SUPPORTING STATEMENT

FOR OMB REVIEW OF EPA ICR No. 2400.01:

INFORMATION COLLECTION REQUEST FOR SECONDARY ALUMINUM 

PRODUCTION NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR 

POLLUTANTS (NESHAP) RISK AND TECHNOLOGY REVIEW (RTR)

Sector Policies and Programs Division

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

June 30, 2010
2

SUPPORTING STATEMENT

INFORMATION COLLECTION REQUEST FOR SECONDARY ALUMINUM 

PRODUCTION NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR 

POLLUTANTS RESIDUAL RISK AND TECHNOLOGY REVIEW 

Part A of the Supporting Statement

1. Identification of the Information Collection

(a) Title of the Information Collection 

“Information Collection Request for Secondary Aluminum Production National Emission 

Standards for Hazardous Air Pollutants (NESHAP) Residual Risk and Technology Review 

(RTR).” This is a new information collection request (ICR).

(b) Short Characterization

This information collection is being conducted by EPA’s Office of Air and Radiation 

(OAR) to assist the EPA Administrator, as required by sections 112(d)(6), and 112(f) of the 

Clean Air Act (CAA), as amended, to determine the current affected population of secondary

aluminum production processes and to reevaluate emission standards for this source category. 

The information from this ICR would also be made available to the public.

This is a one-time information collection. Currently, information necessary to identify

secondary aluminum production facilities is available from EPA’s National Emissions Inventory

(NEI). The NEI does not contain all of the information (equipment, capacity, materials 

processed, emissions collection and control systems, regulatory alternatives used, and emission 

test data) necessary to characterize secondary aluminum production NESHAP affected sources 

for purposes of regulatory analyses. Although some of the needed information may be included 

in Title V or state air emission permits, most permits do not contain all of the information needed

and are not readily available from any single source. Furthermore, there are no readily available 

sources for previously conducted performance test results that will provide data for emissions of 

the variety of pollutants under consideration. To obtain this information, EPA is soliciting 

information with a survey, under authority of CAA section 114, from all affected units. EPA 

intends to administer the survey in electronic (spreadsheet) format. The survey will be sent to all

companies that own or operate secondary aluminum manufacturing facilities.

The EPA estimates the cost to industry of the electronic information collection 

(gathering, entering, and quality assuring (QA) of data submitted in response to the survey) will 
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be 36,248 hours and $3,429,747, which includes $1,200 in operation and maintenance (O&M) 

costs for mailing survey responses to EPA. 

2. Need for and Use of the Collection

(a) Need/Authority for the Collection

The secondary aluminum production source category includes any establishment using 

clean charge, aluminum scrap, or dross from aluminum production, as the raw material and 

performing one or more of the following processes: scrap shredding, scrap 

drying/delacquering/decoating, thermal chip drying, furnace operations (i.e., melting, holding, 

sweating, refining, fluxing, or alloying), recovery of aluminum from dross, in-line fluxing, or 

dross cooling. A secondary aluminum production facility may be independent or part of a 

primary aluminum production facility. For purposes of this subpart, aluminum die casting 

facilities, aluminum foundries, and aluminum extrusion facilities are not considered to be 

secondary aluminum production facilities if the only materials they melt are clean charge, 

customer returns, or internal scrap, and if they do not operate sweat furnaces, thermal chip 

dryers, or scrap dryers/delacquering kilns/decoating kilns. The federal emission standard that is

the subject of this information collection is the National Emission Standards for Hazardous Air 

Pollutants for Secondary Aluminum Production (40 CFR part 63, subpart RRR).

The existing subpart RRR NESHAP regulates HAP emissions from facilities that are 

major sources of HAP that operate aluminum scrap shredders, thermal chip dryers, scrap 

dryers/delacquering kilns/decoating kilns, group 2 furnaces, sweat furnaces, dross only furnaces, 

rotary dross coolers, and secondary aluminum processing units (SAPUs). SAPUs include group 

1 furnaces and in-line fluxers. Area sources of HAP are regulated only with respect to emissions 

of dioxins/furans (D/F) from thermal chip dryers, scrap dryers/delacquering kilns/decoating 

kilns, sweat furnaces, and SAPUs.

