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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 Emission Standards for Primary Aluminum Reduction Plants.” This is a new 

information collection request (ICR), and the EPA tracking number is 2447.01. 

(b) Short Characterization. 

This ICR covers information collection requirements in the proposed amendments to the Primary 

Aluminum NESHAP (40 CFR part 63, subpart LL). 

The potential respondents are owners or operators of any existing, new, or reconstructed primary 

aluminum reduction plant. Per the applicability section of 40 CFR part 63, subpart LL, the following 

affected sources 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. There are 13 facilities currently subject to the NESHAP, all of which 

will be affected by these proposed amendments. The proposed amendments would include polycyclic 

organic matter (POM) emission limits for new, existing and reconstructed prebake potlines, revised 

POM limits for new, existing and reconstructed Soderberg potlines, carbonyl sulfide (COS) emission 

limits for new, existing and reconstructed potlines, POM emission limits for existing pitch storage tanks, 

particulate matter (PM) emission limits for new, existing and reconstructed potlines, PM emission limits 

for new, existing and reconstructed paste production plants, PM emission limits for new, existing and 

reconstructed anode bake furnaces, arsenic limits for new, existing and reconstructed Soderberg potlines, 

nickel limits for new, existing and reconstructed Soderberg potlines and new work practice standards for 

anode bake furnaces, paste production plants and potlines. The proposed amendments also include a 

reduction of the current testing frequency for total fluoride (TF) from prebake and Soderberg potlines

and POM from Soderberg potlines. 

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 Clean Air Act (CAA) requires the EPA to establish NESHAP for both major 

and area sources of HAP that are listed for regulation under CAA section 112(c). A major source is a 
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stationary source that emits or has the potential to emit more than 10 tons per year (tpy) of any single 

HAP or more than 25 tpy of any combination of HAP. An area source is a stationary source that is not a

major source (i.e., an area source does not emit and does not have the potential to emit more than 10 tpy 

of any single HAP or more than 25 tpy of any combination of HAP). There are no area sources subject to

40 CFR part 63, 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 health and environmental impacts) and are commonly referred to as 

maximum achievable control technology (MACT) standards. CAA section 112(d)(6) requires the EPA to 

review these technology-based standards and to revise them “as necessary (taking into account 

developments in practices, processes, and control technologies)” no less frequently than every 8 years. In 

addition, section 112(f) of the CAA requires the EPA to determine for source categories subject to 

certain CAA section 112(d) standards whether the emissions limitations provide an ample margin of 

safety to protect public health. For MACT standards for HAP “classified as a known, probable, or 

possible human carcinogen” that “do not reduce lifetime excess cancer risks to the individual most 

exposed to emissions from a source in the category or subcategory to less than 1-in-1 million,” the EPA 

must promulgate residual risk standards for the source category (or subcategory) as necessary to provide 

an ample margin of safety to protect public health. In doing so, the EPA may adopt standards equal to 

existing MACT standards, if the EPA determines that the existing standards are sufficiently protective. 

The EPA must also adopt more stringent standards, if necessary, to prevent an adverse environmental 

effect, but must consider cost, energy, safety and other relevant factors in doing so. 

Certain records and reports are necessary for the Administrator to confirm the compliance status 

of sources subject to NESHAP, identify any new or reconstructed sources 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 CAA (42 U.S.C. 7414) and set out in the

part 63 NESHAP General Provisions. The recordkeeping and reporting requirements for operating 

permits (i.e., title V permits) are contained in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63 and 70 or

71, the owner or operator must keep each record for 5 years following the date of each occurrence, 

measurement, maintenance, corrective action, report or record. 

(b) Use/Users of the Data.

The information will be used by the delegated authority (state agency, or Regional Administrator 

if there is no delegated state 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 
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delegated permitting authority can identify facilities that may not be in compliance and decide which 

facilities, 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. 

(b) Public Notice Required Prior to ICR Submission to OMB. 

This section is not applicable because this is a rule-related ICR. 

(c) Consultations. 

The proposed amendments were developed in consultation with individual primary aluminum 

production companies and trade associations. The non-EPA persons consulted on the information 

collection activities are identified in Table 1. 

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES 

Contact Organization Telephone No. 

Charles Johnson, Jr. The Aluminum Association, Inc. 703-358-2981 

Mike Palazzolo 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 (state 

or the EPA) will 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 confidentiality is made will be 

safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart BConfidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 

43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).

(g) Sensitive Questions.

This section is not applicable because this ICR does not involve matters of a sensitive nature. 

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.
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Potential respondents under 40 CFR part 63, subpart 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 Aluminum Production. 

There are an estimated 13 facilities that would be subject to the proposed amendments to the 

NESHAP. Twelve of these facilities manufacture primary aluminum and one facility produces anodes 

for offsite use in other primary aluminum facilities. 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. 

(b) Information Requested.

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

Requirements, summarizes the data items, including recordkeeping and reporting requirements, for the 

Primary Aluminum Reduction source category. 

