Revised 1/30 /2007 1 PAPERWORK REDUCTI ON ACT SUBMI SSI ON WORKSHEET

PART I : I nf ormat i on Col l ect i on Request

Thi s worksheet repl aces t he previ ous OMB 83

- I f orm f or I nf ormat i on Col l ect i on Request s ( I CRs ). Thi s worksheet i s i nt ended t o hel p I CR

preparers t ransi t i on bet ween t he pa per 83

- I syst em and use of t he I nf ormat i on Col l ect i on Request

, Revi ew and Approval Syst em ( I CRAS ) f or

submi t t i ng I CRs t o OMB

. Thi s f orm i s not i nt ended f or submi ssi on t o OMB

. For addi t i onal gui dance on compl et i ng t hi s workshe et

, pl ease see

EPA ’ s I CR webs i t e at ht t p :// i nt ranet

. epa

. gov / i cri nt ra /

. There you wi l l f i nd t he f ol l owi ng docume nt s : OEI ’ s I CRAS I nst ruct i ons ( under

Prepare I CR Package t ab ) and OMB ’ s ROCI S I C Q

& A ( l ocat ed under t he Downl oad Gui dance t ab )

, as wel l as t he cont act i nf ormat i on f or your

app r opri at e I CR desk of f i cer

.

1. Agency/Subagency originating request: U.S. Environmental Protection Agency

2. Title: National Emission Standards for Primary Aluminum Reduct ion Plants (40 CFR Part 63, Subpart LL ) ( Amendments )

3. Type of Information Collection ( check one ) :

New collection Extension of a currently approved collection Revision of a currently approved co llection

Nonmaterial or non

- substantive change to a currently approved collection (formerly called the 83

- C) 4. OMB Control Number (OCN) :

EPA ICR Number: 2 44 7 .01

5

. Type of review requested ( check one ) :

Regular Emergency

– Approval Requested by: (mm/dd/yy) Delegated

(If emergency, please submit justification as a separate attachment ) 6

. Requested expiration date ( check one ) :

Three years from approval date Six Months from approval date (maximum for emergency) Other, please sp ecify: (mm/yy)Revised 1/30 /2007 2 7 . Abstract (4000 characters maximum, attach additional sheets as necessary): The NESHAP (or MACT rule) for the Primary Aluminum Reduction Plants were promulgated on October 7, 1997 (62 FR 52407) and amended on November 2, 2005 (70 FR 66285) as 40 CFR 63, subpart LL. The rule is applicable to facilities with affected sources associated with the production of aluminum by electrol ytic reduction. The purpose of this information collection request is to document the expected impacts of proposed changes to subpart LL that are being developed as part of the risk and technology review process of the current subpart LL. The standards promulgated in 1997 and 2005 apply to emissions of HF, measured using total fluorides (TF) as a surrogate , from all potlines and anode bake furnaces, and POM (as measured by methylene chloride extractables) from Soderberg potlines, anode bake furnaces, paste production plants and pitch storage t anks associated with primary aluminum reduction. Affected sources under the rules are each potline, each anode bake furnace (except for one that is located at a facility that only produces anodes for use off

- site), each paste production plant, and each new pitch storage tank. The EPA is required to review technology

- ba sed standards and to revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequently than every 8 years, under CAA section 112(d)(6).

Compared to existing subpart LL, the proposed changes would establish standards for emissions of POM from prebake potlines, reduce the POM emission limit for Soderberg potlines, establish a limit for carbonyl sulfide (COS) emissions from all potlines, and establish a design standard for emission controls app licable to existing pitch storage tanks. In addition, the proposed rule would eliminate the startup, shutdown and malfunction (SSM) exemption, remove the SSM plan requirement, add provisions to provide an affirmative defense a gainst civil penalties for exc eedances of emission standards caused by malfunctions and add a requirement for electronic submittal of performance tests.

8 . Citations for Authorizing Statute(s) :

a. Public Law

Name of law:

Citation:

- Sec

b. US Code

Name of Law: Clean Air Act

Citation: 42 USC: 7401

c. Executive Order
Name/Subject of EO:

Citation : EO

d. Statute at Large

Name of Statute:

Citation: Stat

9 . Associated Rulemaking Information (For Rule Related ICRs Only) :

RIN: 2060

– AQ92 SAN: Stage of Rulemaking (check one) : Proposed Rule

Interim Final or Final Rule

For a Proposed Rule, OMB will n ot consider an ICR complete until the Notice of Proposed Rulemaking has been published. OEI will enter this

information into ICRAS.

