**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 
**NESHAP for Secondary Aluminum Production**  **(40 CFR Part 6 3**  **, Subpart RRR** **) (Renewal)**
**1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Secondary Aluminum Production (40 CFR Part 6 3 , Subpart RRR) (Renewal) , EPA ICR Number 1894.0 7 , OMB Control Number 2060

- 0433 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Secondary Aluminum Productio n were proposed on February 11, 1999, promulgated on March 23, 200 0 , and final rule amendments published on December 19 , 200 5 . These regulations apply to component processes at secondary

aluminum production plants that are major sources and area sources , including aluminum scrap shredders, thermal chip dryers, scrap dryers/delacquering kilns/decoating kilns, secondary aluminum processing units (SAPUs) composed of in

- line fluxers and process furnaces (including both melting and holding furnaces of various c onfigurations), sweat furnaces dross

- only furnaces, and rotary

dross coolers, commencing construction, or reconstruction after the date of proposal. As a result of a 2002 rule amendment, owners and operators of certain aluminum die casting facilities, aluminum foundries, and aluminum extrusion facilities were excluded from the rule coverage. Respondents do not include the owner or operator of any facility that is not a major source of hazardous air pollutant (HAP) emissions, except for those that are area sources of dioxins/furans emissions. This information is being collected to assure compliance with 40 CFR part 63, subpart RRR. In general, all NESHAP standards require initial notifications, performance tests , and periodic reports by

the owners/operators of the affected facilities

. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to either the delegated state or local authority . In the event that there is no such delegated authority, the reports are sent directl y to the U.S. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facility

at each plant site and that each plant site has only o ne respondent (i.e., the owner/operator of the plant site).2

Over the next three ye ars, an average of 1,834 respondents (81 major sources and 1, 753 sweat furnaces) per year will be subject to the standard, and 70 additional sweat furnaces per ye ar will become subject to the standard. We do not estimate any additional new major sources over the three

- ye ar period of this ICR.
All of the secondary

aluminum facilities in the United States are owned and operated by the secondary aluminum industry

(the “Affected Public”). None of the facilities in the United States are owned b y state, local, tribal or the Federal government. They are all privately owned , for

-profit businesses. The burden to the “Affe cted Public” may b e found below in Table 1: Annual Respondent Burden and Cost

− NESHAP for Secondary Aluminum Production (40 CFR Part 6 3 , Subpart RRR) (Renewal) . The Federal government burden associated with the review of reports submitted by

the respondent is shown b elow in Table 2: Average Annual EPA Burden and Cost

− NESHAP for Secondary

Aluminum Production (40 CFR Part 6 3 , Subpart RRR) (Renewal)

. The Office of Management and Budget (OMB) approved the currentl y active Information Collection Request ( IC R) without any “Terms of Clearance.”
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner or operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) s ample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from facilities in secondary aluminum manufacturing cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source cat egory at 40 CFR part 6 3 , subpart RRR

.3

**2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affecte d facility’s i nitial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properl y installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures, and for compliance determinations.
**3. Non**
**- duplication, Consultations, and Ot**  **her Collection Criteria** The requested recordkeeping and reporting are required under 40 CFR part 6 3 , subpart RRR

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional of fice. Otherwise, the information is sent directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency c an be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this IC R was published in the Federal Register ( 77 FR 47631 ) on August 9 , 2012

. N o comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency has consulted industry experts and internal data sources to project the numb er of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting4

provisions in the standard, is the Online Tracking Information Sy stem (O TIS ) which is operated and maintained b y EPA's Office of Compliance. OTI S is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry i s based on our consultations with the Agency ’s internal industry experts. Consultations with industry representatives were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standards to facilitate industry compliance. Industry

representatives were also provided an opportunity

to comment on the ICR burden, including the size, growth, and other characteristics of the regulated industry . For this renewal, we contacted : 1) the Aluminum Association, at (703) 358

- 2960 ; and 2) the North American Die Casting Association (NADCA) , at (202) 842

- 4864. It is our polic y to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. In this case, no comments were received. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. **3(e) General Guidelines** These reporting or recordkeeping requirements do not violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- year statute of limitations on which the permit program is based. Th e retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non

- comp liance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or non existence of essential records. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality i s made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality

of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674,5

March 23, 1979). **3(g) Sensitive Questions** The reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are secondary aluminum production facilities

