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 Ag ency (EPA), are collecting information on emissions of hazardous air pollutants (HAP) a nd other related information from primary aluminum reduction facilities, pur suant to our authority under Se ction 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 H azardous Air Pollutants (NESHAP) for Primary Aluminum Reduction Plants in 40 CFR Part 63, S ubpart LL, developed u nder section 112(d) of the CAA (62 FR 52407, October 7, 1997). The revi ew of the NESHAP fo r primary aluminum reduction plants is being conducted under sections 112(d) and 112(f) of the CAA. There are two components to this informati on 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 operation s 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 requi rement for testing at your primary aluminum reduction facilities and the procedures for repor ting the associated test data (Enclosure 2). The authority for EPA's information gather ing is included in section 114 of the CAA (42 U.S.C. 7414). All information submitted to th e EPA as part of this request will be made available to the public unless a satisfactory s howing 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 inform ation or a trade secret, you should clearly identify such pieces of information. Please do no t 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 s upport 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 re gulations at 40 C.F.R. Part 2, Subpart B. If no claim of confidentially accompanies the info rmation when it is rece ived by the EPA, it may be made available to the public by the EP A 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 ma y 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 cons iders to be emissions data is contained in Enclosure 4. You should not mark the emissions data as confidential business information.2

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 de signated RTI (prime contractor) to be our authorized representative. Therefore, RT I 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 designate d representative of the Agency, RTI must, by law, also abide by the requireme nts of 42 U.S.C. 7414(c) in regard to the confidentiality of what you cl aim to be trade secrets. Enclosure 6 summarizes EPA’s policies and procedures for handling confidential information and describes EPA c ontractor commitments and proce dures for use of confidential materials. It is EPA’s policy that complian ce by an authorized representative with the requirements detailed in Enclosure 6 provides suffic ient information for the rights of submitters of confidential information. If you have questions regarding the need for th is 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 inform ation (CBI) from your survey and return the completed non-confidential survey response and th e test results and other requested information by May 31, 2011 at the appropriate address provided be low. Should you have any problems with meeting this deadline, please contact Mr. Pu tney by telephone at 919-541-2016 or by email at putney.david@epa.gov as soon as you are aware of a pot ential 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 co mmercial 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 Pl anning and Standards Durham, NC 27709 EPA recommends sending your non-CBI files via Re gistered U.S. Mail using return receipt requests, Federal Express, or other method fo r which someone must provide a signature upon receipt. You may also save the files to the di sc 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 ha ve to zip your files in order to transmit them. If you have to zip your files, please change the ex tension of the zipped file from “zip” to “abc” before sending to avoid rejection by th e EPA internet security fire wall. If you are submitting information you wish to cl aim as CBI as described in Enclosure 6, please create a separate CD or DVD containing only the CBI por tion of your survey response, and mail the CD or DVD to EPA by May 31, 2011 at the appropriate addr ess provided below. Clearly mark the disk and/or the materials w ith the words “Confidential Business Information” and send either via U.S. Postal Service Express Mail, registered mail, or private courier to:3

Roberto Morales (C404-02) c/o David Putney (ESD Project 489) U.S. Environmental Protection Agency Office of Air Quality Pl anning and Standards Research Triangle Park, NC 27711

Please use the street address below for commerci al 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 Pl anning 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 mean ingful standards. Your help in providing this information is greatly appreciated.

Sincerely,

Peter Tsirigotis Director, Sector Policies and Programs Division

Office of Air Quality Pl anning and Standards

7 Enclosures

Enclosure 1: Facility Questionnaire fo r Primary Aluminum Reduction Plants Enclosure 2: Test Procedures, Methods, a nd 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 Wh at 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 c ontaining the electronic versi on of Enclosure 1 (Microsoft ® Word format) and the Test Data Re porting Spreadsheet (Microsoft ® Excel format).4

cc: David Shaw, Director, Division of Ai r Resources, New York Department of Environmental Conservati on (without Enclosures) George Pavlou, Deputy Regional Administrator, U.S. Environmental Protection Agency, Region II (without Enclosures)