SUPPORTING STATEMENT FOR OMB REVIEW OF EPA ICR No. 2400.01 : INFORMATION COLLECTION REQUEST FOR SECONDARY ALUMINUM PRODUCTION NA TIONAL 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

October 7 , 20102 SUPPORTING STATEMENT INFORMATION COLLECTION REQUEST FOR SECONDARY ALUMINUM PRODUCTION NATIONAL EMISSION STANDARDS FOR HA ZA RDOUS 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 Nationa l Emission Standards for Hazardous Air Pollutants (NESHAP) Residual Risk and Technology Review (RTR) .” This is a new information collection request (I CR) . The EPA ICR number is 2400

. 01 and the OMB Control number is 2060

- NEW. (b ) Short Characterization Th is information collection is being conducted b y EPA’s Office of Air and Radiation (OAR) to assist the EPA Administrator, as required by section s 112(d) (6) , and 112(f) of the Clean Air Act (CAA) , as amended, to determine the current affected population of s econdary aluminum production processes and to reevaluate emission standard s for this source category

. The information from this I CR 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 (NE I). T he NEI does not contain all of the information ( equipment, capacity , materials processed, emissions collection and control s ys tems, regulatory alternatives used, and emission test data) necessary

to characte rize secondary aluminum production NE S H AP affected sources for purposes of regulatory anal ys es. Although some of the needed information may be included in Title V or s tate air emission permit s, most permits do not contain all of the information needed and are not readil y available from an y single source

. Furthermore, there are no readil y available sources for previousl y conducted performance test results that will provide data for emissions o f the variet y of pollutants under consideration . To obtain this information, EPA is soliciting information with a survey , under authorit y of CAA section 114, from all affected units. EPA intends to administer the survey in electronic (spreadsheet) format . The survey will be s ent 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 i n response to the survey) will3

be 3 6,248 hours and $ 3, 429,747 , which includes $ 1 , 200 in operation and maintenance (O&M) costs for mailing survey

responses to EPA

. 2. Nee d for and Use of the Collection (a ) Ne ed/Authority for the Collection The secondary a luminum 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/deco ating, 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 dry ers, or scrap dry ers/delacquering kilns/decoating kilns. The federal emission standard that is the subject of this information collection i s the National Emission Standards for Hazardous Air Pollutants f

o r Secondary

A l uminum 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 dry ers, scrap dry ers/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 fluxe rs. Area sources of HAP are regulated onl y with respect to emissions of dioxins/furans (D/F) from thermal chip dry ers, scrap dry ers/delacquering kilns/decoating kilns, sweat furnaces, and SAPUs. Section 112(f)(2) of the CAA directs EPA to conduct risk ass essments 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 y ears after pro mulgation. Section 112(d)(6) of the CAA requires EPA to review and revise the MACT standards, as necessary , taking into account developments in practices, proc esses, and control technologies. The section 112(d)(6) technology review is to4

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 originall y promulgated secondary aluminum production NESHAP are over 15 ye ars old. The Agency i s aware that significant changes have been made in the intervening ye ars 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 rev iewing 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 anal ys is, and develop revisions to the NESHAP, as appropriate . An update of the 2005 National Air Toxics Assessment /National Emissions Inventory (NATA NEI ) data sets and more specific information n eeded for further rulemaking would be derived from the ICR. During the RTR processes, EPA examine s the risks from the entire “facility”, where the “facilit y” includes all HAP

- emitting operations within a contiguous area and under common control. In other words, for each facility EPA examine s the HAP emissions not only from the source category

of interest, but also emissions of HAP from all other emission sources at the facility . EPA anal yz e s risks due to the inhalation of HAP that are emitted “facilit y - w ide” for the populations residing within 50 km of each facility . For these facilit y - 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 production 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 an y environmental justice iss ues that might be associated with each category as required under Executive Order 12898. EPA evaluate s 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 categor ies are located. In addition to the facility

- wide risk anal ys is, we are requesting information on criteria pollutants from all air emission sources consistent with EPA’s new multi

- pollutant sector based strategy
.5

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 benefit s of multi

- pollutant and sector

- based analy ses and approaches inc lude the ability

to identify

optimum control strategies, considering feasibility , costs, and benefits across the different pollutant ty pes while streamlining administrative and compliance complexities and reducing conflicting and redundant requirements

. O btaining facility

- wide emissions are needed to determine if an y co - benefits have been achieved concerning the reduction of non

- HAP emissions resulting from the implementation of the NESHAP

. This could improve the implementation of an y future control strat egies for th is sector
. In formation collected directly from companies owning or operating secondary aluminum production facilities will have the greatest practical utility for purposes of performing the RTR and co