For ICRs associated with Interim Final s that are not significant under EO 12866, please attach a draft of the rule

.Revised 1/30 /2007 3 10 . F ederal Register Notices & Comments :

Federal Register Citation ( For Non

- Rule Related and Renewal ICRs Only) :

60

- day Notice: Volume: Page number: Publication Date:
( 30

- day Notice: Volume: Page number: Publication Date )

Did the Agency receive public comments on this ICR? Yes No

Unless submitted as an Emergency ICR or Associated with a Rulemaking, OMB will not consider an ICR complete until the 30

- day notice

h as been published. The second notice will be published following OEI review and approval of the ICR. OEI will enter this information in to ICRAS

.

11 . Annual Cost to Federal Government: 3109 .00

12. Does this ICR contain surveys, censuses, or employ statistical methods? Ye s No

( If Y es, please attach Supporting Statement, Part B )

13. Is a Privacy Impact Assessment required by the E

- Government Act of 2002 for this ICR? Yes No

(A PIA is needed for a new, electronic collection of information. )

14. Agency Contact:

Name: David Putney

Phone: 919/541

- 2016

E

- mail: putney.david@epa.govRevised 1/30 /2007 4 15 . Change in Burden:

A. Program Change Due to a New Statute

If change in burden is a P rogram C hange D ue to a N ew S tatute , identify the C itation s for the N ew S tatutory R equirements:

a. Public Law

Name of law:

Citation:

- Sec

b. US Code

Name of Law:

Citation: USC:

c. Executive Order
Name/Subjec t of EO:

Citation : EO

d. Statute at Large

Name of Statute:

Citation: Stat

B. Program Change Due to Agency Discr etion

If change in burden is a DECREASE because of a P rogram C hange due to A gency D iscretion , please categorize the decrease (select one):

Cutting Redundancy
Using Information Technology
Changing R egulations Changing Forms

Miscellaneous Actions

If change in burden is a INCREASE because of a P rogram C hange due to A gency D iscretion , please categorize the increase (select one):
Changing Regulations

Miscellaneous Actions

C

. Explanation of Change in Burden

Explain the reasons for any program changes or adjustments reported; that is, provide a short statement addressing how the re duction in burden

was achieved or why the increase in burden occurred. (If you need more space, provide a short summary here and elaborate in the Supporting Statement.)

We are requesting an increase in burden of 1 594 hours and $1 7 1, 170 due to implementation of these propo sed changes to the regulation.Revised 1/30 /2007 5 

### PAPERWORK REDUCTI ON ACT SUBMI SSI ON WORKSHEET

Par t I I I : I nf or mat i on Col l ect i on Request Compl et eness Check

Compl et e t hi s checkl i st pr i or t o submi t t i ng t he i nf or mat i on col l ect i on package t o t he Cl ear ance Of f i cer

. The

Cl e ar ance Of f i cer wi l l use t he i nf or mat i on cont ai ned i n t hi s checkl i st

, al ong wi t h ot her i nf or mat i on

, t o cer t i f y

t he i nf or mat i on col l ect i on pr i or t o submi ssi on t o OMB

.

The suppor t i ng st at ement ( check al l t hat appl y

):

a

. I dent i f i es t he st at ut e or r egul at i on aut hor i zi ng t he col l ect i on of t he i nf or mat i on

b

. Descr i bes ef f or t s t aken t o avoi d t he col l ect i on of si mi l ar i nf or mat i on al r eady avai l abl e

, or

col l ect ed under a di f f er ent i nf or mat i on col l ect i on

c

. Descr i bes

, i f appl i cabl e

, met hods t o mi ni mi ze t he bur den on smal l busi nesses or ot her smal l

ent i t i es

d

. I s wr i t t en usi ng pl ai n Engl i sh

, and al l t er mi nol ogy used i s unambi guous and under st andabl e t o

t hose r equi r ed t o r espond t o t he col l ect i on

e

. I ndi cat es how l ong r ecor ds speci f i ed i n t he col l ect i on ar e t o be mai nt ai ned by per sons

r equi r ed t o mai nt ai n t he r ecor ds

f

. Has dedi cat ed r esour ces t o ensur e t he pr oper use and pr ocessi ng of t he i nf or mat i on bei ng

col l ect ed t o enhanc e

( as appr opr i at e ) t he val ue of t he i nf or mat i on t o agenci es and t he publ i c

.

g

. I ndi cat es t he use of a st at i st i cal sur vey met hod ( i f appl i cabl e ) t hat pr oduces val i d and

r el i abl e r esul t s whi l e mi ni mi zi ng undue bur den

.

h

. Descr i bes t he i nt ended use of i nf or mat i on t echnol ogy t o r educe bur den and wher e possi bl e

avoi d unnecessar y syst em and t echnol ogy cost s

.Revised 1/30 /2007 6Revised 1/30 /2007 7 

### PAPERWORK REDUCTI ON ACT SUBMI SSI ON WORKSHEET

Par t I V : Cer t i f i cat i on

Cer t i f i cat i on f or Paper wor k Reduct i on Act Submi ssi o ns

On behal f of t hi s Feder al agency , 1 cer t i f y t hat t he col l ect i on of i nf or mat i on encompassed by t hi s r equest compl i es wi t h '

5 CFR 1320.9.

NOTE : The t ext of 5 CFR 1320.9, and t he r el at ed pr ovi si ons of 5 CFR 1320.8( b )(3), appear at t he end of t he i nst r uc t i ons

.

