1 SUPPORTING STATEMENT NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLU TANTS: 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 R eduction Plants.” This is a new information collection request (ICR), and the EPA t racking 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 o f any existing, new, or reconstructed primary aluminum reduction plant. Per the applicability sec tion of 40 CFR part 63, subpart LL, the following affected sources at a primary aluminum reduction pl ant are covered: each new and existing pitch storag e tank, potline, paste production plant and anode bak e furnace that is located at a plant site that is a major

source as defined in 40 CFR 63.2. There are 13 faci lities currently subject to the NESHAP, all of whic h will be affected by these proposed amendments. The proposed amendments would include polycyclic organic matter (POM) emission limits for new, exist ing and reconstructed prebake potlines, revised POM limits for new, existing and reconstructed Sode rberg potlines, carbonyl sulfide (COS) emission limits for new, existing and reconstructed potlines , POM emission limits for existing pitch storage ta nks, particulate matter (PM) emission limits for new, ex isting and reconstructed potlines, PM emission limi ts for new, existing and reconstructed paste productio n plants, PM emission limits for new, existing and reconstructed anode bake furnaces, arsenic limits f or new, existing and reconstructed Soderberg potlin es, nickel limits for new, existing and reconstructed S oderberg potlines and new work practice standards f or anode bake furnaces, paste production plants and po tlines. The proposed amendments also include a reduction of the current testing frequency for tota l 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 regulat ion under CAA section 112(c). A major source is a2

stationary source that emits or has the potential t o emit more than 10 tons per year (tpy) of any sing le 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 an d does not have the potential to emit more than 10 tpy of any single HAP or more than 25 tpy of any combin ation of HAP). There are no area sources subject to 40 CFR part 63, subpart LL. For major sources, thes e technology-based standards must reflect the maximum degree of emission reductions of HAP achiev able (after considering cost, energy requirements, and non-air quality health and enviro nmental impacts) and are commonly referred to as maximum achievable control technology (MACT) standa rds. CAA section 112(d)(6) requires the EPA to review these technology-based standards and to revi se them “as necessary (taking into account developments in practices, processes, and control t echnologies)” no less frequently than every 8 years . In addition, section 112(f) of the CAA requires the EP A to determine for source categories subject to certain CAA section 112(d) standards whether the em issions 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 life time 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 EP A must promulgate residual risk standards for the sou rce category (or subcategory) as necessary to provi de 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, i f 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 A dministrator to confirm the compliance status of sources subject to NESHAP, identify any new or r econstructed 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 recordkeepin g 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 autho rity (state agency, or Regional Administrator if there is no delegated state agency) to ensure th at the standards and other requirements are being

achieved. Based on review of the recorded informati on at the site and the reported information, the3

delegated permitting authority can identify facilit ies that may not be in compliance and decide which facilities, records or processes may need inspectio n. 3. Nonduplication, Consultations and Other Collection Criteria (a) Nonduplication. A computer search of the EPA’s ongoing ICRs reveale d 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 ru le-related ICR. (c) Consultations. The proposed amendments were developed in consultat ion with individual primary aluminum production companies and trade associations. The no n-EPA persons consulted on the information

collection activities are identified in Table 1.

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLE CTION 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 freq uently, the delegated permitting authority (state or the EPA) will not be reasonably assured that a f acility is in compliance with the standards. (e) General Guidelines. None of the guidelines in 5 CFR 1320.6 are being ex ceeded. (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 fo rth 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, Septe mber 28, 1978; 44 FR 17674, March 23, 1979). (g) Sensitive Questions. This section is not applicable because this ICR doe s not involve matters of a sensitive nature. 4. The Respondents and the Information Requested (a) Respondents/NAICS Codes.4

Potential respondents under 40 CFR part 63, subpart LL are owners or operators of any existing or new facility engaged in Primary Aluminum Reducti on operations. Primary Aluminum Reduction facilities are primarily classified under NAICS cod e 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 prim ary aluminum and one facility produces anodes for offsite use in other primary aluminum facilitie s. We are not aware of any new primary aluminum facility being constructed and no new sources are e xpected during the 3-year period of this ICR. (b) Information Requested. (i) Data Items, Including Recordkeeping Requirement s. 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, Col lection 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 in troduced 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 delegate d permitting authority. The EPA is the permitting authority until the State agency is delegated autho rity to implement the final amendments to the rule. Therefore, information contained in any report subm itted to the Regional Administrator will be entered into the Air Facility System (AFS), which is operat ed and maintained by the EPA’s Office of Compliance. AFS is the EPA’s database for the colle ction, maintenance, and retrieval of compliance data for approximately 125,000 industrial and gover nment-owned facilities. The EPA uses the AFS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. The EPA and its deleg ated authorities can edit, store, retrieve and anal yze the data. (c) Small Entity Flexibility.5