Section 112(f)(2) of the CAA directs EPA to conduct risk assessments on each source 

category subject to maximum achievable control technology (MACT) standards and determine if 

additional standards are needed to reduce residual risks. The section 112(f)(2) residual risk 

review is to be done within 8 years after promulgation. Section 112(d)(6) of the CAA requires 

EPA to review and revise the MACT standards, as necessary, taking into account developments 

in practices, processes, and control technologies. The section 112(d)(6) technology review is to 
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be done at least every 8 years. The NESHAP for Secondary Aluminum Production (40 CFR part 

63, subpart RRR) was first promulgated in 2000. 

The data used as the basis for the originally promulgated secondary aluminum production 

NESHAP are over 15 years old. The Agency is aware that significant changes have been made 

in the intervening years in the number of affected facilities, in industry ownership practices, and 

in emission collection and control configurations. Further, in light of the statutory requirements 

for reviewing emission standards under CAA section 112, the Agency has concluded that 

obtaining updated information will be important to informing its decisions on the secondary

aluminum production NESHAP RTR.

Additional facility-specific information is needed to better characterize emission sources, 

refine the risk analysis, and develop revisions to the NESHAP, as appropriate. An update of the 

2005 National Air Toxics Assessment (NATA)/National Emissions Inventory (NEI) data sets 

and more specific information needed for further rulemaking would be derived from the ICR. 

Information collected directly from companies owning or operating secondary aluminum 

production facilities will have the greatest practical utility for purposes of performing the RTR as 

information from the affected industry will contain the most up-to-date, accurate, and reliable 

equipment and operational data for each facility. The ICR will request information for current 

equipment information and emissions from the most recent years of production, and therefore, 

will not suffer from the considerable “lag time” that can be associated with different permit 

review cycles (e.g., where the currently available inventory does not yet reflect recent changes in 

equipment).1

CAA section 114(a) states that the Administrator may require any owner or operator 

subject to any requirement of the 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) sample 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 

 

1There is a “lag time” associated with compiling large State or national emission inventories. For example, an 

updated version of the NEI database is compiled every three years, but the information contained in the NEI may be 

based on prior years if states do not submit current data. There can also be a “lag time” associated with posting of 

recent permits to State websites (particularly if permits are only posted every 5 years as they are reviewed). 
5

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 reasonably require.

(b) Use/Users of the Data

As mentioned previously, the data used for the originally promulgated NESHAP are 

incomplete, outdated and do not adequately reflect changes in emissions collection and control 

configurations that have occurred since promulgation of the MACT standards. The MACT 

standards contain a number of compliance alternatives to allow for a variety of equipment

configurations and process changes to be used in meeting the emission standards. At present, the 

EPA does not have a database reflecting the post-MACT configurations of secondary aluminum 

production affected sources and air pollution control systems. It is essential for the EPA to have 

updated information to use in the regulatory analyses required under CAA sections 112(d) and 

112(f)(2). The data would also allow the Agency to evaluate compliance options for startup and 

shutdown periods. 

The data collected will be used to update facility information and equipment 

configuration, develop new estimates of the population of affected units, and identify the control 

measures and emission limits being used for compliance with the existing NESHAP. This 

information, along with existing permitted emission limits will be used to establish a baseline for 

purposes of the regulatory reviews. The emissions test data collected will be used to verify the 

performance of existing control measures, examine variability in emissions, evaluate emission 

limits, and to determine the performance of superior control measures that may be considered for 

purposes of reducing residual risk. Emissions data may also be used along with process and 

emission unit details to consider subcategories for further regulation and to estimate the 

environmental and cost impacts associated with any regulatory options considered. 