- benefit analy sis, as information from the a ffected industry will contain the most up

- to
date, accurate, and reliable equipment and operational data for each facility

. At present, EPA has facility

- wide data in the National Emissions Inventory , however some of these data may be missing, erroneous or not representative of current emissions. The I CR will request information for current equipment information and emissions from the most recent ye ars of production , and therefore, will not suffer from the considerable “lag time” that can be associated with different permit review cy cles (e.g., where the currently available inventory

does not y et 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 location s, 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) submi t compliance certifications in accordance with section 114(a)(3); and (G) provide such other information as the Administrator may

reasonably

require.

1 There 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 ma y be based on prior years if states do not submit current data

. Th ere 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).6

(b ) Use/Users of the Data As mentioned previously, the data used for the originall y promulgated NESHAP ar e incomplete, outdated and do not adequatel y reflect changes in emissions collection and control configurations that have occurred since promulgation of the MACT standard s. The MACT standards contain a number of compliance alternatives to allow for a vari ety 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 configuration s of secondary aluminum production affected sources and air pollution control sy stems. It is essential for the EPA to have updated information to use in the regulatory anal yses 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 NESH AP . 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, examin e 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 , i t is EPA’s intent that the NATA NEI updates supplied through this information collection be used in future versions of the NATA NEIand its successor, the Emissions Inventory

S ys tem (EI S). The NEI is used by EPA, States, and the public for a variet y 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. The non

- confidential information collected with this I CR would also be available to the public, including aluminum industry trade groups that may

find the information useful for their7

ongoing data gathering, analy ses, and publications. Inaddition, 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 m ade by individual companies, pursuant to S tate and national emission inventories, oper ating permits applications, initial notification forms , and compliance reports

. However, the complete extent of the data fields requested under this survey is not availa

ble 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 cy cles. There is als o 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 y et processed). The EPA’s proposed information collection seeks up

- to
- date equipment configuration and operational data for the most recent y ears of production. Although some S tate permits are provided to the public as searchable portable document format files (pdfs ) , many S tates 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

- cop y onl y, whereas onl y 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 widel y var yi ng 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

anal ys es from existing docum ents (assuming that these documents were readil y 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 readil y available for all facilities

. To summarize, the i nformation requested relevant to the current (post

- MACT) equipment configuration and operation , regulatory alternatives, emissions data, and effectiveness of various control sy stems at removi ng HAP is not readil y available from other sources . In the absence of8

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 expec ted to yi eld incomplete information. In formation 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 performi ng 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 I CR 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)

. E PA will address public comments before submitting the I CR to OMB. (c) Consultations F eedback was received from the Aluminum Association and the Institute of Scrap Recy cling Industries regarding the scope of the secondary aluminum production industry survey . An opportunity

for detailed comment s on the electronic survey will be provided by the Federal Register notice concerning the availability of the IC R for public review and comment. (d ) Effe cts of Less Frequent Collection This I CR will require the owner/operator of each secondary aluminum production facility to c omplete an electronic update of their 2005 National A i r Toxics Asses s ment (NATA ) NEI data s et 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 d ata (previousl y conducted tests onl y). EPA expects the information requested in this survey to be a one

- time effort.9

(e) General Guidelines None of these reporting or recordkeeping requirements violate an y 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 confidentialit y is made will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart B

– Confidentialit y of Business Information (see 40 CFR 2)

. An y information subsequently determined to constitute a trade secret will be protected under 18 U.S.C. 1905

. If no claim of confidentialit y accompanies the information when it is received b y EPA, it may

be made available to the public without further notice (40 CFR 2.203, September 1, 1976)

. Because CAA sec tion 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 i n 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 b y this act ion 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 curren tly regulated for emissions of particulate matter (PM) as a surrogate for particulate metal HAP, hydrogen chloride, dioxins and furans (D/F), and total hy drocarbon (THC) as a surrogate for organic HAP other than D/F. Area sources are regulated onl y for D/F. Approximately

