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 L L) (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 am ended 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 ba ke 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.
Ingeneral, 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 source s 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 flu orides (TF) and polycyclic organic matter (POM). In addition to HAPs, this standard addresses particulate matter smaller than 10 microns in diameter (P M 10 ), 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 emiss ion monitors (CEMs) in the g eneral 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 sy stem is inoperative. Th ese notifications, report s, and records are essential in determining compliance, and are required of all sources subject to the NESHAP standards.2

Any owner or operator subject to the provisions of this part will maintain a file of these measurements, and retain the file for at le ast five y ears following the date of such occurrence, measurement, maintenance, corrective action, report or record. All rep orts are sent to the delegated state or local authority . In the event that there is no such delegated authority , the reports are s ent 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 n ext three years. However, we expect that one source per y ear will become subject to the standard over the next three years due to the reconstruction of an existing affect ed facility

. The number of facilities decreased for the renewal of this I CR due to m ore 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 dy

namics 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 In formation Collection Request (I CR) is estimated to be $7,130,009 (rounded). The Office of Management and Budget (OMB) approved the currently active I CR without any “ Terms of Clearance. ”
T he 16 major source facilities in the United States, which are respondents to this I CR, 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 Federa l Governm ent. 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 s ources 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. I n addition, sectio n 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 dat a 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.
Inthe Administrator's judgment, HAP emiss ions from hydrogen fluoride (HF), polycyclic organic matter (POM), and3

particulate matter smaller than 10 microns in diameter (PM 10 ) 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 L L. 2(b) Practical Utility/Users of the Data The control of emissions of HAP emissions from HF , POM and PM 10 , 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, p aste production plants, pitch storage tanks and anode bake furnaces. The subject standards are achieved by the capture of particulate matter smaller than 10 micro ns in diameter from paste production plants. The notifications required in the applicable re gulations 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 o perated 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 oper ating conditions under which complianc e 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 des cribed in this I CR 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 che ck 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 f rom 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 L L. 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 . I f 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 th e Federal standards. Therefore, no duplication exists.4

3(b) Public Notice Required Prior to ICR Submission to OMB An announcement of a public comment period for the renewal of this I CR was published in the Federal Register 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 I CR, 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.
Inaddition, we consulted the Agency ’s internal data sources including Donna lee Jones, the Agency contact for the residual risk rule on the primary

aluminum industry

sector, and the AFS ( AI RS Facility S ubs ys tem) , which is the EPA database for the collection, maintenance, and retrieval of all compliance data . The information in AF S i s 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 a pproximately 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 I CR. The Agency

also has the policy

to respond after a thorough review of comments received from the public since the last I CR renewal as well as those submitted in response to the f irst Federal Register

. Inthis 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 continuin g to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. I f the information required by these standards w as 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 y e ars. This is consistent with the General Provisions as applied to the stan dards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five year statute of limitations on which the permit program is5

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 mos t flagrant violators frequently have violations extending beyon d the five y ears. 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 cla im 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, Se ptember 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) Responden ts/SIC Codes The respondents to the recordkeeping and reporting requirements are primary aluminum reduction facilities. The United States Standard Industrial Classification (SI C) code for the respondents affected by the standards is SI C 3334 which corres ponds to the North American Industry

Classification Sy stem (NAI CS) 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 I CR 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 L L).
A source must make the following reports:6 Notification s 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) In itial notification when source bec omes 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) In itial perform ance test. 63.07(b) and 63.09(e) Rescheduled initial performance test. 63.07(b)(2) Demonstration of continuous monitoring sy stem, if applicable. 63.09(g) Compliance status including excess emissions report. 63.09(h) Reports Opacity or visible emissio ns. 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. I f 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: Recordkeeping7 Recordkeeping Startup, shutdown, ma lfunction periods where the continuous monitoring sy stem 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 pl an 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 sy stems (CEMS) if it were used. 63.10(b)(3) Records are required to be retained fo r five y ears. The most recent two y ears 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 sy stem. 63.850(e)(4)

Design information for paste production plant capture sy stems and alternative control devices. 63.850(e)(4) Emissions values from process and control devices. 63.85 9(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 a n 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 ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. Inaddition, 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 r ecordkeeping. (ii) Respondent Activities Respondent Activities8 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. In stall, 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 requirem ents 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 sy stems for the purpose of disclosing and providing information. Adjust the existing way s 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 ty pe of monitoring equipment has significantly reduced the burden associated with monit oring 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, analy sis, storage, and distribution of the required inform ation.9 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 facili ty

records. Input, analy

ze, and maintain data in the A IR S Facility S ubsy s tem (AFS). 5(b) Collection Methodology and Management Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution contr ol devices are properly

installed and operated. Performance test reports conducted for anode bake furnaces and potlines, as wel l as for primary and secondary

control sy stems, 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 auth ority 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 identificati on, as a check on source operation and maintenance, and for compliance determinations.
In formation conta ined 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 industr ial 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 a uthorities can edit, store, retrieve and analy

ze 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 o n small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these requirements the minimum needed to ensure compliance and, therefore, ca nnot reduce them further for small entities. To the extent that larger businesses can use econo mies of scale to reduce their burden, the overall burden will be reduced.10

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 Pri mary Aluminum Reduction Plants (40 CFR part 63, s ubpart L L). 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 I CR. 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 display s a currently

valid OMB Control Number. 6(a) Estima ting 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 L abor Hours from Table 1). These hours are based on Agency studies and back ground documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously approved I CR, and any comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the fo llowing 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 Work e 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 available to those employed by private industry

.11 (ii) Estimating Capital/Startup a nd Operation and Maintenance Costs The ty pe of industry

costs associated with the information collection activities in the subject standards are labor costs whi ch are addressed elsewhere in the I CR 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 maint ain the monitors and other costs such as photocopying and postage.