In addition to informing the RTR regulatory analyses for the secondary aluminum 

production industry, it is EPA’s intent that the NATA NEI updates supplied through this 

information collection be used in future versions of the NATA NEI and its successor, the 

Emissions Inventory System (EIS). The NEI is used by EPA, States, and the public for a variety 

of purposes including tracking of national trends in emissions of criteria and hazardous air 

pollutants. More information in the NEI can be found at http://www.epa.gov/air/data/neidb.html.
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The non-confidential information collected with this ICR would also be available to the 

public, including aluminum industry trade groups that may find the information useful for their 

ongoing data gathering, analyses, and publications. In addition, such trade groups may wish to 

use the data collected to review and verify EPA’s regulatory conclusions. 

3. Non-duplication, Consultations, and Other Collection Criteria 

(a) Non-duplication 

The Agency recognizes that some of the information requested in the information 

collection effort may already be included in the submittals made by individual companies, 

pursuant to State and national emission inventories, operating permits applications, initial 

notification forms, and compliance reports. However, the complete extent of the data fields 

requested under this survey is not available in any consistent or usable format. Additionally, 

these sources do not provide detailed emissions test data. As mentioned previously, there is a lag 

time associated with State and national emission inventories, and permit review cycles. There is 

also a lag time associated with obtaining emission test reports from State agencies (i.e., agencies 

may be reluctant to release emission test results they have not yet processed). The EPA’s 

proposed information collection seeks up-to-date equipment configuration and operational data 

for the most recent years of production. Although some State permits are provided to the public 

as searchable portable document format files (pdfs), many States do not provide electronic 

versions of their issued Title V permits. Even when the permit is available, the unit-specific 

operating data are often not contained within the permit. Some of the initial notifications and

compliance reports submitted are available in hard-copy only, whereas only the facility-level 

information (facility name, location, contact) is available in an electronic format. In order to 

address startup and shutdown issues, the Agency has obtained semi-annual compliance reports 

for secondary aluminum production processes and found the reports to contain a widely varying 

level of detail. Such variation in the level of detail of permits and compliance reports means that 

it would be extremely time consuming for the Agency to mine the level of process detail needed 

for regulatory analyses from existing documents (assuming that these documents were readily 

available to EPA), and that significant data gaps would remain even after data from existing 

documents were compiled. Emissions test reports are often retained as hard copies by State 

agencies and thus are not readily available for all facilities. 
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To summarize, the information requested relevant to the current (post-MACT) equipment

configuration and operation, regulatory alternatives, emissions data, and effectiveness of various 

control systems at removing HAP is not readily available from other sources. In the absence of 

an industry data collection, the EPA would be forced to try an obtain permits, compliance 

reports, and emissions test reports from States; extract information from these reports (which 

vary in detail); and then to fill data gaps where information is not available from the reports 

obtained. This process of acquiring and mining data from existing reports would require more 

time than an industry data collection, and ultimately can be expected to yield incomplete 

information. Information collected directly from companies operating secondary aluminum 

production processes would provide the most timely and complete post-MACT data set with the 

greatest practical utility for purposes of performing the RTR reviews that are due to be 

completed under CAA sections 112(d) and (f)(2). 

(b) Public Notice Required Prior to ICR Submission to OMB

This ICR is being submitted for public review as required by the Paperwork Reduction 

Act of 1995 (PRA) and the subsequent rule issued by the Office of Management and Budget 

(OMB) on August 29, 1995 (60 FR 44978). EPA will address public comments before 

submitting the ICR to OMB.

(c) Consultations

Feedback was received from the Aluminum Association and the Institute of Scrap 

Recycling Industries regarding the scope of the secondary aluminum production industry survey. 

An opportunity for detailed comments on the electronic survey will be provided by the Federal 

Register notice concerning the availability of the ICR for public review and comment.