The Small Business Administration defines a small e ntity engaging in Primary Aluminum Reduction as a firm having no more than 1,000 emplo yees. There are no small businesses operating primary aluminum reduction facilities. (d) Collection Schedule

. The specific frequency for each information collect ion activity within this request is shown in Table 2 for the Primary Aluminum Reduction Source C ategory. 6. Estimating the Burden and Cost of the Collection (a) Estimating Respondent Burden. The annual burden estimates for the proposed amendm ents to the Primary Aluminum Reduction

NESHAP are shown in Table 2. These numbers were der ived from estimates based on the EPA’s experience with other standards. No burden estimate s 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 propo sed 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 ba sed 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 La bor 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 l abor 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 comp ensation of $22.90/hour. These rates represent salaries plus fringe benefits and do not include th e 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 lab or costs are: technical at $76.59, management at $114. 41 and clerical at $48.09. (ii) Estimating Capital and Operations and Maintena nce (O&M) Costs . Capital costs are estimated at $500 per facility to account for stora ge 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 affec ted facilities to conduct new performance6

testing for POM emissions from prebake potlines, PM emissions from potlines, PM emissions from paste production plants, PM emissions from anode ba ke furnaces, arsenic emissions from Soderberg potlines, and nickel emissions from Soderberg potli nes. The proposed amendments also include a reduction of the current testing frequency for TF e missions from prebake and Soderberg potlines and POM emissions from Soderberg potlines. (iii) Annualizing Capital Costs . Annualized capital costs are approximately $55/fa cility or $715 for the industry. (c) Estimating Agency Burden and Cost

. Because the information collection requirements wer e developed as an incidental part of standards development, no costs can be attributed t o the development of the information collection requirements. Because reporting and recordkeeping r equirements on the part of the respondents are required under the operating permits rules in 40 CF R part 70 or part 71 and the part 63 NESHAP General Provisions, no operational costs will be in curred by the Federal Government. Publication and distribution of the information are part of the Com pliance Data System, with the result that no Federa l costs can be directly attributed to the ICR. Examin ation of records to be maintained by the respondent s will occur incidentally as part of the periodic ins pection of sources that is part of the EPA’s overal l compliance and enforcement program, and, therefore, is not attributable to the ICR. The only costs tha t the Federal government will incur are user costs as sociated with the analysis of the reported informat ion, as presented in Table 3. The Agency labor rates are from the Office of Perso nnel Management (OPM) 2014 General Schedule, which excludes locality rates of pay. The se 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/ho ur for clerical (GS-6, Step 3), $29.17 for technical (GS-1 2, Step 1) and $39.31/hr for management (GS-13, Step 5). These rates were increased by 60 percent t o 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 Bu rden 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 duri ng the 3-year period of this ICR is 4.00 to 4.337

respondents per year, for one-time requirements (de pending on facility operations) and 12 to 13 respondents per year for annual requirements (depen ding on facility operations). For the proposed amendments to the Primary Aluminum Reduction NESHAP, the components of

the total annual burden attributable to this ICR in clude reading the amendments to the NESHAP, conducting the performance testing to demonstrate c ompliance 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 eac h column for technical, managerial and clerical staff, and by adding down the cost column. The aver age annual burden for the recordkeeping and reporting requirements in the proposed amendments t o 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 in dustry for the proposed amendments are $6,500. (ii) The Agency tally. The average annual Federal Government cost is $907 2 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 perso n-hours per year down each column for technical, managerial and clerical staff and by adding down th e 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 I CR. (g) Burden Statement The average annual respondent burden for the propos ed amendments to the Primary Aluminum Reduction NESHAP is estimated at 32 person-hours. Burden means the total time, effort or financial re sources 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, in stall and utilize technology and systems for the purposes of collecting, validating and verifying in formation, processing and maintaining information, and disclosing and providing information; adjust th e existing ways to comply with any previously applicable instructions and requirements; train per sonnel to be able to respond to a collection of8