(iii) Capital/Startup vs. O peration 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) $100,00 0 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 I CR, as identified in the total of column D of the above table. The tot al operation and maintenance (O&M) cost for this I CR 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 IC R is estimated to be $91,348. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with analy sis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspec tion of so urces of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the I CR is estimated to be $10,247. This cost is based on the avera ge12

hourly labor rate as follows: Managerial $5 8.18 (GS

- 13, Step 5, $36.36 + 60% ) Technical $4 3.17 (GS

- 12, Step 1, $26.98+ 60%) Clerical $2 3

. 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 L L). 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our research for this I CR, 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 thre e y ears. The number of respondents over the three years period of this I CR 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

- ye ar period of this I CR 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. I n this standard, exis ting 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 I CR is calculated using the following table:13 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 performan ce 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 L L), 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 Bu rden 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 2,0 01 (rounded) hours per response. 6(f) Reasons for Change in Burden14

The decrease in labor burden to industry from the most recently

approved I CR is due a decrease in the number of existing primary aluminum reduction plants that are subject to NESHAP subp art LL. The number of facilities decreased for the renewal of this IC R 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 dy

namics related to the amount of aluminum being recovered to produce aluminum products. The reduction in the number of respondents to this I CR 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 I CR.
Inaddition, there was a decrease in the burden to the Federal/State government in the renewal of the I CR is due to the decre ase in the number of respondents. The costs associated with regulators attending performance tests were also removed from this I CR b ecause th is 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 re cordkeeping 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 sy stems for the purposes of collecting, validating, and verify ing information, processing and maintain ing information, an d disclosing and providing information; to adjust the existing way s 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 source s; 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 displ ay s a valid OMB Control Number. The OMB Co ntrol 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, includ ing the use of automated collection techniques, EPA has established a public docket for this I CR under Docket I D 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 obta in a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket I D number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and I nformation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Cons tituti on Ave nue , NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Read ing Room is (202) 566

- 1744, and the telephone number for the d ocket center i s (202) 566

- 1 752 . Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503,15

Attention: Desk Officer for EPA. Please include the EPA Docket I D 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.16

Table 1. Annual Respondent Burden and cost: NESHAP for Prim ary Alum inumReduction Plants (40 CFR Part 63, Subpart LL)

Burden item (A) Person
hours per occurrence (B)

No. of occurrences per respondent per year (C)

Person
hours per respondent per year (C=AxB) ( D)

Respondents per year (E)

Technical person hours per year (E=CxD) (F)

Managem ent person - hours per year (E=0.05) (G)

Clerical person hours per year (Ex0.1) (H)

Total Cost per year , $ a

1. Applications N/A 2. Survey and Studies N/A 3. Ac quisition, Installation, and Utilization of Technology and Systems 8 1 8 1 b 8.0 0.4 0.8 819.48 4. Reporting Requirements A. Read instructions 4 1 4 1 b 21.2 1. 1 2.1 409.74 B. Required activities Initial performance tes t 100 c 1 100 1 b 120 6.0 12.0 12,292.20 Annual performance test 100 c 5.1 d 510 16 e 8160 .0 408 .0 816 .0 835,,869.60 Monthly performance test (Method 13/14) 200 f 12 2400 12 g 28800 .0 1440 .0 2880 .0 2,950,128.00 Monthly performance test (CEM or Alcan cassette) 40 h 18 i 720 16 1 1520.0 800 .0 1600 .0 1,180,051.20 Quarterly performance test 200 j 16 k 3200 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 b 2.0 0 .1 0 .2 204.87 Notification of

constr u ction ./reconstr

uction 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 0.2 204.8717 Burden item (A) Person
hours per occurrence (B)

No. of occurrences per respondent per year (C)

Person
hours per respondent per year (C=AxB) ( D)

Respondents per year (E)

Technical person hours per year (E=CxD) (F)

Managem ent person - hours per year (E=0.05) (G)

Clerical person hours 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 b 32 .0 1.6 3.2 3,277.92 Notification of compliance

status 4 1 4 16 b 64 .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 n 51.2 2.56 5.1 5,244.67 Report of no excess emissions 8 2 m 16 14.4 o 230.4 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 b 0 .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 info rmation r equired by standards 3 q 52 q 156 16 2496 .0 124.8 249.6 255,677.76 F. Time to train personnel N/A G. Time to adjust existing ways t t o comply with previously applicable requirements N/A18 Burden item (A) Person
hours per occurrence (B)

No. of occurrences per respondent per year (C)

Person
hours per respondent per year (C=AxB) ( D)

Respondents per year (E)

Technical person hours per year (E=CxD) (F)

Managem ent person - hours per year (E=0.05) (G)

Clerical person hours per year (Ex0.1) (H)

Total Cost per year , $ a

H. Time to transmit or disclose Information 0.25 r 2 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 la bor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2006, A Table 10. Private industry, by occupational and industry group. @ The rates are from column 1, A Total 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 fac ility (i.e., pitch storage tank). It is assumed that the plant has a startup, shutdown and malfunc tion 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 p erform 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 al ternative 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 respo ndent (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 Assum es 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 mon itoring 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 Governm ent: NESHAP for Prim ary Alum inumReduction Plants (40 CFR part 63, subpart LL)

Burden Item (A) Person Hours Per Occurrence (B)

Num ber 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)

Managem ent 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 b 2.0 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 b 2.0 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

Not ification 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 10,246.7120 Burden Item (A) Person Hours Per Occurrence (B)

Num ber 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)

Managem ent 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 follow ing hourly labor rates times a 1.6 benefits multiplication factor to acc ount 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) A 2007 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 pla nts on an annual basis for purposes of calculating the burden. However, plants are expected to submit performance test results w ith 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.