(d) Effects of Less Frequent Collection

This ICR will require the owner/operator of each secondary aluminum production facility

to complete an electronic update of their 2005 National Air Toxics Assessment (NATA) NEI 

data set to be used for RTR purposes. In addition, facilities will be asked to complete an 

electronic survey of general facility information (production processes and capacities), 

equipment details, permit limits, emission control measures, and emissions test data (previously 

conducted tests only). EPA expects the information requested in this survey to be a one-time 

effort.
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(e) General Guidelines

None of these reporting or recordkeeping requirements violate any of the regulations 

established by OMB at 5 CFR part 1320, section 1320.5

(f) Confidentiality

Respondents will be required to respond under the authority of CAA section 114. If a 

respondent believes that disclosure of certain information requested would compromise a trade 

secret, it should be clearly identified as such and will be treated as confidential until and unless it 

is determined in accordance with established EPA procedure as set forth in 40 CFR Part 2 not to 

be entitled to confidential treatment. 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–Confidentiality of Business Information (see 40 CFR 2). Any 

information subsequently determined to constitute a trade secret will be protected under 18 

U.S.C. 1905. If no claim of confidentiality accompanies the information when it is received by 

EPA, it may be made available to the public without further notice (40 CFR 2.203, September 1,

1976). Because CAA section 114(c) exempts emission data from claims of confidentiality, the 

emission data provided may be made available to the public. Therefore, emissions data should 

not be marked confidential. A definition of what EPA considers emissions data is provided in 40 

CFR 2.301(a)(2)(i).

(g) Sensitive questions

This section is not applicable because this ICR will not involve matter of a sensitive 

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Respondents affected by this action are owners/operators of secondary aluminum 

production facilities. In the U.S., there are approximately 400 secondary aluminum production

facilities including approximately 100 major sources of HAP and 300 area sources of HAP. 

Major sources are currently regulated for emissions of particulate matter (PM) as a surrogate for 

particulate metal HAP, hydrogen chloride, dioxins and furans (D/F), and total hydrocarbon 

(THC) as a surrogate for organic HAP other than D/F. Area sources are regulated only for D/F. 

Approximately 200 companies operate secondary aluminum production facilities with an average 

of approximately two facilities per company. 
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The North American Industry Classification System (NAICS) codes for respondents affected by

the information collection include 331314 for secondary smelting and alloying of aluminum as 

well as secondary aluminum production facilities that are collocated at primary aluminum 

production facilities (331312); aluminum sheet, plate and foil manufacturing facilities (331315); 

aluminum extruded product manufacturing facilities (331316); other aluminum rolling and 

drawing facilities (331319); aluminum die casting facilities (331521); aluminum foundry

facilities (331524); and sweat furnaces which can be included in various NAICS categories 

including, but not limited to, 562920, 493110, 811490, 423320, 423930, 423120, 423140, 

339999, and 488410.

(b) Information Collected 

(i) Data Items. Each owner/operator of each secondary aluminum production facility

will be required to complete an electronic survey that contains several components. The draft 

electronic survey is a Microsoft Excel spreadsheet file that is divided into two worksheets (“tabs” 

within the spreadsheet). Respondents that own or operate major sources of HAP will be required 

to complete the major source tab. Respondents that own or operate area sources of HAP will be 

required to complete the area source tab. Respondents will also be asked to supply plant 

schematics; title V permits; operating permits; permit applications; performance test reports; 

emission inventory reports; copies of consent decrees or orders affecting their plants; notices of 

operating violations; startup, shutdown and malfunction plans; and site-specific operating, 

maintenance and monitoring plans. Respondents will also be required to correct, update or 

complete a table of data for their plants for inclusion in the NATA NEI. 

Although a large amount of information is needed for regulatory review of the NESHAP, 

the EPA has designed the secondary aluminum production information collection in a way to 

minimize the burden associated supplying and processing this information. The EPA will prepopulate survey spreadsheets with each facility's 2005 NATA NEI data set to be reviewed

(thereby reducing respondent burden to locate and import their facility’s NEI data). For facilities 

that are not presently included in the NATA NEI, respondents will be provided with a blank 

spreadsheet in which to enter data. The secondary aluminum production information collection 

is being administered in spreadsheet form (as opposed to data base software) because 

respondents are likely to be more familiar with spreadsheet use than with data bases and,

following QA, data from the Excel spreadsheet rows can be readily imported into Access data 
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base software for use by the Agency (eliminating the time required for EPA to key-enter data). 