information; search data sources; complete and revi ew 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 OM B control number. The OMB control numbers for the EPA’s regulations in 40 CFR part 63 are listed in 4 0 CFR part 9. To comment on the Agency’s need for this informatio n, the accuracy of the provided burden estimates and any suggestions for minimizing respon dent burden, including through the use of automated collection techniques, the EPA has establ ished a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2011-0797 which is available for onl ine viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket a nd Information Center in the EPA Docket Center (EPA/DC), Room 3334, EPA WJC West Building, 1301 Co nstitution 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) 566-17 42. An electronic version of the public docket is

available at http://www.regulations.gov. This site can be used to submit or view public comm ents, access the index listing of the contents of the pub lic docket and to access those documents in the pub lic docket that are available electronically. When in t he system, select “search,” then key in the Docket ID

Number identified above. Also, you can send comments to the Office of Inform ation and Regulatory Affairs, Office of Management and Budget, 725 17 th Street, NW, Washington, DC 20503, Attention

Desk Officer for EPA. Please include the relevant D ocket ID Number (EPA-HQ-OAR-2011-0797) in any correspondence.9

PART B This section is not applicable because statistical methods are not used in data collection associated with the proposed rule.10TABLE 2. ANNUAL RESPONDENT BURDEN AND COST - AMENDMENTS TO PRIMARY ALUMINUM NESHAPa(A) (B) (C) (D) (E) (F) (G) (H)Person-hours peroccurrenceNo. ofoccurrences perrespondentPerson-hours perrespondent(C=A*B)Respondents peryearTechnical personhours per year(E=C*D)Managementperson-hours peryearClerical personhours per year(E*0.1)Costa, $1. ApplicationsN/A2. Surveys and Studies N/A3. Acquisition, Installation, and Utilization ofTechnology and SystemsN/A4. Reporting RequirementsA. Read instructionsb4 1 4 4.33 17.33 0.87 1.73$1,510B. Required activitiesc(compliance testing)-$93,23113.00-$1,212,003C. Create information N/AD. Gather existing information N/AE. Write reportd46 1 46 4.00 184.00 9.20 18.40$16,0305. Recordkeeping RequirementsA. Read instructions See 4AB. Plan activitiesN/AC. Implement activities (COS calculations) 1 12 12 12.00 144.00 7.20 14.40$12,545D. Develop record system N/AE. Time to enter information See 4CF. Time to train personnel N/AG. Time to adjust existing ways to comply withpreviously applicable requirementsN/AH. Time to transmit or disclose information 1 2 2 13.0026.00 1.30 2.60$2,265I. Time for auditsN/ATOTAL LABOR BURDEN AND COST (SALARY)371.33 18.57 37.13 -$1,179,653TOTAL NUMBER OF ANNUAL RESPONSESANNUAL CAPITAL COSTSe$715TOTAL ANNUALIZED COSTS-$1,178,938Burden item29aThis 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 basedon the U.S. Department of Labor, Bureau of LaborStatistics, Occupational Employment and Wages, May2013.bThere are an estimated 13 existing facilities; no new facilities are expected.cThe 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. The weighted cost impact on afacility basis for compliance testing is estimatedat -$93,231.d12 facilities would be required to submit a one-time design specification for pitch storage tank controls.e13 facilities would be required to provide recordstorage at $500 per facility, annualized at 7% for15 years.11TABLE 3. ANNUAL BURDEN AND COST TO THE AGENCY - AMENDMENTS TO PRIMARY ALUMINUM NESHAP(A) (B) (C) (D) (E) (F) (G) (H)Personhours peroccurrenceOccurrencesperrespondentEPApersonhours/year(C=A*B)Facilitiesper yearTechnicalpersonhours/year(E=C*D)Managementpersonhours/year(F=0.05*E)Clericalpersonhours/year(G=0.1*E)Costa, $Report Review:Review pitchstorage tankcontrol systemdesign10 1 10 4.33 43.33 2.17 4.33$2,268Reviewperformancetest reports10 1 10 13.00 130.00 6.50 13.00$6,804TOTALBURDENAND COST173.33 8.67 17.33 $9,072Burden itemaThis 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, Step 3) for clerical. These ratesare from the Office of Personnel Management (OPM) 2014 General Schedule, which excludes locality ratesof pay.12ATTACHMENT 1. INFORMATION REQUIREMENTS - AMENDMENTSTO PRIMARY ALUMINUM NESHAPRequirement Citation for existing sources Citationfor new sources General Provisions citationPOM 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/ACalculation of monthly COS emissions§63.843(e) §63.844(e)