The cer t i f i cat i on i s t o be made wi t h r ef er ence t o t hose r egul at or y pr ovi si ons as set f or t h i n t he

i nst r uct i ons

.

The f ol l owi ng i s a summar y of t he t opi cs

, r egar di ng t he pr oposed col l ect i on of i nf or mat i on

, t hat t he cer t i f i cat i on cover s :

( a ) I t i s necessar y f or t he pr oper per f or mance of agency f unct i ons ;

( b ) I t avoi ds unnecessar y dupl i cat i on ;

( c ) I t r educes bur den on smal l ent i t i es ;

( d ) I t uses pl ai n

, coher ent

, and unambi guous t er mi nol ogy t hat i s under st andabl e t o r espondent s ;

( e ) I t s i mpl ement at i on wi l l be consi st ent and compat i bl e wi t h cur r ent r epor t i ng and r ecor dkeepi ng pr act i ces ;

( f ) I t i ndi cat es t he r et ent i on per i ods f or r ecor dkeepi ng r equi r ement s ;

( g ) I t i nf or ms r espondent s of t he i nf or mat i on cal l ed f or under 5 CFR 1320.8( b )(3):

( I ) Why t he i nf or mat i on i s bei ng col l ect ed ’

( i i ) Use of i nf or mat i on ;

( iii ) Bur den est i mat e ;

( i v ) Nat ur e of r esponse ( vol unt ar y

, r equi r ed f or a benef i t

, or mandat or y );

( v ) Nat ur e and ext ent of conf i dent i al i t y ; and

( vi ) Need t o di sp l ay cur r ent l y val i d OMB cont r ol number ;

( h ) I t was devel oped by an of f i ce t hat has pl anned and al l ocat ed r esour ces f or t he ef f i ci ent and ef f ect i ve

management

and use of t he i nf or mat i on t o be col l ect ed ( see not e i n I t em 19 of t he i nst r uct i ons );

( I ) I t uses ef f ect i ve and ef f i ci ent st at i st i cal sur vey met hodol ogy ; and

( j ) I t makes appr opr i at e use of i nf or mat i on t echnol ogy

.Revised 1/30 /2007 8 Si gnat ur e of Pr ogr am Of f i ci al

Pet er Tsi r i got i s

, Di r ect or

Sect or Pol i ci es and Pr ogr ams Di vi si on

Of f i ce of Ai r Qual i t y Pl anni ng and St andar ds Dat e

Si gnat ur e of Seni or Of f i ci al or desi gnee

Oscar Mor al es

, Di r ect or

Col l ect i on St r at egi es Di vi si on

Of f i ce of

Envi r onment al I nf or mat i on Dat eRevised 1/30 /2007 9 5 CFR 132 0.9 r eads “ As par t of t he agency submi ssi on t o OMB of a pr oposed col l ect i on of i nf or mat i on

, t he agency ( t hr ough t he

head of t he agency

, t he Seni or Of f i ci al or t hei r desi gnee ) shal l cer t i f y ( and pr ovi de a r ecor d suppor t i ng such cer t i f i cat i on )

t hat t he pr opo sed col l ect i on of i nf or mat i on

--

“ ( a ) i s necessar y f or t he pr oper per f or mance of t he f unct i ons of t he agency

, i ncl udi ng t hat t he i nf or mat i on t o be

col l ect ed wi l l have pr act i cal ut i l i t y ;

“ ( b ) i s not unnecessar i l y dupl i cat i ve of i nf or mat i on ot her wi se r easonabl y accessi bl e t o t he agency ;

“ ( c ) r educes t o t he ext ent pr act i cabl e and appr opr i at e t he bur den on per sons who shal l pr ovi de i nf or mat i on t o or f or t he

agency

, i ncl udi ng wi t h r espect t o smal l ent i t i es

, as def i ned i n t he Regul at or y Fl exi bi l i t y Act 5 U

. S

. C § 601(6)), t he use of

such t echni ques as :

“ (1) est abl i shi ng di f f er i ng compl i ance or r epor t i ng r equi r ement s or t i met abl es t hat t ake i nt o account t he

r esour ces avai l abl e t o t hose who ar e t o r espond ;

