Summary of Comments and Responses for the Information Collection Request for National

Emissions Standards for Hazardous Air Pollutants (NESHAP) for Secondary Aluminum Production Residual Risk and Technology Review (RTR); EPA ICR Number 240 0.01 (75 FR 4352 0, July 26, 2010)

Metals and Minerals Group Sector Policies and Program Division Office of Air Quality Planning and Standards U.S. Environment al Protection Agency

October 6, 20 10INTRODUCTION

On July 26, 2010, EPA published a notice in the Federal Register (75 FR 43520) announcing their intent to submit a request to the Office of Management and Budget (OMB) for a new Information Collection Request (I CR). The I CR will be used to collect certain information from second ary aluminum production facilities for the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Secondary Aluminum Production Residual Risk and Technology

Review (RTR); EPA I CR Number 24001.01. The notice included a request for comments on specific aspects of the proposed I CR; we received comments from one commenter in response to the notice. The c omments were submitted by

Robert P. Strieter, VP, Environment Health and Safety , The Aluminum Association. The comments are located in docke t number EPA - HQ - OAR - 2010 - 0469 - 0007. The EPA responses to the comments follow the comments below, as appropriate. SUMMARY OF COMMENTS AND RESPONSES Comment: Requests for information relating to collocated (non - subpart RRR regulated) sources of emissio ns are outside the scope of the RTR project and are not justified in the Supporting Statement. The commenter cited requests for information pertaining to HAP emissions, control devices, discharge characteristics, criteria air pollutants and energy usage for these sources. Response: During the RTR processes, EPA examines the risks from the entire “facility”, where the “facility” includes all HAP - emitting operations within a contiguous area and under common control. In other words, for each facility EP A examines the HAP emissions not only from the source category

of interest, but also emissions of HAP from all other emission sources at the facilit y. EPA analyzes risks due to the inhalation of HAP that are emitted “facility- wide” for the populations res iding within 50 km of each facility . For these facility - wide risk analy ses, the modeled source category risks will be compared to the facility - wide risks to determine the portion of facility - wide risks that could be attributed to the secondary aluminum pr oduction source category . We are requesting these data in order to conduct an accurate facility - wide risk anal ys is. The facility

wide risk anal ys es will also be used to determine the potential for any environmental justice issues that might be associated with each category as required under Executive Order 12898. EPA evaluates the distribution of HAP - related cancer and non - cancer risks across different social, demographic, and economic groups within the populations living near the facilities where these source categories are located. We are requesting these data in order to conduct an accurate facility - wide risk analy sis. In addition to the facility - wide risk anal ys is, we are requesting information on criteria pollutants from all air emission sources co nsistent with EPA’s new multi - pollutant sector based strategy . Sector - based approaches are based on integrated assessments that consider multiple pollutants in a comprehensive and coordinated manner to manage emissions and CAA requirements. The benefits o f multi pollutant and sector - based anal ys es and approaches include the ability to identify

optimum control strategies, considering feasibility , costs, and benefits across the different pollutant t ypes while streamlining administrative and compliance comple xities and reducing conflicting and redundant requirements. Obtaining facility - wide emissions are needed to determin e if an y co benefits have been achieved concerning the reduction of non - HAP emissions resulting from theimplementation of the NESHAP. Thi s could improve the implementation of an y future control

strategies for this sector. EPA has revised the supporting statement to include justification for requesting these data. In addition, EPA has revised the questionnaire, as suggested b y the commenter , to eliminate the request for respondents to reenter criteria pollutant data if this data is included in emissions inventory reports. Comment: The proposed survey data form is extremel y long and the specified 60 day response time is inadequate. Th e commenter requested that this be extended to 120 day s. Response: EPA has agreed to complete the RTR, and propose and promulgate a rule in accordance with a court - ordered deadline. Because of the time required to review and anal yz e the responses, inclu ding sufficient time for quality assurance, EPA must limit the response time to 60 day s. It should also be noted that respondents also have had time to review the draft questionnaire to determine in advance the t ypes of information that will be requested. Comment: The commenter has noted several instances where the questionnaire is ambiguous or potentially

confusing. Response: EPA has revised the questionnaire on the basis of this comment to clarify the questions and terminology to convey the inform ation requested more precisely .