. The United States Standard Industrial Classification (SI C) codes for the respondents affected b y the standards, which correspond to the North American Industry Classification System (NAI CS) codes, are listed below for this source category

. **Standard (40 CFR,**  **Pa rt**  **63, Subpart**  **RRR) SIC Codes**  **NAICS Codes** Secondary

Smelting and Alloying of Aluminum 3341, 3399 331314 Primary Aluminum Production 3334 331312 Aluminum Sheet, Plate, and Foil Manufacturing 3353 331315 Aluminum Extruded Product Manufacturing 3354 331316 Other Aluminum Rolling and Drawing 3355 331319 Aluminum Die

- Casting Foundries 3363 331521 Aluminum Foundries (except Die

- Casting) 3365 331524 **4(b) Information Requested (i) Data Items**  In this ICR, all the data that is recorded or reported is required b y the NESHAP for Secondary

Aluminum Production (40 CFR P art 6 3 , S ubpart RRR). A source must make the following reports:
**Notifications** Initial notification 63.9(b)(1)

- (2) Intention to construct/reconstruct 63.9(b)(5 ), 63.1515 (a) (4) Initial performance test and visible emission observations 63.10(d)(2) Anticipated and actual date of startup 63.1515(a)(3) Reschedule initial performance test 63.7(b)(2) Special compliance obligations for a new source 63.1515(5) Demonstration of continuous monitoring systems 63.9(g)6 **Notifications** Opacity or visible emissions for major sources 63.10(d)(3), 63.1515(a)(6) Notification of compliance status 63.9(h), 63.1515(b) Periodic startup, shutdown, malfunction reports 63.10(d)(5)(i) Operation, maintenance, and monitoring plan for each emission unit to be approved b y the permitting authority 63.6(e)(1)

- (2) Semiannual report 63.10(e), 63

. 1516(b) A source must keep the following records: **Recordkeeping** Startup, shutdown, malfunction periods where the continuous monitoring system is inoperative 63.10(b)(2) Emission test results and other data needed to determine emissions 61. 13 (g) All reports and notifications 63.10(b) Record of applicability 63.10(b)(3) Records of sources with continuous monitoring systems 63.10(3) Records are required to be retained for five years 63.10(b)(1), 63.1517 Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically . However, electronic reporting s ys tems are not widel y used. At this time, it is estimated that 10 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate continuous parameter monitors (e.g. temperature monitors), continuous opacity monitors, flow monitors and bag leak detectors, if applicable. Perform initial performance test Reference Methods 1, 2, 3, 4, 5, 9, 23, 25A, 26A, test and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above.7 **Respondent Activities** Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information

. Transmit, or otherwise disclose the information. Currently , sources are using monitoring equipment that provides parameter data in an automated way (e.g., continuous parameter monitoring s ys tem). Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Acti vities** 
EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online tracking Information Sy stem ( OTI S )

. **5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated . Performance test reports are used b y the Agency to dis cern a source’s initial capability to compl y with the emission standard and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S , which is operated and8

maintained by

the EP A O ffice of Compliance. OTI S is EPA ’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices, and EPA headquarters. EPA

- delegated Authorities can edit, store, retrieve and anal yz e the data. The records required b y this regulation must be retained by the owner or operator for five ye ars. **5(c) Small Entity Flexibility** The majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements neede d to ensure compliance and, therefore, cannot reduce them further for small entities. T o the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedul e**  The specific frequency

f or each information collection activity w ithin this request is shown below in Table 1: Annual Respondent Burden and Cost

− NESHAP for Secondary Aluminum Production (40 CFR Part 6 3 , Subpart RRR) ( Renewal )

. **6. Estimating the Burden and Cost of the Collection**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized h eadings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not c onduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from th ese recordkeeping and reporting requirements is estimated to be 101 , 856 (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previously approved ICR, and any comments received.9

**6(b) Estimating Respondent Costs (i) Estimating Labor Costs** 
This I CR uses the following labor rates: Managerial $ 121.44 ($ 57.83 + 110%) Technical $ 100.23 ($ 47.73 + 110%) Clerical $50.51 ($ 24.05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by o ccupational and industry group .” The rates are from column 1, “ Total c ompensation .” The rates have been increa sed by 110 percent to account for the benefit packages available to those employed by private industry