200 companies operate secondary aluminum production facilities with an average of approximately

two facilities per compan y.10

The North American Industry Classification S ys tem (NAICS) codes for respondents affected b y the information coll ection include 331314 for secondary smelting and alloyingof aluminum as well as secondary

aluminum production facilities that are collocated at primary aluminum production facilities (331312); aluminum sheet, plate and foil manufacturing facilities (33131 5); aluminum extruded product manufacturing facilities (331316); other aluminum rolling and drawing facilities (331319); aluminum die casting facilities ( 331 521); aluminum foundry facilities (331524) ; and sweat furnaces which can be included in various NAI CS categories including , but not lim i ted to, 56292 0 , 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 c omplete an electronic survey that contains s everal 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 wil l 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 ap plications; 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 secon dary aluminum production information collection in a way to minimize the burden associated supplying and processing this information. T h e EPA will pre populate survey

spreadsheets with each facility 's 2005 NATA NEI data set to be review ed (thereb y reducin g respondent burden to locate and import their facility ’s NEIdata). For facilities that are not presently

included in the NATA NE I, respondents will be provided with a blank spreadsheet in which to enter data. The secondary aluminum production informati on collection is being administered in spreadsheet form (as opposed to data base software ) because respondents are likel y to be more familiar with sprea dsheet use than with data bases and , following QA, data from the Excel spreadsheet rows can be readil y i mported into Access data11

base software for use b y 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 be en reduced in several way s: (1) Area sources of HAP ar e being asked to respond to a shortened worksheet that addresses affected source s 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) electronicall y . ( 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 affecte d 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 Manag ement (a ) Agency Activities A list of activities required of the EPA is provided in Attachment 3

. These include: i) de velop electronic questionnaire and packages for mail out ; ii) answer respondent questions ; iii) review and anal yz e responses and emission s data; and iv) anal yz e requests for confidentialit y. (b ) Collection Methodology and Management In collecting and anal yz ing the information associated with this I CR, 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 qualit y assurance (QA) of each submittal. The EPA may place follow

- up calls to12

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 analy sis. Portions of s urvey responses claimed as CBI will be housed in a separ ate 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 NE I and its successor, the Em issio ns Inventory Sy stem (EI S). Emissions test report data will be entered into a data base b y EPA (or EPA contractor personnel) familiar with extract in g test data from test reports. The resulting data bases will be QA’d prior to and as part of regulatory anal ys es. (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 re spondents 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 facilit y and fewer data (because area sources are regulated onl y for D/F)

. Even if they

are major source s of HAP emissions, s mall 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 electro nic format of the questionnaire in orde r to reduce the burden and improve the data accuracy from all respondents, including small entities

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

. This question will help to identify , quantify , and mi nimize the burden on small entities during the rulemaking process. (d ) Collection Schedule EP A anticipates issuing the CAA s ection 114 letters by late

- 2010

. These CAA section 114 letters would require the owner/operator of each secondary aluminum produc tion facilit y to complete the secondary

aluminum production facility survey spreadsheet (including NATA NEI update) an d submit emissions test data w ithin 60 day s of receipt of the survey

. EPA will compile and anal yz e survey

response data upon receipt

.13

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) d ata
. Technical, management, and clerical average hourl y rates for private industry workers and were taken from the United States Department of Labor, Bureau of L abor Statistics, Se p tember 2009 , “Table 2. Civilian Workers, by

occupational and industry grou p,” 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, $5 4

. 5 2 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 full y - burdened hourl y wage rates used to represent respondent labor costs are: technical at $9 8.20 , management at $11 4

. 49 , and clerical at $4 8.53

. These estimates represent the one

- time burden that will be incurred b y 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) 200 9 General Schedule which excludes locality

rates of pay

. These rates can b e obtained from Salary Table 2010

- GS, available on the OPM website at www.opm.gov/oca/10tables/html/gs_h.asp

. The government employ ee labor rates are $16

. 28 per hour for clerical (GS

- 7 , Step 1 ), $ 34.3 4 for technical (GS

1 3 , Step 1 ), and $ 47.74 for managerial (GS

- 1 5 , Step 1 )

. These rates were increased b y 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 $ 54.9 4 , and manageria l at $ 76.38

. ( c ) Estimating the Respondent Universe and Total Burden and Costs Estimates based on previous survey s of the industry and review of operating permits indicate that the potential respondent universe consists of 4 00 facilities

. A ll 4 00 of these facilit ies will be re quired 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

.14

( d ) Bottom Line Burden Hours and Costs Tables (i ) Respondent tally

. The bo ttom line industry burden hours and costs, presented in Attachment 2 , are calculated by summing the person

- hours column and b y summing the cost column

. The burden and cost to the industry is 3 6,248 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 b urden 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 s ection 114 letters to all respondent s 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 I CR is a simple collect ion; therefore , this section does not apply

. (iv) Variations in the annual bottom line

. This section does not apply as this is a one

time collection. ( e ) Reasons for Change in Burden This is the initial estimation of burden for this information collection ; therefore, this section does not appl y. ( f ) Burden Statement Burden means the total time, effort, or financial resources expended b y 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 sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adju st the existing way s to compl y with an y 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 other wise 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 display s a15

currentl y 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 3 6,248 hours and $3, 429,747 ( 91 hours and $ 8,571 /respondent for 4 00 respondents

. This ICR does not include an y 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 electronicall y to EPA.