“ (2) t he cl ar i f i cat i on

, consol i dat i on

, or si mpl i f i cat i on of compl i ance and r epor t i ng r equi r ement s ; or col l ect i on

of i nf or mat i on

, or any par t t her eof ;

“ (3) an exempt i on f r om cover age of t he col l ect i on of i nf or mat i on

, or any par t t her eof ;

“ ( d ) i s wr i t t en usi ng pl ai n

, coher ent

, and unambi guous t er mi nol ogy and i s under st andabl e t o t hose who ar e t o r espond ;

“ ( e ) i s t o be i mpl ement ed i n ways consi st ent and compat i bl e

, t o t he maxi mum ext ent pr act i cabl e

, wi t h t he exi st i ng

r epor t i ng and r ecor dkeepi ng pr act i ces of t hose who ar e t o r espond ;

“ ( f ) i ndi cat es f or each r ecor dkeepi ng r equi r ement t he l engt h of t i me per sons ar e r equi r ed t o mai nt ai n t he r ecor ds

speci f i ed ;

“ ( g ) i nf or ms pot ent i al r espondent s of t he i nf or mat i on cal l ed f or under § 132 0.8( b )(3); [ see bel ow ]

“ ( h ) has been devel oped by an of f i ce t hat has pl anned and al l ocat ed r esour ces f or t he ef f i ci ent and ef f ect i ve management

and use of t he i nf or mat i on t o be col l ect ed

, i ncl udi ng t he pr ocessi ng of t he i nf or mat i on i n a manner wh i ch shal l enhance

,

wher e appr opr i at e

, t he ut i l i t y of t he i nf or mat i on t o agenci es and t he publ i c ;

“ ( I ) uses ef f ect i ve and ef f i ci ent st at i st i cal sur vey met hodol ogy appr opr i at e t o t he pur pose f or whi ch t he i nf or mat i on

i s t o be col l ect ed ; and

“ ( j ) t o t he maxi mum ext ent pr act i cabl e

, uses appr opr i at e i nf or mat i on t echnol ogy t o r educe bur den and i mpr ove dat a

qual i t y

, agency ef f i ci ency and r esponsi veness t o t he publ i c

. ”

NOTE : 5 CFR

1320.8( b )(3) r equi r es t hat each col l ect i on of i nf or mat i on :

“ (3) i nf or ms and pr ovi des r easonabl e not i ce t o t he pot ent i al per sons t o whom t he col l ect i on of i nf or mat i on i s addr essed

of :

“ ( I ) t he r easons t he i nf or mat i on i s pl anned t o be and / or has been used t o f ur t her t he pr oper per f or mance of t he

f unct i ons of t he a gency ;

“ ( i i ) t he way such i nf or mat i on i s pl anned t o be and / or has been used t o f ur t her t he pr oper per f or mance of t he

f unct i ons of t he agency ;Revised 1/30 /2007 10Revised 9/1/2006 1 PAPERWORK REDUCTION ACT SUBMISSION WORKSHEET

Part II: Information Collection Detail

I MPORTANT

: A separat e Part I I must be compl et ed f or each I nf ormat i on Col l ect i on ( I C ) act i vi t y associ at ed wi t h t he I CR

. I f more t han one

Part I I i s requi red

, creat e a sep arat e Part I I document f or each I C

. For more i nf ormat i on see OEI ’ s I CR websi t e at

ht t p :// i nt ranet

. epa

. gov / i cri nt ra /

. There you wi l l f i nd i nf ormat i on on compl et i ng t hi s f orm ( see OEI ’ s I CRAS i nst ruct i ons under t he Prepare

an I CR t ab ) and i nf ormat i on on how break your I CR i nt o I Cs ( see OMB ’ s ROCI S I C Q

& A under t he Downl oad Gui dance t ab ).

1. Ti t l e of I nf ormat i on Col l ect i on : Nat i onal Emi ssi on St andar ds f or Pr i mar y Al umi num Reduct i on Pl ant s (40 CFR 63, Subpart LL)

2. I s t hi s a common f orm ?

Yes

No

( Sel ect Yes t o i dent i f y f or ms t hat

EPA i s wi l l i ng t o host f or pot ent i al

use by ot her Feder al Agenci es

. ) 3. Obl i gat i on t o respond ( check one ):

Voluntar y Required to obtain or retain benefits
Mandatory

Note: Only one select

ion may be made. If multiple

cat egories apply, you must create additional ICs to

account for the burden associated with each
category. 4. Frequency of report i ng ( onl y t o be compl et ed

i f t her e ar e r epor t i ng r equi r ement s

, check al l

t hat appl y

):

Hourly
Daily
Weekly
Monthly

Year l y Every Decade
Quarterly

Semi

- Annually
Biennially

Once
Occasionally

5. CFR Citation(s) for the information collection under review (if applicable):

Title 40 Part 63 Section 84 3

- 8 44

Title Part Section

Title Part Section

Title Part SectionRevised 9/1/2006 2

6. Information Collection Instruments/Forms (if applicable) :

Form Name:

Form Number:

URL (required if electronic) :

Is this form available electronically? Yes No If yes, can this form be submitted electronically? Yes No

Form Name:

Form Number:

URL (required if electronic) :

Is this form available electronically? Yes No If yes, can this form be submitted electronically? Yes No

Form Name:

Form Number:

URL (required if electronic) :

Is this form available electronically? Yes No If yes, can this form be submitted electronically? Yes No

Attach additional sheets if necessary.