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

amendments to the Primary Aluminum Reduction NESHAP are identified in Table 2 and are introduced 

in section 6(a). 

5. The Information Collected–Agency Activities, Collection Methodology and Information 

Management

(a) Agency Activities.

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

Reduction NESHAP are provided in Table 3 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 enforcement programs of the delegated permitting authority. The EPA is the permitting 

authority until the State agency is delegated authority to implement the final amendments to the rule.

Therefore, information 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 approximately 125,000 industrial and government-owned facilities. The EPA uses the AFS for 

tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional

offices and EPA headquarters. The EPA and its delegated authorities can edit, store, retrieve and analyze 

the data. 

(c) Small Entity Flexibility.
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The Small Business Administration defines a small entity engaging in Primary Aluminum 

Reduction as a firm having no more than 1,000 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 2 for the Primary Aluminum Reduction Source Category. 

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

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

facilities are expected to become affected sources during the 3-year period of this ICR. 

(b) Estimating Respondent Costs. 

The information collection activities for the proposed Primary Aluminum Reduction NESHAP 

are presented in Table 2. 

(i) Estimating Labor Costs. Table 2 presents estimated costs for the required data collection 

activities. Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data. 

Technical, management, and clerical average hourly rates for private industry workers were taken from 

the United States Department of Labor, Bureau of Labor Statistics, Occupational Employment and 

Wages, May 2013 available at http://www.bls.gov/oes/current/naics4_331300.htm. Wages for technical 

labor are based on "Alumina and Aluminum Production and Processing – Engineers," with a total 

compensation of $36.47/hour. Wages for management labor are taken from "Alumina and Aluminum 

Production and Processing – Management Occupations," with a total compensation of $54.48/hour. 

Wages for clerical labor are based on "Alumina and Aluminum Production and Processing – Production, 

Planning, and Expediting Clerks," with a total compensation of $22.90/hour. 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 $76.59, management at $114.41 and clerical at $48.09. 

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. Capital 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 would require affected facilities to conduct new performance 
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testing for POM emissions from prebake potlines, PM emissions from potlines, PM emissions from 

paste production plants, PM emissions from anode bake furnaces, arsenic emissions from Soderberg 

potlines, and nickel emissions from Soderberg potlines. The proposed amendments also include a 

reduction of the current testing frequency for TF emissions from prebake and Soderberg potlines and 

POM emissions from Soderberg potlines. 

(iii) Annualizing Capital Costs. Annualized capital costs are approximately $55/facility or $715 

for the industry. 

(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 will 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 sources 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 will incur are user costs associated with the analysis of the reported information, 

as presented in Table 3. 

The Agency labor rates are from the Office of Personnel Management (OPM) 2014 General 

Schedule, which excludes locality rates of pay. These rates can be obtained from Salary Table 2014-GS 

available on the OPM website, http://www.opm.gov/policy-data-oversight/pay-leave/salarieswages/salary-tables/pdf/2014/GS_h.pdf. The government employee labor rates are $15.78/hour for 

clerical (GS-6, Step 3), $29.17 for technical (GS-12, Step 1) and $39.31/hr for management (GS-13, 

Step 5). These rates were increased by 60 percent to include fringe benefits and overhead. The fullyburdened wage rates used to represent Agency labor costs are: clerical at $25.25/hour, technical at 

$46.67/hour and management at $62.90/hour. 

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

There are an estimated 13 existing facilities that are currently subject to the Primary 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 4.00 to 4.33 
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respondents per year, for one-time requirements (depending on facility operations) and 12 to 13 

respondents per year for annual requirements (depending on facility operations). 

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 compliance with the proposed emission limits, 

reporting the results of those emissions tests, and complying with all other monitoring, recordkeeping

and reporting activities 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 2 are 

calculated by adding person-hours per year down each column for technical, managerial and clerical 

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

reporting requirements in the proposed amendments to 40 CFR part 63, subpart LL for the 13 existing 

facilities that are subject to the Primary Aluminum NESHAP is 32 person-hours, with an annual average 

cost of -$90,800. Estimated capital costs to the industry for the proposed amendments are $6,500. 

(ii) The Agency tally. The average annual Federal Government cost is $9072 for 199 hours for the 

proposed amendments to 40 CFR part 63, subpart LL. The bottom line Agency burden hours and costs 

presented in Table 3 are calculated by adding person-hours per year down each column for technical, 

managerial and clerical staff and by adding down the cost column. 

(iii) Variations in the annual bottom line. This section does not apply since no significant 

variation is anticipated. 

(f) Reasons for Change in Burden. 

This section does not apply because this is a new ICR. 

(g) Burden Statement 

The average annual respondent burden for the proposed amendments to the Primary Aluminum 

Reduction NESHAP is estimated at 32 person-hours. 

Burden means the total time, effort or financial resources expended by persons to generate, 

maintain, retain or disclose or provide information to or for a Federal agency. This includes the time

needed to review instructions; develop, acquire, install and utilize technology and systems for the 

purposes of collecting, validating and verifying information, processing and maintaining information, 

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 
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information; search data sources; complete and review the collection of information; and 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 currently valid OMB control number. The OMB control numbers for the 

EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9. 

