PART
A
OF
THE
SUPPORTING
STATEMENT
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Reporting
and
Recordkeeping
Requirements
for
the
Secondary
Aluminum
Production
NESHAP."
This
is
a
revision
of
the
existing
information
collection
request
(
ICR)
No.
1894.02
approved
under
OMB
Control
Number
2060­
0433.
Potential
respondents
are
owners
or
operators
of
new
and
existing
secondary
aluminum
production
facilities.
This
revision
of
the
existing
ICR
reflects
the
changes
to
the
respondent
community
that
would
result
from
amendments
to
the
final
rule.
By
excluding
aluminum
die
casting
facilities,
aluminum
foundries,
and
aluminum
extrusion
facilities
from
the
rule
coverage,
the
amendments
would
reduce
the
number
of
potential
respondents
by
about
35
percent
compared
to
the
existing
rule.

(
b)
Short
Characterization.

Potential
respondents
are
owners
or
operators
of
new
and
existing
secondary
aluminum
production
facilities.
This
revised
ICR
reduces
the
number
of
potential
respondents
and
associated
burden
costs
that
would
result
from
amendments
to
the
rule.
The
amendments
are
being
made
to
implement
settlement
agreements
with
the
Aluminum
Association
[
Aluminum
Association
v.
EPA
(
No.
00­

1211,
D.
C.
Circuit)]
and
the
American
Foundrymen's
Society
[
American
Foundrymen's
Society,
et
al;
v.
EPA
(
No.
00­
1208,
D.
C.

Circuit)].
As
a
result
of
amendments
to
the
rule,
owners
and
operators
of
aluminum
die
casting
facilities,
aluminum
foundries,

and
aluminum
extrusion
facilities
are
no
longer
considered
respondents.
Component
processes
include
aluminum
scrap
shredders,
thermal
chip
dryers,
scrap
dryers/
delacquering
kilns/
decoating
kilns,
secondary
aluminum
processing
units
(
SAPUs)
composed
of
in­
line
fluxers
and
process
furnaces
(
including
both
melting
and
holding
furnaces
of
various
configurations),
sweat
furnaces,
dross­
only
furnaces,
and
rotary
dross
coolers.

Consistent
with
the
General
Provisions
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Source
2
Categories
(
40
CFR
Part
63,
Subpart
A),
respondents
do
not
include
the
owner
or
operator
of
any
facility
that
is
not
a
major
source
of
HAP
emissions
except
for
those
that
are
area
sources
of
dioxin/
furan
emissions.

Respondents
must
submit
one­
time
notifications
of
applicability
and
reports
on
initial
performance
test
results.

Plants
must
develop
and
implement
a
startup,
shutdown,
and
malfunction
plan
and
submit
semiannual
reports
of
any
event
where
the
plan
was
not
followed.
Respondents
must
also
develop
and
implement
an
operation,
maintenance,
and
monitoring
plan
covering
each
affected
source
and
each
emission
control
device
used
for
compliance
with
the
rule.
Semiannual
reports
for
periods
of
operation
during
which
the
monitoring
parameter
ranges
established
during
the
initial
compliance
test
are
exceeded
(
or
reports
certifying
that
no
exceedances
have
occurred)
also
are
required.
General
requirements
applicable
to
all
NESHAP
require
records
of
applicability
determinations;
performance
test
results;
deviations;
periods
of
startups,
shutdowns,
or
malfunctions;
monitoring
records;
and
all
other
information
needed
to
determine
compliance
with
the
applicable
standard.

Records
and
reports
must
be
retained
for
a
total
of
5
years
(
2
years
at
the
site;
the
remaining
3
years
of
records
may
be
retained
off­
site).
The
files
may
be
maintained
on
microfilm,
on
a
computer
or
floppy
disks,
on
magnetic
tape,
or
on
microfiche.