Note: Instruments/Forms must be submitted/uploaded as a separate attachment.Revised 9/1/2006 3

7. Federal Ent erpri se Archi t ect ure Busi ness Ref erence Model :

Li ne of Busi ness (

check one ) : Subf unct i on ( check one ) :

Envi r onment al Management Envi r onment al Moni t or i ng and For ecast i ng

Envi r onment al Remedi at i on

Pol l ut i on Pr e

vent i on and Cont r ol

Heal t h I l l ness Pr event i on

I mmuni zat i on Management

Publ i c Heal t h Moni t or i ng

Heal t h Car e Ser vi ces

Consumer Heal t h and Saf et y

Nat ur al Resour ces Wat er Resour ce Management

Conser vat i on

, Mar i ne and Land Management

Recr eat i onal Resour ce Management and Tour i sm

Agr i cul t ur al I nnovat i on and Ser vi ces

Not e : Most EPA I CRs wi l l be al i gned wi t h t he Envi r onment al Management FEA Li ne of Busi ness

. Ot her l i kel y cat egor i es ar e al so l i st ed

. For a

f ul l l i st i ng of t he FEA Busi ness Ref er ence Model cat egor i es and def i ni t i ons

, see :
http://www.whitehouse.gov/omb/egov/documents/FY07_Ref_Model_Mapping_QuickGuide.pdf

.

8. Pri vacy Act Syst em of Records ( i f appl i cabl e

) :

Ti t l e :

Feder al Regi st er Ci t at i on : Vol ume Page Number Publ i cat i on Dat e

9. Respondent s

Tot al Number : 15

Smal l Ent i t y Number : 0

Per cent age of r esponses col l ect ed el ect r oni cal l y : 0 Af f ect ed Publ i c ( check one ) :

I ndi vi dual s or Househol ds

Pr i vat e Sect or (

i f pr i vat e sect or

, check al l t hat appl y )

Busi ness or ot her f or

- pr of i t

Not

- f or

- pr of i t i nst i t ut i ons

Far ms

St at e

, Local

, or Tr i bal Gover nment s

Feder al Gover nment

Not e : Onl y o ne sel ect i on may be made

. I f mul t i pl e cat eg or i es appl y

,

you must cr eat e addi t i onal I Cs t o account f or t he bur den associ at ed

wi t h each cat egor y

. Sel ect i ng mul t i pl e subcat egor i es wi t hi n

“ Pr i vat e Sect or ” wi l l not af f ect t hen number of I Cs r equi r ed

.

10. Frequency : How of t en on average wi l l each respo ndent respond t o

t he I nf ormat i on Col l ect i on ?Revised 9/1/2006 4

Number of Respondent s 15 per Year

Hour Busi ness

hour

Day Busi ness

Day

Week Mont h

Decade Quar t er

Hal f

-

year Cal cul at ed Annual Frequency : 1

( r esponses per r espondent per year )

Cal cul at ed Annual Number of Responses : 15

11. Hour and Cost Burden : Ent er t he hour s and cost ( per r esponse ) br oken out b y r epor t i ng

, r ecor d keepi ng

, and t hi r d par t y di scl osur e :

Hour s per Response Tot al Annual Hour Bur den Cost per Response Tot al Annual Cost Bur den

Repor t i ng 51.8 1

, 5 53 0 0

Recor dkeepi ng 1 .15 207 4.60 825

Thi r d Par t y Di scl osur e 0 0 0 0

Tot al 53 1,760 4.60 825

I MPORTANT

: “Cost per Res ponse” and “Tot al Annual Cost Burden” shoul d i ncl ude Capi t al / St art up and O & M cost s onl y

.Revised 9/1/2006 5

12. Annual Responses and Burden Change

Tot al Request ed Pr ogr am Change

due t o New

St at ut e Pr ogr am Change

due t o Agency

Di scr et i on Change due t o

Adj ust ment i n

Agen cy Est i mat e Change due t o

Vi ol at i on of

t he PRA Cur r ent l y

Appr oved

Annual

Responses 30 30

Annual Hour

Bur den 1 ,760 1 ,760

Annual Cost

Bur den $ 1 7 0,568 $ 1 7 0,568

### 1 

## SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS: PRIMARY

ALUMINUM REDUCTION PLANTS

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection.