The secondary aluminum production spreadsheets will be provided to owners and operators on a 

compact disk which respondents can use to save and submit their survey spreadsheets and other 

materials such as electronic copies of flow diagrams and emission test reports. The burden 

associated with collection of emissions test data has been reduced in several ways: 

(1) Area sources of HAP are being asked to respond to a shortened worksheet that 

addresses affected sources that are regulated under the NESHAP and other sources of 

HAP emissions. 

(2) Data are being requested for the HAP surrogates defined in the MACT standards and 

any available data related to speciated HAP.

(3) Respondents may provide electronic or hard copy emissions test reports, whichever 

they find to be less burdensome.

(4) Respondents are being asked to transmit the responses (except for confidential 

business information) electronically.

(ii) Respondent Activities. The activities a respondent must undertake to fulfill the 

requirements of the information collection are presented in Attachment 2. These include: i) read 

instructions; ii) provide information on each affected source through electronic survey; and iii) 

submit hard or electronic copies of flow diagrams, previous emission test reports, and available 

CEMS or COMS data.

5. The Information Collected – Agency Activities, Collection Methodology, and 

Information Management

(a) Agency Activities

A list of activities required of the EPA is provided in Attachment 3. These include: i) 

develop electronic questionnaire and packages for mail out; ii) answer respondent questions; iii) 

review and analyze responses and emissions data; and iv) analyze requests for confidentiality.

(b) Collection Methodology and Management

In collecting and analyzing the information associated with this ICR, EPA will use 

personal computers and applicable spreadsheet and database software. To better facilitate 

uniformity in the format of the requested data, and, thus, increase the ease of database entry, 

standardized survey questions, example responses, and Excel spreadsheet forms will be 

distributed to respondents. EPA will ensure the accuracy and completeness of the collected 

information by reviewing each submittal. Flow diagrams may be used to answer any questions 

revealed during quality assurance (QA) of each submittal. The EPA may place follow-up calls to 
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respondents should questions remain after reviewing all materials submitted. Following QA of 

each submittal, the spreadsheet information from each facility will be uploaded into an Access 

data base for further analysis. Portions of survey responses claimed as CBI will be housed in a 

separate data base from the non-CBI survey responses. In addition, a copy of the NATA NEI

updates submitted will be routed for inclusion in EPA’s residual risk input data base, and for 

inclusion in future versions of the NATA NEI and its successor, the Emissions Inventory System 

(EIS). Emissions test report data will be entered into a data base by EPA (or EPA contractor 

personnel) familiar with extracting test data from test reports. The resulting data bases will be 

QA’d prior to and as part of regulatory analyses.

(c) Small Entity Flexibility

All respondents required to comply with the secondary aluminum production survey will 

be subject to the same requirements. EPA expects that half of the respondents may be small 

entities. Small entities are likely to be area sources. Small entities and other companies that own 

and/or operate facilities that are not major sources of HAP emissions (i.e., area sources) will 

have fewer affected sources per facility and fewer data (because area sources are regulated only 

for D/F). Even if they are major sources of HAP emissions, small entities would have fewer 

portions of the survey to complete, as their operations would likely be less extensive. The 

Agency also plans to use an electronic format of the questionnaire in order to reduce the burden 

and improve the data accuracy from all respondents, including small entities. In addition, the 

survey will contain a question to determine the small entity status of a facility. This question

will help to identify, quantify, and minimize the burden on small entities during the rulemaking 

process. 

