April 25, 2011 

Dennis Krause 

Reynolds Metals, St. Lawrence Reduction Plant 

194 County Route 45 

Massena, NY 13662-0150 

Re: Requirement to provide information and conduct metal hazardous air pollutant analyses 

according to Section 114 of the Clean Air Act 

Dear Mr. Krause: 

We, at the U.S. Environmental Protection Agency (EPA), are collecting information on 

emissions of hazardous air pollutants (HAP) and other related information from primary 

aluminum reduction facilities, pursuant to our authority under Section 114 of the Clean Air Act 

(CAA) (42 U.S.C. 7414). The information gathered will be used by the EPA to perform a review 

of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Primary 

Aluminum Reduction Plants in 40 CFR Part 63, Subpart LL, developed under section 112(d) of 

the CAA (62 FR 52407, October 7, 1997). The review of the NESHAP for primary aluminum 

reduction plants is being conducted under sections 112(d) and 112(f) of the CAA. 

There are two components to this information request, both of which you are required to 

complete and submit to EPA. The first component is a survey requesting general facility 

information, information on production operations and emissions controls, and reports of 

previously performed emissions testing for each of your primary aluminum reduction facilities 

(Enclosure 1). The second component is a requirement for testing at your primary aluminum 

reduction facilities and the procedures for reporting the associated test data (Enclosure 2). 

The authority for EPA's information gathering is included in section 114 of the CAA 

(42 U.S.C. 7414). All information submitted to the EPA as part of this request will be made 

available to the public unless a satisfactory showing is made that public access to such 

information would divulge methods or processes entitled to protection as confidential business 

information or trade secrets. If you believe that disclosure of specific pieces of information you 

submit would reveal confidential business information or a trade secret, you should clearly 

identify such pieces of information. Please do not label an entire response “confidential” if only 

certain portions consist of confidential business information or trade secrets. Refer to Enclosure 

3 for the information that the EPA may require, at a later time, to support your confidentiality 

claims. Any information determined to constitute a trade secret will be protected under 18 U.S.C. 

1905, 5 U.S.C.A 552(b)(4), and EPA’s implementing regulations at 40 C.F.R. Part 2, Subpart B. 

If no claim of confidentially accompanies the information when it is received by the EPA, it may 

be made available to the public by the EPA without further notice (40 CFR part 2.203, 

September 1, 1976). Because section 114(c) of the Act exempts emission data from claims of 

confidentiality, the emission data you provide may be made available to the public. For this 

reason, questions on emissions data are listed in a separate section of the enclosed request for 

information. A clarification of what the EPA considers to be emissions data is contained in 

Enclosure 4. You should not mark the emissions data as confidential business information. 
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We have contracted RTI International (RTI) (Contract No. EP-D-06118) to help us gather 

information about your industry. As noted in Enclosure 5, we have designated RTI (prime 

contractor) to be our authorized representative. Therefore, RTI has the same rights EPA has as 

discussed above and in Enclosure 3. This means that RTI will have access to all information 

provided to us in your response to this request. As a designated representative of the Agency, 

RTI must, by law, also abide by 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 EPA’s policies and procedures for handling confidential 

information and describes EPA contractor commitments and procedures for use of confidential 

materials. It is EPA’s policy that compliance by an authorized representative with the 

requirements detailed in Enclosure 6 provides sufficient information for the rights of submitters 

of confidential information. 

If you have questions regarding the need for this information request or need clarification 

on the information requested, please contact David Putney with EPA’s Office of Air Quality 

Planning and Standards. 

After you have completed the survey responses, you should remove any components you 

wish to claim as confidential business information (CBI) from your survey and return the 

completed non-confidential survey response and the test results and other requested information 

by May 31, 2011 at the appropriate address provided below. Should you have any problems with 

meeting this deadline, please contact Mr. Putney by telephone at 919-541-2016 or by email at 

putney.david@epa.gov as soon as you are aware of a potential delay in your schedule. 

Please use the address below for delivery by U.S. Mail: 

David F. Putney (Mail Code D243-02) 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Please use the address below for delivery by commercial package carriers (e.g. FedEx and UPS): 

David Putney (Mail Code D243-02) 

109 T.W. Alexander Drive 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Durham, NC 27709 

EPA recommends sending your non-CBI files via Registered U.S. Mail using return receipt 

requests, Federal Express, or other method for which someone must provide a signature upon 

receipt. You may also save the files to the disc provided in Enclosure 7 or send the completed 

forms electronically via email to primaryicr@epa.gov. If you choose to e-mail your data files 

and they are extremely large data files, you may have to zip your files in order to transmit them. 

If you have to zip your files, please change the extension of the zipped file from “zip” to “abc” 

before sending to avoid rejection by the EPA internet security fire wall. 

If you are submitting information you wish to claim as CBI as described in Enclosure 6, 

please create a separate CD or DVD containing only the CBI portion of your survey response, 

and mail the CD or DVD to EPA by May 31, 2011 at the appropriate address provided below. 

Clearly mark the disk and/or the materials with the words “Confidential Business Information” 

and send either via U.S. Postal Service Express Mail, registered mail, or private courier to: 
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Roberto Morales (C404-02) 

c/o David Putney (ESD Project 489) 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Please use the street address below for commercial package carriers, such as FedEx and UPS: 

Roberto Morales (C404-02) 

c/o David Putney (ESD Project 489) 

109 T.W. Alexander Drive 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Durham, NC 27709 

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS 

INFORMATION TO EPA. E-mail and facsimile (FAX) are not secure forms of communication 

and should never be used to transmit CBI. 

If you have questions regarding this request, please contact David Putney, Metals and 

Inorganic Chemicals Group by telephone at 919-541-2016 or by email at putney.david@epa.gov. 

I am sure you understand how vital it is for the EPA to use the very best information 

available to develop the most meaningful standards. Your help in providing this information is 

greatly appreciated. 

Sincerely, 

Peter Tsirigotis 

Director, Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

7 Enclosures 

Enclosure 1: Facility Questionnaire for Primary Aluminum Reduction Plants 

Enclosure 2: Test Procedures, Methods, and Reporting Requirements for the Information 

Collection Request for the Primary Aluminum Reduction Source Category 

Enclosure 3: EPA’s Authority to Gather Information (Section 114 of the CAA) 

Enclosure 4: A Clarification of What EPA Considers Emissions Data 

Enclosure 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 (Microsoft® Word 

format) and the Test Data Reporting Spreadsheet (Microsoft® Excel format). 
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cc: David Shaw, Director, Division of Air Resources, New York Department of 

Environmental Conservation (without Enclosures) 

George Pavlou, Deputy Regional Administrator, U.S. Environmental Protection Agency, 

Region II (without Enclosures)