“ National Em ission Standards for Primary Aluminum Reduction Plants

. ” This is a new

information collection request (ICR)

, and the EPA tracking number i s 2447.01

.
(b) Short Characterization.

This ICR covers information collection requirements i n the proposed amendments to the Primary

Aluminum NESHAP ( 40 CFR part 63, subpart LL )

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

, new , or reconstructed p rimary

aluminum r eduction p lant

. Per the applicability section of subpart LL , the following affected so urces at a

primary aluminum reduction plant are covered: each new and existing pitch storage tank, potline, paste

production plant and anode bake furnace that is located at a plant site that is a major source as defined in

40 CFR 63.2. The re are 15 facilit ies currently subject to the NESHAP, all of which will be affected by

these proposed amendments. The proposed amendments would include new polycyclic organic matter

(POM) emission limits for prebake potlines, new carbonyl sulfide (COS) emission limits for potlines,

revised POM emission limits for Soderberg potlines, new POM emission limits for existing pitch storage

tanks and new requirements for periods of startup and shutdown

. T hese amendments are explained

further in the section 4 of this supporting stat ement

.

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 ) require s t he 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

HAP or m ore 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 combinatio n of HAP )

. There are no area sources subject to

subpart LL. 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

### 2



## healt h 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 account develop ments 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

whether the emission s 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 exposed to emission s 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, t he 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 effect, 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 subject 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 NESHAP General Pr ovisions

. 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 ea ch

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

delegated permitting authority can identify facilities that may not be in compliance and decide which

facili tie s, records 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.

### 3



## (b) Public Notice Requi red 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 primary aluminum

production companies and trade association 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. 70 3

- 358

- 2981

Mike P alazzolo Alcoa , Inc. 412

- 553

- 4832

Don Backfisch Noranda Aluminum, Inc. 573

- 643

- 2361

(d) Effects of Less Frequent Collection.

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

or the E PA) 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 information submitted to the Agency for which a claim of c onfidentiality 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, September 1, 1976; amended by

43 FR 39999, September 28, 197 8; 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 Respondents and the Information Requested

(a) Respondents/NAI C S Codes

. Potential respondents under s ubpart LL are owners or operators of any existing or new facility

engaged in Primary Aluminum Reduction operations

. Primary Aluminum Reduction facilities are

primarily classified under NAICS code 331312

, Primary Alumi num Production

.

The re are an estimated 15 facilities that w ould be subject to the proposed amendments to the

NESHAP

. Fourteen of these facilities manufacture primary aluminum and on e facility produces anodes

for offsite use in other primary aluminum facili ties. We are not aware of any new primary aluminum

facility being constructed and no new sources are expected during the 3-year period of this ICR.

### 4



## (b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. Attachment 1

, Information

Requirements, summarize s the data items, including recordkeeping and reporting requirements , for the

Primary Aluminum Reduction s ource c ategor y

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

amendments to the Primary Aluminum Reduction NESHAP are identified in Table 3 an d are introduced

in section 6(a).

(i i i) Summary of Requirements. The EPA is including in T able 2 an estimate of the burden

associated with performing an affirmative defense. The EPA is providing this as an illustrative example

of the potential additional administrative burden a source may incur to assert an Affirmative Defense in

response to an action to enforce the standards set forth in subpart LL

.

This illustrative estimate is not considered a duplicate estimate of cost under the General Duty to

Minimize Emissions clause under 40 CFR 63.6(e)(1)(i), which states: “At all times, the owner and

operator must operate and maintain any affected source, including associated air pollution control

equipm ent and monitoring equipment, in a manner consistent with safety and good air pollution control

practices for minimizing emissions. Determining whether such operation and maintenance procedures

are being used will be based on information available to the A dministrator which may include, but is not

limited to, monitoring results, review of operation and maintenance procedures, review of operation and

maintenance records, and inspection of the source.”

To provide the public with an estimate of the relative ma gnitude of the burden associated with an

assertion of the affirmative defense position adopted by a source, the EPA provides an administrative

adjustment to this ICR that estimates the costs of the notification, recordkeeping and reporting

requirements ass ociated with the assertion of the affirmative defense. The EPA’s estimate for the

required notification, reports and records, including the root cause analysis, associated with a single

incident totals approximately $3, 14 2 and is based on the time and effo rt required of a source to review

relevant data, interview plant employees and document the events surrounding a malfunction that has

caused an exceedance of an emission limit. The estimate also includes time to produce and retain the

records and reports f

or submission to the EPA. The EPA provides this illustrative estimate of this burden

because these costs are only incurred if there has been a violation and a source chooses to take advantage

of the affirmative defense.