Subpart
RRR
requires
respondents
to
monitor
control
device
operating
parameters
to
assure
continuous
compliance
with
the
rule.
Parameter
monitoring
requirements
include
bag
leak
detectors
or
continuous
opacity
monitors
for
fabric
filter
systems,
lime
injection
rate
monitors
for
lime­
conditioned
fabric
filter
systems,
temperature
monitors
for
afterburners
or
incinerators,
and
temperature
monitors
for
fabric
filter
inlet
temperature.
Respondents
also
must
maintain
records
of
specific
information
needed
to
determine
that
the
standards
are
being
achieved
and
maintained.
These
requirements
are
described
in
Attachment
1.
3
2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
NESHAP
for
new
or
existing
major
sources
or
area
sources
that
reflect:

...
the
maximum
degree
of
reduction
in
emissions
of
[
HAPs]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
emission
reduction,
any
nonair
quality
health
and
environmental
reduction,
and
energy
requirements.
[
section
112(
d)(
2)]

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).
Certain
records
and
reports
are
necessary
for
the
Administrator
to:
(
1)
confirm
the
compliance
status
of
major
sources,
(
2)
identify
any
non­
major
sources
not
subject
to
the
standards,
and
(
3)
identify
new
or
reconstructed
sources
subject
to
the
standards.
Specific
information
needed
by
EPA
for
the
secondary
aluminum
NESHAP
includes,
for
units
requiring
the
use
of
air
emission
controls,

whether
the
required
controls
are
properly
installed,
operated,

and
maintained.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.

7414)
and
set
out
in
the
NESHAP
General
Provisions.

(
b)
Practical
Utility/
Users
of
the
Data.

The
information
will
be
used
by
Agency
enforcement
personnel
to:
(
1)
identify
major
sources
and
new
or
reconstructed
sources
subject
to
the
standards;
(
2)
ensure
that
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.

Based
on
the
reported
information,
EPA
can
decide
which
plants,

records,
or
processes
should
be
inspected.
The
records
that
plants
maintain
will
indicate
to
EPA
whether
plant
personnel
are
operating
and
maintaining
control
equipment
properly.

3.
Nonduplication,
Consultation,
and
Other
Collection
Criteria
(
a)
Nonduplication.
4
The
information
required
by
the
secondary
aluminum
NESHAP
is
not
duplicated
by
existing
EPA
regulations
and
is
not
expected
to
be
required
by
any
other
EPA
rulemaking
currently
in
progress.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,

a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.
The
EPA
has
issued
guidance
to
State
and
local
agencies
encouraging
them
to
consolidate
duplicative
requirements
into
a
single
element
to
be
reported.

(
b)
Public
Notice
Required
Prior
to
ICR
Submissions
to
OMB
This
section
is
not
applicable
because
this
is
a
rulerelated
ICR.

(
c)
Consultations.

Following
promulgation
of
the
final
rule,
the
American
Foundrymen's
Society
filed
a
petition
for
review
that
culminated
in
a
settlement
agreement
lodged
with
the
United
States
Court
of
Appeals
for
the
District
of
Columbia.
As
a
result
of
that
settlement
agreement,
aluminum
foundries,
aluminum
die
casting
facilities,
and
aluminum
extrusion
facilities
are
no
longer
subject
to
the
rule.

(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
were
collected
less
frequently,

EPA
could
not
be
reasonably
assured
that
a
plant
is
in
compliance
with
the
standards.
5
(
e)
General
Guidelines.

None
of
the
general
information
collection
guidelines
in
5
CFR
1320.6
of
the
OMB
regulations
implementing
the
Paperwork
Reduction
Act
are
being
exceeded.
The
Agency
has
taken
all
practicable
steps
to
develop
simplified
requirements.

(
f)
Confidentiality
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;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
28,

1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,

1979).

(
g)
Sensitive
Questions.

This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Codes.

Respondents
are
owners
or
operators
of
secondary
aluminum
production
facilities
at
approximately
1,700
locations
which
are
required
to
comply
with
the
monitoring,
recordkeeping,
and
reporting
requirements
in
the
rule.
Prior
to
the
amendments,

respondents
at
approximately
2,700
locations
were
required
to
comply
with
these
requirements.
The
SIC
code
for
the
respondents
affected
by
the
standard
is
primarily
3341.
Secondary
aluminum
production
sources
collocated
at
other
sources
that
may
be
affected
are
in
SIC
3334
(
primary
aluminum
production),
3353
(
aluminum
sheet,
plate,
and
foil
manufacturing),
and
3355
(
other
aluminum
rolling
drawing).

(
b)
Information
Requested.

