Mr. XXXXXXXX , President

XXXXXXXX XXXXXXXX XXXXXXXX Re: Requirement to provide i nformation according to 42 U.S.C 7414 Dear Mr. XXXXX : Pursuant to section 114 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) is requesting that you provide the information described in Enclosure 1 and the National Emissions Inventory (NEI) spreadsheet
. At EPA, an important step in the development of regulation s involve s gathering and anal yz ing information. We are s eeking information specific to your company ’ s facilities because such information is key to understanding how an industry operates, and what facilities do and/or can do to reduce, mitigate, or eliminate air pollution. We are requesting that you send the completed surveys for all of your facilities that are in the secondary

aluminum production source category (see 40 CFR 63, subpart RRR) to us by XXXXX X, 20XX **.** The Clean Air Act (42 U.S.C. 7414 ) requires that yo u complete the enclosed surveys an d return them to us by the deadline
. The EPA issued N ational Emission S tandards for H azardous A ir P ollutants (NESHAP) for secondary

aluminum production under s ection 112 (d) of the C AA on March 23 , 200 0
. We are now in the process of collecting updated information concerning hazardous air pollutant ( HAP ) emission sources and controls in the secondary aluminum industry
. This information will be used to review, and revise as necessary , the NESHAP under section 112(d)(6) and to conduct the residual risk review under section 112(f) of the CAA. In the enclosed survey s , we request information on secondary aluminum processes, emissions, and controls. The electronic version of Enclosure 1 and the National Air Toxics Assessment (NATA)/ National Emissions Inventory (NEI) spreadsh eet are the survey forms that yo u are required to complete and return to us in **electronic format**
. If we presentl y have NATA NEI data for your facility, the excel spreadsheet will be populated with existing data for your facility
. Y o u will need to revise and update the existing data as well as complete any missing information. Enclosure 2 contains the instructions for completing Enclosures 1 and the NATA NEI spreadsheet
. Enclosure 7 is the compact disc containing the electronic forms. Using th e inform ation yo u provide to us in th i s survey , along with similar information we receive from other companies in your industry , we will determine the amount of HAP s emi tted ; the present level of emission control ; and assess what would be the environmental, energy , and economic impacts associated with installing and operating emission control techniques feasiblefor your industry
. You may respond “Not Applicable ” to questions that do not apply to your facilities. Enclosure 3 c ontains a summary of our legal auth ority in s ection 114 of the CAA to obtain the information requested in thi s survey . If you believe that providing any specific information to us would reveal a trade secret, please identify this information clearl y in your response . However, p lease do no t label your entire response “ Confidential ” if only a portion include s trade secret s . You can see in Enclosure 3 the ty pe of information that EPA may ask of yo u at a later time to prove that any information you have so identified is truly confidential. Any information determined to be a trade secret will be protected by 18 U.S.C. 1905. If you do not claim as confidential any of the information in yo ur returned survey , we can make this information available to the public without noti fying you further (40 CFR Part 2.203, September 1, 1976). Because s ection 114 of the CAA **does not allow emission data**  to be claim ed as confidential, the emission data you provide to us can be made available to the public. A detailed explanation of what we consider to be emi ssion data is contained in Enclosure 4
. We have contracted RTI International (RTI) (Contract No. EP
- D
- 06
- 118) to help us gather information about your industry
. A s noted in Enclosure 5 , we have designated RTI to be our authorized representative. Theref ore, RTI has the same rights discussed above and in Enclosure 3 as EPA has
. This means that RTI will have access to all information provided to us in your completed survey
. As a designated representative of the Agency , RTI must, by law, also abide b y the requirements of 42 U.S.C. 7414(c) in regard to the confidentiality of what you claim to be trade secrets. Enclosure 6 summarizes our policies and procedures for handling trade secret information and describes how our contractor also is required to use t he same procedures as we do. Because our contractors or other authorized representatives are required to follow the requirements in Enclosure 5 , we believe that we can ensure your rights and protect any privileged information you submit to us. A draft o f Enclosure 1 was given to representatives of your industry for their comments. We have incorporate d several of their comments and suggestions into the final version. If you have questions regarding the need for this survey or need clarification on the information we are requesting , please contact Rochelle Bo yd with EPA ’ s Office of Air Quality Planning and Standards at 919
- 541
- 1390 (e
- mail : boyd.rochelle @epa.gov). Please return the completed non - confidential survey response in electronic format to M s . B oyd at the address below by XXX XX , 20 XX
.

Rochelle Bo yd U
. S
. EPA Mailroom (D243
- 02) U .S. Environmental Protection Agency Office of Air Quality

Planning and Standards109 T.W. Alexander Drive Research Triangle Park, NC 27711 If your respon se to this information collection request includes data with a claim of confidential business information , p lease create a separate CD
- ROM containing onl y the information on the spreadsheet that is CBI
. In essence, if you do have CBI data, you will have to submit (2) separate CD
- ROM(s) ; one for the CBI version and one for the non
- CBI version
. Clearly mark the disk containing the CBI data with the words “Confidential Business In formation.” Send onl y these CBI files under separate cover to:

Roberto Morales c/o Rochelle Bo yd U.S. EPA Mailroom (C404
- 02) U.S. Environmental Protection Agency Office of Air Quality

Planning and Standards 109 T.W. Alexander Drive Research Triangle Park, NC 27711 For security of your data, EPA recommends sending your confidential files to Mr. Morales via Registered U.S. Mail using return receipt requested, Federal Express, or other method for which someone must provide a signature upon receipt. DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS I NFORMATION TO EP A. E
- mail and facsimile are not secure forms of communication and should never be used to transmit CBI
. I am sure you understand how important it is for the EPA to use the very best information available to develop the most meaningful standard. Your help in providing this information is greatl y appreciated. Sincerel y,
Peter Tsirigotis Director, Sector Policies and Programs Division Office of Air Quality

Planning and Standards
7 Enclosures Enclosure 1: Reference cop y of the Information Collection Request Questionnaire Enclosure 2 : Instructions for completing the spreadsheets for the NATA NE I and Enclosure 1 Enclosure 3 : EPA’s information gathering a uthority Enclosure 4 : Clarification of what EPA considers to be emissions dataEnclosure 5 : Summary of contractor’s authority as representative of EPA Enclosure 6 : Procedures for safeguarding CBI under the CAA Enclosure 7 : Compact Disc containing the electronic version of Enclosure 1 (Excel ® format)

and the NATA NEI populated or blank spreadsheet.

cc: XXXXX State Agency XXXXXXX U.S. Environmental Protection Agency , Region XX

OAQPS/SPPD/MMG: RBo yd D243
- 02, 541
- 1390 (RTI/MBahner

/ 541
- 6016 / 3 /23/10 )