In this source category, it is unlik ely that a control device malfunction would cause an

exceedence of any emission limit. For reasons explained in the FRN, we have asserted that although a

### 5



## cost for affirmative defense is possible, we believe that malfunctions are unlikely. Thus for th is sou rce

categor y

, the EPA is not assigning any burden associated with affirmative defense.

TABLE 2

. COST ESTIMATE FOR ROOT CAUSE ANALYSIS

Personnel Number of

Personnel Time Requirement

(hours) Total Hours Hourly Rate ($/hr) Total

Technical Personnel 3 6 18 9 8.20 $ 1,768

Managerial Personnel 2 6 12 114.49 $ 1,374

Total 5 30 $ 3,14 2



## 5. The Information Collected

– Agency Activities, Collection Methodology and Information

Management

(a) Agency Activities.

The Agency activities associated with the proposed am endments to the Primary Aluminum

Reduction NESHAP are provided in Table 4 and are introduced in section 6(c).

(b) Collection Methodology and Management

. Data and records maintained by the respondents are tabulated and published for use in

compliance and e nforcement programs of the delegated permitting authority

. The EPA is the permitting

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

rule. Therefore, 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, maintenance, and retrieval of compliance

data for approximatel y 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 headquarters. The EPA and its delegated a uthorities can ed it, store, retrieve and analyze

the compliance data.

(c) Small Entity Flexibility.

The Small Business Administration defines a small entity engaging in Primary Aluminum

Reduction as a firm having no more than 1

, 0 00 employees

. There are no small businesses operating

primary aluminum reduction facilities

.
(d) Collection Schedule

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

Table 3 for the Primary Aluminum Reduction S ource C atego ry.

### 6



## 6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual burden estimates for the proposed amendments to the Primary Aluminum Reduction

NESHAP are shown in Table 3

. These numbers were derived from estimates based on the EPA’s

experience wi th other standards. No burden estimates are provided for new sources because no new

facilities are expected to become affected sources during the 3

- year period of this ICR.

(b) Estimating Respondent Costs.

(i) Estimating Labor Costs

. Table 3 presents esti mated 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 Unite d States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2.

Civilian Workers, 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 $46.76 per hour for technical, $54.52 per hour for managerial

and $23.11 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 respondent labor costs are: technical at $98.20, management at

$114.49 and clerical at $48.53.

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

. C apital costs are

estimated at $500 per facility to account for storage of records. No O&M costs are associated with the

information collection requirements of the proposed amendments to the Primary Aluminum Reduction

NESHAP

. The proposed amendments w ould require affected facilities to conduct new performance

testing for POM emissions from prebake potlines

, calculate COS emissions from potlines and prepare

design reports for pitch storage tank controls

.
(i ii ) Annualizing Capital Costs

. Annualized capital c osts are approximately $55/facility or $825

for the industry

.
(iv) Affirmative Defense/Root Cause Anal ysis/Malfunction Costs

. The EPA’s estimate for a root

cause analysis is based on general experience to calculate the time and effort required of a source to

review relevant data, interview plant employees and reconstruct the events prior to a malfunction in

order to determine primary and contributing causes. The level of effort also includes time to produce and

retain the report in document form so that the source will have it available should the EPA or state

enforcement agencies ever request to review it.

### 7



## (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 EPA’ 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 4

. The Agency labor rates are from the Office of Personnel Management (OPM) 20 10 General

Schedule

, which exclu des locality rates of pay. These rates can be obtained from Salary Table 20 10

- GS

available on the OPM website, http://www.opm.gov/oca/10tables/pdf/gs_h.pdf

. The government

employee labor rates ar e $ 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 Burden and Costs

.

There are an estimated 15 existing facilities that are currently subject to the Prim ary Aluminum

Reduction NESHAP. No new major sources are expected during the next 3 years. Consequently, the

average number of primary aluminum respondents during the 3

- year period of this ICR is :

(1 respondent/facility) x ( 15 facilities ) / ( 3 years) = 5 re spondents per year

.