(d) Collection Schedule

EPA anticipates issuing the CAA section 114 letters by late-2010. These CAA section 

114 letters would require the owner/operator of each secondary aluminum production facility to 

complete the secondary aluminum production facility survey spreadsheet (including NATA NEI 

update) and submit emissions test data within 60 days of receipt of the survey. EPA will compile 

and analyze survey response data upon receipt.
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6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden and Costs

Attachment 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 rates for private industry workers and were taken from 

the United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. 

Civilian Workers, by occupational and industry group,” available at 

www.bls.gov/news.release/ecec.t02.htm. Wages for occupational groups are used as the basis 

for the labor rates with a total compensation of $46.76 per hour for technical, $54.52 per hour for 

managerial, and $23.11 per hour for clerical. 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 $98.20, management at $114.49, and clerical at $48.53. These estimates represent 

the one-time burden that will be incurred by the recipients.

(b) Estimating Agency Burden and Costs

The costs the Federal Government would incur are presented in Attachment 3. The 

Agency labor rates are from the Office of Personnel Management (OPM) 2009 General Schedule 

which excludes locality rates of pay. These rates can be obtained from Salary Table 2010-GS, 

available on the OPM website at www.opm.gov/oca/10tables/html/gs_h.asp. The government 

employee labor rates are $16.28 per hour for clerical (GS-7, Step 1), $34.34 for technical (GS13, Step 1), and $47.74 for managerial (GS-15, Step 1). These rates were increased by 60 

percent to include fringe benefits and overhead. The fully-burdened wage rates used to represent 

Agency labor costs are: clerical at $26.05, technical at $54.94, and managerial at $76.38.

(c) Estimating the Respondent Universe and Total Burden and Costs

Estimates based on previous surveys of the industry and review of operating permits 

indicate that the potential respondent universe consists of 400 facilities. All 400 of these facilities 

will be required to complete some portion of the electronic survey. The government burden 

estimate provided in Attachment 3 assumes that 5 percent of the respondents will not be subject 

to the NESHAP. However, it is not known how many of these claims will be valid so all 

respondents are included in the burden estimate for respondents (in Attachment 2). Attachment 

2 lists the various portions of the survey in detail. 
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(d) Bottom Line Burden Hours and Costs Tables

(i) Respondent tally. The bottom line industry burden hours and costs, presented in 

Attachment 2, are calculated by summing the person-hours column and by summing the cost 

column. The burden and cost to the industry is 36,248 hours and $3,428,547. No capital or 

annualized costs are applicable because this is a one-time submittal. O&M costs of $1200.00 are 

estimated for postage to mail in the survey response to EPA, for portions of the responses that 

can not be submitted electronically. 

(ii) Agency tally. The bottom line Agency burden and cost, presented in Attachment 3

is calculated in the same manner as the industry burden and cost. The estimated burden and cost 

are 2,182 hours and $116,415, which includes $6,900 in O & M costs to send CAA section 114 

letters to all respondents with electronic return receipt and a compact disk containing the 

electronic spreadsheet, pre-populated NATA NEI spreadsheets, questionnaire printing costs, and 

computer storage of data received.

(iii) The complex collection. This ICR is a simple collection; therefore, this section 

does not apply.

(iv) Variations in the annual bottom line. This section does not apply as this is a onetime collection.

(e) Reasons for Change in Burden

This is the initial estimation of burden for this information collection; therefore, this

section does not apply. 

(f) Burden Statement

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 systems for the purposes of collecting, validating, and verifying information, 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 
14

currently valid OMB control number. The OMB control numbers for EPA’s regulations are listed 

in 40 CFR part 9 and 48 CFR chapter 15.

The total cost burden for the secondary aluminum production data gathering effort is 

estimated to be 36,248 hours and $3,429,747 (91 hours and $8,571/respondent for 400 

respondents. This ICR does not include any requirements that would cause the respondents to 

incur either capital or start-up costs. O&M costs of $1200 ($3/respondent) are estimated for 

postage to mail portions of the survey response that cannot be submitted electronically to EPA. 