INFORMATION COL LECTION 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 collect ed in the development of the current NESHAP and a review of operating permits indicate that the potential respondent universe consists of 4 00
res p ondent s . All 4 00 respondents will be required to complete some portion of the electronic survey . The governm ent 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 faci lities 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 p ortion of the survey . Assumptions use d 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 sect ion 114, EPA expects that all respondents requested to submit information will do so

.16 List of Attachments

1. Draft Questionnaire Content 2. Industry

Burden and Costs for Responding to the Questionnaire 3. Agency

Burden and Costs17 Attachment 1. Dr aft 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 cop y of the electronic questio nnaire 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 current ly 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 NAT A NEI data_unlisted.xls Blank spreadsheet to be provided for entry of data b y facilities for which no NATA NEI data are presentl y available. 0202 NATA NEI 2005 data_listedsample.xls Sample populated spreadsheet for correction and updating of the presentl y available NATA NEI data set
.18

Attachm ent 2. In dus tr

y Bu rd en an d Co st fo r R

es pondi ng to Qu es ti

onnai re

(A) H

ou rs p er Occurrence (B ) Oc currences /

Re sp on de nt / Ye ar (C) H our s/ Re sp ond en t/ Ye ar (A x B ) (D) Re sp ond en ts / Ye ar 1 (E

) Te chnical Ho ur s/ Ye ar (C x D) (F

) M an ag erial Ho ur s/ Ye ar (E x 0 .0 5) (G ) Cl erical Ho ur s/ Ye ar (E x 0 .1 0) (H

) Cos t/ Y ea r

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

a. Com plete and su bm

it s ur vey sp re ads heet tabs , a s fo llo ws : A ll fa cilit ie s in fo rm

ation 20 1 20 400 8,000 400 800 $870,190 M aj or s our ce in fo rm ation 120 1 120 100 12,000 600 1,200 $1,305,284 A re a source in fo rm

ation 16 1 16 300 4,800 240 480 $522,114 b. Pre pare or

c opy/s can pl

ant sc hem

atic c. Copy/s can and su bm

it rep or ts a s fo llo ws : Ti tle V per mit 2 1 2 100 200 10 20 $21,755 Op erati ng per mit 2 1 2 300 600 30 60 $65,264 Pe rm it ap plic ation 2 1 2 20 40 2 4 $4,351 Pe rfo rm ance tes t re por

ts 8 1 8 300 2,400 120 240 $261,057 Emi ssion in ventor

y re por ts 2 1 2 100 200 10 20 $21,755 Co ns ent decrees o r o rd ers 2 1 2 20 40 2 4 $4,351 No tice of operati

ng violations 2 1 2 20 40 2 4 $4,351 St ar tup, s hutdow

n, m alfu nction (SSM ) p la n 2 1 2 400 800 40 80 $87,019 Sit e- sp ecific o pe rati

ng, m ai nte nanc e and mo ni

tor in g plan 2 1 2 400 800 40 80 $87,019

31,520 1,576 3,152 $3,428,547 total= 3 6, 248 avg hr/respondent= 9 1 $ 8 ,5 71
$ - $ - $ 1,200 $ 1,200

1 Th e n um

be r o f re sp ondents p er

y ear is b as ed on 400 fac ilit ie s wit h 1 fac ilit iy /res pondent. La bor + O&M = $ 3,429,747 2 Po st age Co st s fo r m

ailin g sur vey re sp ons es t o EP A are es ti ma ted at $12 fo r Fe deral

E xp re ss le tter

s ize e nvelope fla t ra te; 100 re spondents s ubm it b y ma il (re ma in in g res pondents s ubm it e le ctronical

ly ). 5. R ECORDKEEPING

RE QUIRE ME NTS (No t applic able) TOTA L AN

NUA L LA BOR BURDEN A ND COST

Re sp ond en t Ac ti vi ty

A. Rea d In str

uctions 1. A PPL ICA TIO NS (No t Applic able) 2. SUR VE Y AND STUDIES (No t Appl ic able) 3. A CQUISIT ION, INST AL LA TI ON, A ND UT IL

IZ AT ION OF TE

CHNOL OG Y AND SY STE MS (No t Applic able)