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

costs associated with the information collection activities in the subject standard are both labor costs , which are addressed elsewhere in this ICR , and the costs associated with continuous monitoring. Th e capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation and**  **Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Start up Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)
Bag leak detectors $29,786 0 $0 $5,250 1 27 $141,750 Flow meters 2 $3,000 0 $0 $0 0 $0 Tem perature mo nitors 3 $1,200 70 $84,000 $0 0 $0 Continuous opacity monitors 4 $36,000 0 $0 $7,500 0 $0
**TOTAL $84,000**  **$141,750** 1 Assume that 34 percent of major sources (or 27 respondents) will use bag leak detectors on fabric filters with an average cost to industry at $29,786. The actual cost of the bag leak detectors depends on the number of probes on the unit, and O&M costs for bag leak detectors is approximately $5,250. 2 All chlorine injection systems already have chlorine flow meters and the operation and maintenance costs are negligible. 3 Tem perature monitors will be installed at ne w s weat furnaces (70 per year) at a cost of $1 ,200. The O&M costs for temperatures monitors are negligible.10

4 Sources with fabric filters will be complying with the monitoring requirements through the use of a bag leak detector or visible emissions observations and not continuous opacity monitors. The total capital/startup costs for this ICR are $84,000. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $141,750. This is the total of column G.
The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the I CR is estimated to be $ 22 5 , 750

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost** The only costs to the A gency

are those costs associated with anal ys is of the reported information. EPA ’s overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents , periodic inspection of sources of emissions , and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 741 , 216

. This cost is based on the average hourl y labor rate as follows: Managerial $ 62.27 (GS

- 13, Step 5, $ 38.92 + 60%) Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%) Clerical $2 5.01 (GS

- 6, Step 3, $1 5

. 63 + 60%) These rates are from the Office of Personnel Management (OPM) , 2012 General Schedule , which excludes locality , rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to government emplo ye es. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

− NESHAP for Secondary Aluminum Productio n (40 CFR Part 63, Subpart RRR) ( Renewal )

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 1, 764 existing respondents will be subject to the standard. It is estimated that an additional 70 respondent per year will become subject. The overall average number of respondents, as shown in the table below, is 1, 834 per year. The number of respondents i s calculated using the following table that addresses the three ye ars covered b y this ICR.11 **Number of Respondents**

Year (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 7 0 1, 694 0 0 1, 764 2 7 0 1, 764 0 0 1, 834 3 7 0 1, 834 0 0 1, 904 Average 7 0 1, 764 0 0 1, 834
Column D is subtracted to avoid double

- counting respondents . As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 1, 834

. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Responses E=(BxC)+D Notification of applicability 70 1 0 70 Notification of construction/reconstruction 0 0 0 0 Notification of actual startup 0 0 0 0 Notification of special compliance requirements 0 0 0 0 Notification of performance test 0 1 0 0 Notification of compliance status 81 1 0 81 Waiver application 0 1 0 0 Semiannual reports 1, 764 2 0 3, 528 Startup, shutdown, malfunction report 2 1 0 2 Total 3, 681
The number of Total Annual Responses is 3, 681

. The total annual labor costs are $ 9 , 862 , 781 . Detail s regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

− NESHAP for Secondary Aluminum Production (40 CFR Part 63, Subpart RRR) ( Renewal )

. **6(e) Bottom Line Burden Hours Burden Hours and Cost Tables**
The detailed bottom line burden hours and cost calculations for the respondents and the12

Agency are shown in Tables 1 and 2, respectivel y, and summarized below

. **(i) Respondent Tally** The total annual labor hours are 101 , 856 at a cost of $9,862,781

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

− NESHAP for Secondary

Aluminum Production (40 CFR Part 63, Subpart RRR) ( Renewal )

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 2 8 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $ 22 5,750

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally**
The average annual Agency b urden and cost over next three ye ars is estimated to be 1 6 , 448 labor hours at a cost of $ 74 1 ,2 16

. See T able 2 : Average Annual EPA Burden and Cost

− NESHAP for Secondary

Aluminum Production (40 CFR Part 63, Subpart RRR) ( Renewal )

. **6(f) Reasons for Change in Burden**  There is an adjustment increase in the total estimated burden as currently identified in the OMB Inventory

of Approved Burdens. This increase is not due to any program changes. The change in the burden and cost estimates oc curred because the estimated average number of annual respondents has increased. Additionally , the revised burden and cost estimates reflect updated labors rates available from the Bureau of Labor Statistics

. **6(g) Burden Statement** The annual public repo rting and recordkeeping burden for this collection of information is estimated to average 2 8 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining informati on, 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 th e 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 valid OMB Control Number. The OMB Control Numbers for EPA ’ s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided13

burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 20 12

- 0 505

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically . When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 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