INFORMATION COLLECTION REQUEST FOR SECONDARY ALUMINUM 

PRODUCTION NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR 

POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW (RTR)

Part B of the Supporting Statement

1. Respondent Universe

Estimates based on information collected in the development of the current NESHAP and 

a review of operating permits indicate that the potential respondent universe consists of 400 

respondents. All 400 respondents will be required to complete some portion of the electronic 

survey. The government burden estimate provided in Attachment 3 assumes that 5 percent of 

facilities will provide documentation that they are not subject to the secondary aluminum 

production NESHAP. However, it is not known how many of these claims will be valid so all 

facilities are included in the burden estimate for respondents (in Attachment 2). Attachment 2 

lists the various portions of the survey in detail and provides an estimated number of respondents

required to complete each portion of the survey. Assumptions used in the burden estimates are 

that a total of 400 facilities composed of 100 major sources of HAP and 300 area sources of HAP 

will be subject to the NESHAP. 

2. Response Rates

Since the information will be requested pursuant to the authority of CAA section 114,

EPA expects that all respondents requested to submit information will do so. 
15

List of Attachments

1. Draft Questionnaire Content

2. Industry Burden and Costs for Responding to the Questionnaire

3. Agency Burden and Costs
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Attachment 1.

Draft Questionnaire Content

The draft questionnaire may be found in separate files accompanying this supporting statement, including the following:

File name Description

secal_allcompany114.doc This is the paper copy of the electronic 

questionnaire which will be sent with the 

compact disk and 114 letter. Attachments to 

this document are: (1) a list of definitions useful 

in completing the questionnaire; and (2) a list of 

hazardous air pollutants based on section 

112(b)(1) of the CAA as currently modified.

secal_allcompany_questionnaire.xls This multi-tabbed spreadsheet file is the 

electronic version of the survey. It includes 

separate tabs for area sources and major sources, 

as well as tabs with definitions and the current 

HAP list.

0202 NATA NEI data_unlisted.xls Blank spreadsheet to be provided for entry of 

data by facilities for which no NATA NEI data 

are presently available.

0202 NATA NEI 2005 data_listedsample.xls Sample populated spreadsheet for correction and 

updating of the presently available NATA NEI 

data set.
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Attachment 2. Industry Burden and Cost for Responding to Questionnaire

(A) Hours per 

Occurrence

(B) Occurrences/ 

Respondent /Year

(C) Hours/

Respondent/

Year (A x B)

(D) Respondents/ 

Year

1

(E) Technical 

Hours/Year

(C x D)

(F) Managerial Hours/Year

(E x 0.05)

(G) Clerical 

Hours/Year

(E x 0.10) (H) Cost/ Year

4 1 4 400 1,600 80 160 $174,038

a. Complete and submit survey spreadsheet tabs, as follows:

 All facilities information 20 1 20 400 8,000 400 800 $870,190

 Major source information 120 1 120 100 12,000 600 1,200 $1,305,284

 Area source information 16 1 16 300 4,800 240 480 $522,114

b. Prepare or copy/scan plant schematic

c. Copy/scan and submit reports as follows:

Title V permit 2 1 2 100 200 10 20 $21,755

Operating permit 2 1 2 300 600 30 60 $65,264

Permit application 2 1 2 20 40 2 4 $4,351

Performance test reports 8 1 8 300 2,400 120 240 $261,057

Emission inventory reports 2 1 2 100 200 10 20 $21,755

Consent decrees or orders 2 1 2 20 40 2 4 $4,351

Notice of operating violations 2 1 2 20 40 2 4 $4,351

Startup, shutdown, malfunction (SSM) plan 2 1 2 400 800 40 80 $87,019

Site-specific operating, maintenance and monitoring plan 2 1 2 400 800 40 80 $87,019

 31,520 1,576 3,152 $3,428,547

total= 36,248 avg hr/respondent= 91 $ 8,571 

 $ - 

 $ - 

 $ 1,200 

 $ 1,200 

1

The number of respondents per year is based on 400 facilities with 1 facilitiy/respondent. Labor + O&M = $ 3,429,747 

2

Postage Costs for mailing survey responses to EPA are estimated at $12 for Federal Express letter size envelope flat rate; 100 respondents submit by mail (remaining respondents submit electronically).