D. G ather Ex is ti ng In fo rm

ation (In cl

uded in 4B) 4. R EP ORT R EQUIREM ENT S
B. Re qui re d Acti vi ti es

C. Cre ate In fo rm

at io n (In cl

uded in 4B)

AN NUA LI ZE

D C AP ITA L COSTS (No t Applic able) TOTA L AN

NUA L COS TS (O&M ) 2

TOTA L AN

NUA LIZE

D COST S (A nnualize d capi tal + O&M c os ts ) AN NUA L CA PIT AL

COST S (No t Applic able) E. W rit e Re por

t (No t A pplic able)19

Atta ch me nt 3. Agen cy

Bu rde n an d Cost s

Age nc y Activity (A ) E PA Ho urs / Occurre nc e (B ) Oc curre nc es/

Resp on de nt

/Y ea r (C) EP

A Ho urs /R esp on de nt

/Y ea r (A x B) (D)

Re sp onde nts / Ye ar 1 (E) EP

A Te chni cal Hou rs / Y ea r (C x D) (F

) EPA Ma na ge ri al Ho urs /Y ea r (E x 0.05) (G) E PA

Cle ri cal Hours /Y ea r (E x 0.10) (H) Co st , $ Dev el op/ rev is e qu esti on na ire spreadsh

eets an d i ns tructi on s 200 1 200 1 200 10 20 12,274 $ Pre- popu la te spreadsh

eets wi th ex is ti ng NEI data 0.1 1 0.1 400 40 2 4 2,455 $ Mai l ou t qu esti on na ire 2 0.2 1 0.2 400 80 4 8 4,909 $ An al yze an d respon d to cl ai mst hat su rv ey i s n ot requ ired becau se com pan y isn ot su bj ect to N ES HAP3 0.2 1 0.2 10 2 0 0 123 $ An swer respon

den t qu esti ons v ia ph on e or em ai l. 0.5 1 0.5 50 25 1 3 1,534 $ An al yze requ ests f or con fid en ti al it y 5 1 1 1 50 50 3 5 3,068 $ Revi ew an d an al yze respon

ses (i nc lud ing fo llo w- up ) 6 NE I data 0.5 1 0.5 400 200 10 20 12,274 $ Sector su rv ey spreadsh eet data 2 1 2 400 800 40 80 49,094 $ Revi ew/an al yzeem is si on s test data

7 0.5 1000 500 1 500 25 50 30,684 $ To ta l An nua l Ho ur s 1,897 95 190 116,415 $ total = 2,182 ho ur s Exp en ses (O &M) 8 Pri nt ing qu esti on na ir e 1,400 $ Com pact di sks 80 $ Postag e 2,400 $ Com pu te r storag e of data 3,030 $ To ta l Exp en

ses 6,910 $ TO TAL AN NU

AL LABO R BURDEN AN D C OST 123,325 $ 1. T hen umb er of respon den ts per y ear i s based on

th e esti mated n um ber of respon den ts. 2. Mai lo ut packag e i nc lud es secti

on 114 l etter wi th stan dard en cl osu res, h ard copy of su rv ey ov erv ie w docu me nt, an d com pact di sk con tai ning spreadsh

eet f ile s. Assu me s EPA wi

ll ma il on e qu esti on na ire per com

pan y. 3. Assu me s 5% of

com pan ie s prov id e docu me ntat io n. It i s n ot kn ow n ho w m an y of t he se cl ai ms wi ll be v al idso th isn umb er of f aci lit ie s h as n ot been su btracted f rom th e bu rd en esti mates associ

ated w it h com pl et ing the su rvey. 4. Assu me s th at 12.5% of

th e respon den ts wi ll have qu esti ons. 5. Assu me s th at 25% of f aci lit ie s wi ll ha vecon fid en ti al data. 6. Assu me s 100 m

aj or sou rces an d 300 area sou

rces. 7. Som e em is si on s test resu lt s wi ll requ ir e l it tl e t imef or an al ys is(e.g ., th

ose wi thi n th e ran ge of ot he r test resu

lt s), w hi le oth ers wi ll requ ire addi ti on al ti me (e.g ., poten

ti al errors). E

xp ect to spen

d an av erage of 0.5 h r per test resu

lt

. 8. Copy costs are esti

mated f or 70 pag es at $0.05/page. Com

pact di sks were esti

mated at $0.20/each . Postage C osts are esti mated at $6 f

or Federal E xp ress l etter si zeen ve lo pe f la t rate. D ata storag

e esti ma te d at $21/G

B/m o, assu ming 25 MBper f

aci lit y, 400 f aci lit ie s an d 12 m on th s to rage. Webpag

e cost esti mated at $85/m

o f or 6 m on ths.