- 17 52 , and the te lephone number for the docket center is (202) 566

- 17 52 . 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 EPA Docket ID Number EPA

- HQ

- OECA

- 20 12

- 0 505 and OMB Control Number 2060

- 0 43 3 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.**Table 1: Annual Respondent Burden and Cost**

**– NESHAP for**  **Secondary Aluminum Production (40 CFR Part 6**  **3 , Subpart** 

**RRR )**  **(Renewal)**

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

**No. of occurrences**  **per respondent**  **per year (C)** 

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

**Respondents per year**  **a (E)** 

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

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

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

**Total Cost Per year**  **b**

1. Applications N/A 2. Surveys and studies N/A 3. Acquisition, installation, and utilization c of technology and systems 54 1 54 70 3,780 189 378 $420,924.36 4. Reporting requirements a. Read instructions d 0.13 1 0.13 70 9.1 0 0.46 0.91 $1,013.34 b. Required activities Initial performance test e, f 24 1 24 0 0 0 0 $0 Repeat performance test e, f 24 0.20 4.8 0 0 0 0 0 $0 Operating, maintenance and monitoring plan e, f 32 1 32 70 2,240 112 224 $249,436.66 Startup, shutdown, malfunction (SSM) plan g 32 1 32 70 2,240 112 224 $249,436.66 c. Create information See 4B d. Gather existing information See 4B e. Write report Notification of applicability e, f 2 1 2 70 140 7 14 $15,589.79 Notification of construction/reconstruction N/A Notification/report of actual startup N/A Notification of special compliance Requirements N/A Notification of performance test e 2 1 2 0 0 0 0 $0 Notification of compliance status e 4 1 4 81 324 16.2 32.4 $36,079.23 Waiver application h 2 1 2 0 0 0 0 $0 Report of performance test See 4B Semiannual reports i 8 2 16 1, 764 28,224 1, 411 .2 2, 822 .4 $ 3,142,901.87 SSM report j 8 1 8 2 16 0.8 1.6 $1,781.69 **Subtotal for Reporting Requirements**  **42,519 $4,117,163.58** 15

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

**No. of occurrences**  **per respondent**  **per year (C)** 

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

**Respondents per year**  **a (E)** 

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

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

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

**Total Cost Per year**  **b**

5 . Recordkeeping requirements a. Read instructions 4 1 4 81 324 16.2 32.4 $36,079.23 b. Plan activities See 4E c. Implement activities See 4B d. Develop record system N/A e. Time to enter/transmit information Records of all information required by the standards N/A Major sources k 1.5 52 78 81 6,318 315.9 631.8 $703,545.00 Sweat furnaces l 0.5 52 26 1, 683 4 3 , 758 2, 187 .9 4, 375 .8 $4,872,700.53 f. Time to train personnel m 4 1 4 70 280 14 28 $31,179.58 g. Time to adjust existing ways to comply with previous applicable requirements N/A
h. Time to disclose information New sources n 0.25 2 0.5 70 35 1.75 3.5 $3,897.45 All sources o 0.25 2 0.5 1, 764 8 82 4 4

. 1 8 8 .2 $98,215.68 i. Time for audits N/A **Subtotal for Recordkeeping Requirements 59,33**  **7 $5,745,617.47** 
**TOTAL LABOR BURDEN AND COST (rounded)**  **101 ,**  **8 5**  **6 $9,862,781** 

**Assu mpti**  **ons:** a We have assumed that the average number of respondents that will be subject to this rule will be 1, 764 . There are approximately 1, 683 sweat furnaces and 8 1 major sources that are currently subject to the rule. It is estimated that there will be an additional 70 new sweat furnaces subject to the dioxins/furans requirements of the rule based on the number of new sweat furnaces meeting the requirements over the thre e year period of the ICR. There will be no additional new major sources over the three

- year period of this ICR. b This ICR uses the following labor rates : $ 121.44 per hour for Executive, Administrative, and Managerial labor; $ 100.23 per hour for Technic al labor, and $ 50.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bu reau of Labor Statistics, March 20 12 , Table 2. Civilian Workers, by o ccupational and industry group

