = Not Applicable.