To comment on the Agency’s need for this information, the accuracy of the provided burden 

estimates and any suggestions for minimizing respondent burden, including through the use of 

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

No. EPA-HQ-OAR-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), Room 3334, EPA WJC West Building, 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) 566-1742. An electronic version of the public docket is 

available at http://www.regulations.gov. This site can be used to submit or view public comments, 

access the index listing of the contents of the public docket and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in the Docket ID 

Number identified above. Also, you can send comments to the Office of Information and Regulatory 

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention 

Desk Officer for EPA. Please include the relevant Docket ID Number (EPA-HQ-OAR-2011-0797) in 

any correspondence. 
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PART B

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

associated with the proposed rule. 
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TABLE 2. ANNUAL RESPONDENT BURDEN AND COST - AMENDMENTS TO PRIMARY ALUMINUM NESHAP a

(A) (B) (C) (D) (E) (F) 

Person-hours per 

occurrence

No. of 

occurrences per 

respondent

Person-hours per 

respondent 

(C=A*B)

Respondents per 

year

Technical personhours per year 

(E=C*D)

Management 

person-hours per 

year

Cleric

hour

(E

1. Applications N/A2. Surveys and Studies N/A3. Acquisition, Installation, and Utilization of Technology and Systems N/A4. Reporting Requirements

A. Read instructionsb 4 1 4 4.33 17.33 0.87 

B. Required activitiesc (compliance testing) -$93,231 13.00 

C. Create information N/AD. Gather existing information N/AE. Write reportd 46 1 46 4.00 184.00 9.20 

5. Recordkeeping Requirements

A. Read instructions See 4AB. Plan activities N/A

C. Implement activities (COS calculations) 1 12 12 12.00 144.00 7.20 

D. Develop record system N/AE. Time to enter information See 4CF. Time to train personnel N/AG. Time to adjust existing ways to comply with previously applicable requirements N/AH. Time to transmit or disclose information 1 2 2 13.00 26.00 1.30 I. Time for audits N/A

TOTAL LABOR BURDEN AND COST (SALARY) 371.33 18.57 

TOTAL NUMBER OF ANNUAL RESPONSESANNUAL CAPITAL COSTSe 

TOTAL ANNUALIZED COSTS 

Burden item

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a This ICR uses the following labor rates: $114.41 for managerial labor, $76.59 for technical labor, and $48.09 for clerical labor. These rates are based on the U.S. Departm

Statistics, Occupational Employment and Wages, May 2013. 

b There are an estimated 13 existing facilities; no new facilities are expected. c The average cost for POM, PM, nickel and arsenic testing is offset by the proposed reductions in testing frequency for existing TF and POM standards in the current rule. 

facility basis for compliance testing is estimated at -$93,231. 

d 12 facilities would be required to submit a one-time design specification for pitch storage tank controls. e 13 facilities would be required to provide record storage at $500 per facility, annualized at 7% for 15 years. 
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TABLE 3. ANNUAL BURDEN AND COST TO THE AGENCY - AMENDMENTS TO PRIMARY ALUMINUM NESHAP 

(A) (B) (C) (D) (E) (F) (G) 

Personhours per 

occurrence

Occurrences 

per 

respondent

EPA 

personhours/year 

(C=A*B)

Facilities 

per year

Technical 

personhours/year 

(E=C*D)

Management 

personhours/year 

(F=0.05*E)

Clerica

person

hours/ye

(G=0.1*

Report Review:

Review pitch storage tank 

control system design

10 1 10 4.33 43.33 2.17 4.33 

Review performance test reports 

10 1 10 13.00 130.00 6.50 13.00 

TOTAL BURDEN AND COST

173.33 8.67 17.33 

Burden item

a This ICR uses the following average hourly labor rates: $62.90 for managerial (GS-13, Step 5), $46.67 (GS-12, Step 1) for technical, and $25.25 (GS-6

are from the Office of Personnel Management (OPM) 2014 General Schedule, which excludes locality rates of pay. 
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ATTACHMENT 1. INFORMATION REQUIREMENTS - AMENDMENTS TO PRIMARY ALUMINUM NESHAP

Requirement Citation for existing sources Citation for new sources General Prov

POM limits for prebake potlines §63.843(a)(2) §63.844(a)(2) PM limits for prebake potlines §63.843(a)(3) §63.844(a)(3) Nickel limits for Soderberg potlines §63.843(a)(4) §63.844(a)(4) Arsenic limits for Soderberg potlines §63.843(a)(5) §63.844(a)(5) PM limits for paste production plants §63.843(b)(4) §63.844(b)(2) PM limits for anode bake furnaces §63.843(c)(3) §63.844(c)(3) Design specifications for pitch storage tanks §63.843(d) N/A Calculation of monthly COS emissions §63.843(e) §63.844(e)