. The rates are from column 1, “ Total c ompensation .” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that it will take each new respondent 54 hours to complete the task. This burden cost is as sociated with the mo nitoring of all control equipment16

ensuring that respondents of new sweat furnaces meet the required specifications of this subpart. d We have assumed that it will take each respondent 0.13 hours to read instructions. e We have assumed that all existing sources are in com pliance with the initial rule requirements. I t is further assumed that new sweat furnaces will co mp ly by meeting the equipment specifications rather than by conducting performance tests. Respondents that are major sources are required to demonstrate initial compliance with the applicable emission limit, equipment, work practice, or operational standard for affected source or emission unit and report results in the notification of com pliance status report. f Since we have assumed that there will be no new sources over the next three

- year period of this ICR, there will be no new sources conducting initial performance tests. We have determined that respondents of new sweat furnaces will not be required to conduct emis sions testing to show compliance with the emission limit, since it was determined that sweat furnaces sold in the United States now have an afterburner installed and meet the design residence time of 0.8 seconds or greater and an operating tem perature of 1 600 o F or greater. All ne w respondents are required to submit for approval an operation, maintenance and monitoring plan for affected sources. g We have assumed that respondents of sweat furnaces may submit with the notification of compliance report information on the manufacturers specifications and the SSM plan h It is assumed that there will be no new sources requiring a waiver from the performance test requirements. i It is assumed that each respondent will take 8 hours to w rite semiannual report of excess emissions or no excess emissions. j It is assumed that two major sources will have a startup, shutdown, malfunction occurrence per year that is not managed accor ding to plan. k It is assumed that it will take 1.5 hours for major source respondents to enter and transmit records. l It is assumed that it will take 0.5 hours for existing sweat furnaces respondents to enter and transmit records.
m We have assumed that it will take 4 hours to train new sweat furnaces employees.
n We have ass umed that it will take 0.25 hours to each new sweat furnaces respondent to disclose information.
o We have assumed that it will take 0.25 hours for each respondent to disclose information.**Table 2: Average Annual EPA Burden and Cost** 
**- NESHAP for**  **Secondary Aluminum Production (40 CFR Part 6**  **3 , Subpart** 

**RRR )**  **(Renewal)**

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per plant**  **per year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E) Technical**  **person**   ** hours per** **year (E=CxD)**  **(F)**

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

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

**Cost, $ b** 

Initial performance tests 40 1.4 56 0 0 0 0 $0 Report performance test including retesting c 48 1 48 0 0 0 0 $0 Notification of applicability 0.5 1 0.5 70 35 1.75 3.5 $1, 813.78 Notification of constructio n/reconstruction N/A Notification of actual startup N/A Notification of special compliance re quirements N/A
Notification of performance test 2 1 2 0 0 0 0 $0 Notification of com

pliance status d 2 1 2 70 140 7 14 $ 7,255.14 Report of performance test c 40 1 40 0 0 0 0 $0 Repeat of performance test report c 40 1 40 0 0 0 0 $0 Semiannual reports e 4 2 8 1, 764 1 4 , 11 2 705 .6 1 ,411 .2 $731,317.71 Startup, shutdown, malfunction report f 8 1 8 2 16 0.8 1.6 $829.16 Subtotals Labor Burden and cost 1 4 , 303 715 .15 1, 430 .3 $741,215.79 **TOTAL ANNUAL BURDEN AND COST (rounded)**  16,448 $ 741,216

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to this rule will be 1,764. There are approximately 1, 683 sweat furnaces and 81 major sources that are currently subject to the rule. It is estimated that there will be an additional 70 new sweat furnaces subject to the dioxins/furans requirements of the rule based on the number of new sweat furnaces meeting the requirements over the three year period of the ICR. There will be no a dditional new major sources over the three

- year period of this ICR. b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for governme nt overhead expenses: $ 62.27 Managerial rate (GS

- 13, Step 5, $ 3 8

. 92 x 1.6), $ 46.21 Technical rate (GS

- 12, Step 1, $ 2 8.88 x 1. 6), and $ 25.01 Clerical rate (GS

- 6, Step 3, $1 5

. 63 x 1.6). These rates are from the Office of Personnel Management (OPM) 2012 Ge neral Schedule , which excludes locality rates of pay. c We have assumed that all existing responde nt are in com pliance with the initial rule requirements. I t is further assumed that ne w sweat furnaces will com ply b y meetin g the equipment specification than by conducting performance test. d We have assumed that it will take 2 hours for each respondent to com plete notification of compliance status.
e We have assumed that each existing respondent will take 4 hours two times per year to complete the semiannual reports. f We have assumed that two major sources will have a startup, shutdown, malfunction oc currence that is not managed according to plan.