(
i)
Data
items,
Including
Recordkeeping
Requirements.

Attachment
1,
Source
Data
and
Information
Requirements,

summarizes
the
recordkeeping
and
reporting
requirements
including
the
required
retention
time
for
all
records.
6
(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
standards
are
identified
in
Table
1
and
introduced
in
Section
6(
a).
To
the
extent
practicable,
the
activities
required
by
respondents
were
designed
to
make
use
of
or
to
be
consistent
with
existing
reporting
and
recordkeeping
practices.

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
Table
2
and
introduced
in
Section
6(
c).

(
b)
Collection
Methodology
and
Management.

This
section
is
not
relevant
to
this
information
collection
request
(
ICR).

(
c)
Small
Entity
Flexibility.

As
a
result
of
the
amendments,
the
number
of
small
businesses
that
would
be
affected
is
reduced.
Approximately
1,600
of
the
estimated
1,700
plants
that
make
up
the
secondary
aluminum
industry
are
small
businesses
based
on
the
definition
used
by
the
Small
Business
Administration
(
500
or
fewer
company
employees).
Information
available
to
the
EPA
indicates
that
86
of
these
plants
are
major
sources
of
HAP
emissions.
The
remaining
plants
are
area
sources
and
are
subject
to
emission
limits,
monitoring,
recordkeeping,
and
reporting
only
related
to
dioxin/
furan
emissions.
Because
most
of
the
monitoring
and
recordkeeping
requirements
in
the
rule
are
necessary
to
insure
proper
operation
of
emission
control
equipment,
plants
need
to
collect
the
information
for
their
own
records
to
show
compliance
with
the
emission
standards.
The
EPA
does
not
expect
that
any
affected
source,
including
small
businesses,
will
experience
adverse
impacts
due
to
the
reporting
and
recordkeeping
requirements
of
the
proposed
rule.

Under
Section
112(
i),
the
Administrator
or
the
applicable
regulatory
authority
also
may
grant
one
additional
year
if
the
owner
or
operator
demonstrates
that
more
time
is
needed
to
7
install
controls
for
a
source.
This
additional
time
would
ease
capital
availability
problems
for
plants
in
marginal
economic
condition
that
need
to
purchase
and
install
new
or
upgraded
emission
controls.

(
d)
Collection
Schedule.

Information
contained
in
the
one­
time
reports
will
be
entered
into
the
Compliance
Data
System
operated
and
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
enforcement
and
compliance
programs.

Semiannual
reports
of
exceedances
of
or
compliance
with
the
control
device
operational
parameter
ranges
are
required.
A
schedule
for
collection
of
information
and
publication
of
data
is
not
applicable
because
reports
and
recordkeeping
would
be
triggered
by
action
of
the
respondents.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.

The
annual
burden
estimates
for
reporting
and
recordkeeping
are
presented
in
Table
1.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
sources
subject
to
the
standards
are
presented
in
Table
1.
Because
much
of
the
data
are
already
collected
by
respondents
or
required
by
existing
law,

minimal
respondent
development
costs
are
associated
with
the
information
collection
activities
for
the
standards.
Labor
rates
and
associated
costs
are
based
on
the
Comprehensive
Assessment
and
Information
Rule
(
CAIR)
economic
analysis
and
estimated
hourly
rates
are
as
follows:
technical
at
$
33,
management
at
$
49,
and
clerical
at
$
15.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
8
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
the
General
Provisions
for
the
MACT
standards,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
the
Compliance
Data
System,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program,
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Table
2.
Labor
rates
and
associated
costs
are
based
on
the
CAIR
economic
analysis
and
estimated
hourly
rates
are
as
follows:
technical
at
$
33,
management
at
$
49,
and
clerical
at
$
15.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
EPA
had
previously
identified
2,661
plants
that
would
be
required
to
comply
with
the
monitoring,
recordkeeping,
and
reporting
requirements
of
the
rule.
As
a
result
of
the
amendments
to
the
rule,
1,736
plants
involved
in
secondary
aluminum
production
would
be
required
to
comply
with
the
monitoring,
recordkeeping,
and
reporting
requirements.
Based
on
analyses
of
information
collected
from
two
industry­
wide
surveys,

the
Agency
estimates
that
86
of
the
sources
may
be
major
sources.

Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
1.

(
e)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables.

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours,
presented
in
Table
1,
are
calculated
by
adding
personhours
per
year
down
the
column
for
technical
staff;
management
and
clerical
hours
are
calculated
as
a
fraction
of
technical
hours,
0.05
for
management
and
0.1
for
clerical.
The
bottom
line
respondent
cost,
presented
in
Table
1,
is
calculated
by
adding
9
down
the
cost
column,
which
includes
the
cost
of
technical,

management,
and
clerical
hours.
Due
to
the
reduction
in
the
number
of
respondents,
the
revised
estimate
of
total
annual
hours
is
120,228
and
the
revised
estimate
of
annual
cost
is
$
9.0
million.
These
costs
include
the
costs
of
conducting
initial
performance
tests
and
installing
the
necessary
monitoring
devices.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Table
2,
are
calculated
as
in
the
respondent
table,
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,
total
cost
is
the
sum
of
this
total
salary
cost
and
total
travel
expenses
for
tests
attended.
The
total
annual
hours
are
25,457.
The
total
annual
cost
is
$
817,942.

(
iii)
Variations
in
the
annual
bottom
line.
The
respondent
burden
is
reduced
from
148,031
hours
annually
to
120,228
hours
annually
and
the
respondent
cost
is
reduced
from
$
10.4
million
to
$
9.0
million.

(
f)
Reasons
for
Change
in
Burden.

The
amended
rule
would
reduce
the
number
of
potential
respondents
from
2,661
to
1,736.

(
g)
Burden
Statement
The
average
annual
respondent
burden
for
the
1,736
affected
secondary
aluminum
production
facilities
is
estimated
at
120,228
hours.
This
estimate
includes
time
for
preparing
and
submitting
notices,
gathering
information
(
e.
g.,
conducting
emission
performance
tests),
submitting
reports,
and
maintaining
records.

Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
207.6
hours
per
response.
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
10
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
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.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2002­
0084,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,

Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:

Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
11
2002­
0084)
and
OMB
control
number
(
2060­
0433)
in
any
correspondence.

PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
12
Table
1.
13
14
Table
2.
15
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions
citation
Record
Retention
NOTIFICATIONS
Applicability
63.1500
63.9(
b)(
1)­

(
2)
5
years
Area
source
to
major
source
63.1515(
a)(
1)
63.9(
b)(
1)

New
or
reconstructed
major
source
63.1515(
a)(
2)
63.9(
b)(
3)

Intention
to
construct
or
reconstruct
63.1515(
a)(
3)(
i)
63.9(
b)(
4)

Date
construction
or
reconstruction
commenced
63.1515(
a)(
3)(
ii)
63.9(
b)(
4)

Anticipated
startup
(
N/
A)
63.1515(
a)(
3)(
iii)
63.9(
b)(
4)
"

Actual
startup
(
N/
A)
63.1515(
a)(
3)(
iv)
63.9(
b)(
4)
"

Intention
to
construct/
reconstruct
(
N/
A)
63.1515(
a)(
4)
63.9(
b)(
5)
"

Special
compliance
requirements
(
N/
A)
63.1515(
a)(
5)
63.9(
d)
"

Date
of
initial
performance
test
63.1515(
a)(
6)
63.9(
e)
"

Continuous
monitoring
systems
63.1515(
a)(
7)
63.9(
g)

Notification
of
compliance
status
(
including
performance
test)
63.1515(
b)
63.9(
h)
&

63.10(
d)
"
Requirement
Regulation
citation
General
Provisions
citation
Record
Retention
NOTIFICATIONS
16
REPORTS
Startup,
shutdown,
malfunction
plan/
reports
63.1516(
a)
63.10(
e)(
3)
"

Excess
emissions/
summary
report
or
no
excess
emissions
reports
63.1516(
b)
63.10(
e)
"

Operation,
maintenance,
and
monitoring
plan
63.1510(
b)
63.6(
e)(
1)­

(
2)
"

RECORDS
Record
retention
63.1517(
a)(
1)
63.10(
b)
"

General
NESHAP
records
63.1517(
a)
63.10(
b)
"

N/
A
=
Not
applicable.
