1 SUPPORTING STATEMENT NATIONAL EMISSION STANDARDS FOR HA ZARDOUS 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 Hazardous Ai r Pollutants 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 final amendments to the National Emission Standards for Hazardous Air Pollutants (N ESHAP) for Primary Aluminum Plants (40 CFR part 63, subpart LL). The 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 pl ant 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 (except for anode bake furnaces that are not located on the same site as a primary aluminum reduction plant). There are 11 facilities currently subject to 40 CFR part 63, subpart LL, all of which will be affected by these final amendments. The final amendments 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, paste production plants and anode bake furnaces; mercury (Hg) limits for new, existing and reconstructed anode bake furnaces; arsenic, nickel and polychlor inated biphenyl (PCB) limits for new, existing and reconstructed Soderberg potlines; and new work practice standards for anode bake furnaces, paste production plants and potlines. The final amendments include a reduction of the current testing frequency for total fluoride (TF) from prebake and Soderberg potlines and POM from Soderberg potlines. The final amendments establish a polychlorinated biphenyl (PCB) limit for new, existing and reconstructed Soderberg potlines. There is only one facility affected by this limit and that facility is permanently shut down. As such, there are no costs associated with the three year period of this ICR. The information collection requirements associated with the final amendments to the NESHAP

are listed in Attachment 1.2 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 hazardous air pollutants (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 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 technologybased 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 cont rol 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, pro cesses, 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) sta ndards 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 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 recor dkeeping 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 or3 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 EPA 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 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 re vealed 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 final 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. Curt Wells The Aluminum Association, Inc. 703-358-2976 Mike Palazzolo Alcoa, Inc. 412-553-4832 Brandon Coomes Century Aluminum 273-521-7454

(d) Effects of Less Frequent Collection. If the relevant information was collected less frequently, the delegated permitting authority (state agency or the EPA Regional Administrator) 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 B-4 Confidentiality 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. Respondents under 40 CFR part 63, subpart LL are ow ners or operators of any existing or new facility engaged in primary aluminum reduction operations. Primary aluminum reduction facilities are primarily classified under NAICS c ode 331312, Primary Aluminum Production. There are an estimated 11 facilities that would be subject to the final amendments to 40 CFR part 63, subpart LL. Ten of these facilities manufacture primary aluminum and 1 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 expect ed 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 Production source category. (ii) Respondent Activities. The respondent activities that will be required by the final amendments to 40 CFR part 63, subpart LL are identified in Table 2 and are introduced in section 6(a). 5. The Information Collected–Agency Activiti es, Collection Methodology and Information Management (a) Agency Activities. The Agency activities associated with the final amendments to 40 CFR part 63, subpart LL 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 EPA 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 for5 tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. The EPA and its delegate d authorities can edit, store, retrieve and analyze

the 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 1,000 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 Production source category. 6. Estimating the Burden and Cost of the Collection (a) Estimating Respondent Burden. The annual burden estimates for the final amendments to 40 CFR part 63, subpart LL 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 40 CFR part 63, subpart LL 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 ra tes 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 la bor are taken from "Alumina and Aluminum Production and Processing – Management Occupati ons," 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, manage ment at $114.41 and clerical at $48.09.6 (ii) Estimating Capital and Operations and Maintenance (O&M) Costs . Capital costs are estimated at $500 per facility to account for storage of records. An additional capital cost of $1,000,000 is estimated for the installation of two manifold duct collection systems at one affected facility. No O&M costs are associated with the information collection requirements of the final amendments to 40 CFR part 63, subpart LL. The final amendments would require affected facilities to conduct new performance testing for POM emissions from prebake potlines; PM emissions from potlines, paste production plants and anode bake furnaces; Hg emissions from anode bake furnaces and arsenic, nickel and PCB emissions from Soderberg potlines. The final 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 $111,000. (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 Comp liance 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 associ ated 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 la bor costs are: clerical at $25.25/hour, technical at $46.67/hour and management at $62.90/hour.7 (d) Estimating the Respondent Universe and Total Burden and Costs

. There are an estimated 11 existing facilities that are currently subject to 40 CFR part 63, subpart LL. No new major sources are expected during the next 3 years. Consequently, the average number of primary aluminum respondents during the 3-year pe riod of this ICR is 3.67 respondents per year, forone-time requirements (depending on facility operations) and 20 to 22 respondents per year for semiannual requirements (depending on facility operations). For the final amendments to 40 CFR part 63, subpart LL, 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 final 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 co lumn 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 final amendments to 40 CFR part 63, subpart LL for the 11 existing facilities that are subject to 40 CFR part 63, subpart LL is 33 person-hours, with an annual average cost of about -$95,000. Estimated capital costs to the industry for the final amendments are about $1,005,500 (this total includes new manifold costs that affect only one facility). (ii) The Agency tally. The average annual Federal Government cost is $14,587 for 321 hours for the final 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 final amendments to 40 CFR part 63, subpart LL is estimated at 33 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 time8 needed to review instructions; develop, acquire, install 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 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 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 17 th Street, NW, Washington, DC 20503, Attention

Desk Officer for EPA. Please include the releva nt Docket 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 final rule.10TABLE 2. ANNUAL RESPONDENT BURDEN AND COST - AMENDMENTS TO PRIMARY ALUMINUM NESHAPaaThis 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. Department of Labor, Bureau of LaborStatistics, Occupational Employment and Wages, May 2013.bThere are an estimated 11 existing facilities; no new facilities are expected.cThe average cost for new emission limit testing is offset by the final reductions in testing frequency for existing TF standards in the current rule.d11 facilities are required to submit a one-time design specification for pitch storage tank controls.e11 facilities are required to provide recordstorage at $500/ facility, annualized at7% for 15 years, one facility is required to install manifold sampling systems at atotal cost of $1 million annualized at 7% for15 years.11TABLE 3. ANNUAL BURDEN AND COST TO THE AGENCY -AMENDMENTS TO PRIMARY ALUMINUM NESHAPaThis ICR uses the following average hourlylabor 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 rates of pay.12ATTACHMENT 1. INFORMATION REQUIREMENTS- AMENDMENTS TO PRIMARY ALUMINUM NESHAPRequirement Citation for existingsources Citation for new sources General Provisions citationPOM limits for potlines§63.843(a)(2) §63.844(a)(2)PM limits for 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)PCB limits for Soderberg potlines§63.843(a)(6) §63.844(a)(6)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)Hg limits for anode bake furnaces§63.843(c)(4) §63.844(c)(4)Design specifications for pitch storage tanks§63.843(d) N/ACalculation of monthly COS emissions§63.843(e) §63.844(e)