5. RECORDKEEPING REQUIREMENTS (Not applicable)

TOTAL ANNUAL LABOR BURDEN AND COST

Respondent Activity

A. Read Instructions

1. APPLICATIONS (Not Applicable)

2. SURVEY AND STUDIES (Not Applicable)

3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY 

AND SYSTEMS (Not Applicable)

D. Gather Existing Information (Included in 4B)

4. REPORT REQUIREMENTS

B. Required Activities

C. Create Information (Included in 4B)

ANNUALIZED CAPITAL COSTS (Not Applicable)

TOTAL ANNUAL COSTS (O&M)

2

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)

ANNUAL CAPITAL COSTS (Not Applicable)

E. Write Report (Not Applicable)
18

Attachment 3. Agency Burden and Costs

Agency Activity

(A) EPA Hours/ 

Occurrence

(B) Occurrences/

Respondent/Year

(C) EPA 

Hours/Respondent/Y

ear (A x B)

(D) 

Respondents/

Year

1

(E) EPA Technical 

Hours/ Year (C x 

D)

(F) EPA 

Managerial

Hours/Year 

(E x 0.05)

(G) EPA 

Clerical 

Hours/Year 

(E x 0.10) (H) Cost, $

Develop/revise questionnaire spreadsheets and instructions 200 1 200 1 200 10 20 $ 12,274

Pre-populate spreadsheets with existing NEI data 0.1 1 0.1 400 40 2 4 $ 2,455

Mail out questionnaire

2

0.2 1 0.2 400 80 4 8 $ 4,909

Analyze and respond to claims that survey is not required because 

company is not subject to NESHAP30.2 1 0.2 10 2 0 0 $ 123

Answer respondent questions via phone or email. 0.5 1 0.5 50 25 1 3 $ 1,534

Analyze requests for confidentiality

5

1 1 1 50 50 3 5 $ 3,068

Review and analyze responses (including follow-up)

6

NEI data 0.5 1 0.5 400 200 10 20 $ 12,274

Sector survey spreadsheet data 2 1 2 400 800 40 80 $ 49,094

Review/analyze emissions test data70.5 1000 500 1 500 25 50 $ 30,684

Total Annual Hours 1,897 95 190 $ 116,415

total = 2,182 hours

Expenses (O&M)8

 Printing questionnaire $ 1,400

 Compact disks $ 80

 Postage $ 2,400

 Computer storage of data $ 3,030

Total Expenses $ 6,910

TOTAL ANNUAL LABOR BURDEN AND COST $ 123,325

1. The number of respondents per year is based on the estimated number of respondents. 

2. Mailout package includes section 114 letter with standard enclosures, hard copy of survey overview document, and compact disk containing spreadsheet files. Assumes EPA will mail one questionnaire per company.

3. Assumes 5% of companies provide documentation. It is not known how many of these claims will be valid so this number of facilities has not been subtracted from the burden estimates associated with completing the survey.

4. Assumes that 12.5% of the respondents will have questions.

5. Assumes that 25% of facilities will have confidential data.

6. Assumes 100 major sources and 300 area sources.

7. Some emissions test results will require little time for analysis (e.g., those within the range of other test results), while others will require additional time (e.g., potential errors). Expect to spend an average of 0.5 hr per test result.

8. Copy costs are estimated for 70 pages at $0.05/page. Compact disks were estimated at $0.20/each. Postage Costs are estimated at $6 for Federal Express letter size envelope flat rate.

 Data storage estimated at $21/GB/mo, assuming 25 MB per facility, 400 facilities and 12 month storage. Webpage cost estimated at $85/mo for 6 months.