For the proposed amendments to the Primary Aluminum Reduction NESHAP , the components of

the total annual burden attributable to this ICR include reading the amendments to the NESHAP

, conducting the performance testing to demonstrate com pliance with the proposed emission limits and

reporting th e results of those emissions tests . 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 bottom line respondent burden hours and costs presented in Table 3 are

calculated by adding person

- hours per year down each column for technical, managerial and clerical

### 8



## staff, and by adding down the cost column. The average annual burden for t he recordkeeping and

reporting requirements in the proposed amendments t o subpart LL for the 15 existing facilities that are

subject to the Primary Aluminum NESHAP is 1 20 person

- hours

, with an annual average cost of

$ 1 1, 316 . Estimate d c apital costs to the industry for the proposed amendments are $ 7

, 500

.
(ii) The Agency tally. The average annual Federal Go vernment cost is $ 3

, 109 for 6 9 hours for the

proposed amendments to subpart LL

. The bottom line Agency burden hours and costs presented in Table

4 are cal culated 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 provides an adjustment to this ICR that estimates the costs of the notification,

recordkeeping and reporting requirements associated with the assertion of the affirmative defense. The

EPA’s estimate for the requi red notification, reports and records, including the root cause analysis,

associated with a single incident totals approximately $3, 14 2 and is based on the time and effort required

of a source to review relevant data, interview plant employees and document the events surrounding a

malfunction that has caused an exceedance of an emission limit. The estimate also includes time to

produce and retain the records and reports for submission to the EPA.

For the purpose of estimating the annual burden in this categ ory, the EPA is attributing no

instances of affirmative defense. The costs in Table 2 are illustrative of affirmative defense, which we

see sources having no need for, given the technical reasons explained in the FRN.

(g) Burden Statement

The average annu al respondent burden for the proposed amendments to the Primary Aluminum

Reduction NESHAP is estimated at 1 20 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 info rmation,

and disclosing and providing information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of

information; search data sources; complete and revi ew the collection of information; and transmit or

otherwise disclose the information.

### 9



## 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, includi ng through the use of

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

No. EPA

- HQ

- OAR

- 2011

- 0797 which is available for online viewing at http://www.regulations. gov , or

in person viewing at the Air and Radiation Docket 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 electronical ly. 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, Attenti on Desk

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

- HQ

- OAR

- 2011

- 0797 ) in any

c orrespondence.

### 10



## PART B

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

associated with the proposed rule

.

## 11

TAB LE 3

. ANNUAL RESPONDENT BURDEN AND COST

- AMENDMENTS TO PRIMARY 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

p er year (E=C*D) (F)

Management

person

- hours

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 15 60 3 6 $ 6

, 52 7

B. Required activities c (compliance testing) 106 0.67 71 

### 15 1065 5 3 107 $ 115, 844

C. Create information N/A

D. Gather existing information N/A

E. W rite report d 46 0.33 15 15 225 11 23 $ 2 4,471

5. Recordkeeping Requirements

A. Read instructions See 4A

B. Plan activities N/A

C. Implement activities (COS calculations) 1 12 12 15 180 9 18 $ 19,580

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 disclose information 1 2 2 15 30 2 3 $ 3

, 321

I. Time for audits N/A

TOTAL LABOR BURDEN AND COST (SALARY) 1

, 560 78 1 57 $ 169

, 743

TOTAL NUMBER OF ANNUAL RESPONSES 30

ANNUAL CAPITAL COSTS e $ 825

TOTAL ANNUALIZED COSTS $ 170

, 568

N/A = not applicable.

a T his ICR uses the following labor rat es : $ 114.49 for managerial labor, $ 98.20 for technical labor, and $4 8.53 for clerical labor. These rates are based on the U.S. Department of Labor,

Bureau of Labor Statistics, Occupational Employment and Wages, Ma y 20 09

.

b There are an estimated 15 existin g facilities; no new facilities are expected; the average number expected to read the rule during the 3

- yr compliance period is 15/3=5

.

c The average facility cost for polycyclic organic matter testing was calculated at 115, 844 /15 = $ 7,723

.

d 15 facilities would be required to submit a one

- time design specification f or pitch storage tank controls.

e 15 facilities would be required to provide record storage at $500/ facility, annualized at 7% for 15 years.

## 12

TABLE 4

. ANNUAL BURDEN AND COST TO THE AGENCY

- AME NDMENTS TO PRIMARY ALUMINUM NESHAP

Burden item (A)

Person

- hours

per occurrence (B)

Occurrences
per respondent (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 pitch s torage tank control system design b 4 1 4 15 60 3 6 $ 3,109

TOTAL BURDEN AND COST $ 3,109

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 technical

, and $2 5.01 (G S

- 6, Step 3) for c lerical. These rates are from the Office of Personnel Management (OPM) 20 1 0 General Schedule

, which excludes locality rates of pay

.

b Assumes Agency will review all of the annual reports

- including the polycyclic organic matter performance test reports and the pitch storage tank control design specifications.

## 13

ATTACHMENT 1. INFORMATION REQUIREMENTS

- AMENDMENTS TO PRIMARY ALUMINUM NESHA P

Requirement Citation for existing sources Citation for new sources General Provisions citation

POM limit for prebake potlines §63. 843(a)(2)(iv

- vii) §63. 844(a)(2)

Design specifications for pitch storage tanks §63. 843(d) N/A

Calculation of monthly COS emissions §63. 843(e) §63. 844(e)