1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
Maximum
Achievable
Control
Technology
(
MACT)
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
Part
63,
Subpart
LL)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
MACT
for
Primary
Aluminum
Reduction
Plants,
40
CFR
Part
63,
Subpart
LL.

1(
b)
Short
Characterization/
Abstract
The
MACT
standards
for
this
rule
were
proposed
on
September
26,
1996
and
were
promulgated
on
October
7,1997.
These
standards
apply
to
the
owner
or
operator
of
the
affected
facilities
which
include
new
or
existing
potlines,
paste
production
plants,
or
anode
bake
furnaces
associated
with
primary
aluminum
production
and
located
at
a
major
source,
and
for
each
new
pitch
storage
tank
associated
with
a
primary
aluminum
reduction
plant.

These
MACT
standards
implement
Section
12(
b)
of
the
Clean
Air
Act,
as
amended
and
are
based
on
the
Administrator's
determination
that
primary
aluminum
reduction
plants
emit
or
have
the
potential
to
emit
hazardous
air
pollutants
(
HAPs).
The
standards
ensure
that
all
major
sources
of
air
toxic
emissions
achieve
the
level
of
control
already
being
achieved
by
the
better
controlled
and
lower
emitting
sources
in
each
category
and
involve
the
installation,
operation
and
maintenance
of
particulate
control
devices
such
as
electrostatic
precipitators
or
scrubbers.
The
major
HAPs
emitted
by
these
facilities
include
hydrogen
fluoride
(
HF)
measured
as
total
flouride
(
TF)
and
polycyclic
organic
matter
(
POM).
In
addition
to
HAPs,
this
standard
addresses
particulate
matter
smaller
than
10
microns
in
diameter
(
PM
10),
which
are
controlled
under
the
National
Ambient
Air
Quality
Standards
(
NAAQS).

In
general,
all
MACT
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
according
to
the
general
provisions
specified
in
40
CFR
Part
63,
Subpart
A.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Section
63.850
of
the
final
standard
includes
these
provisions,
except
that
the
existing
performance
specifications
for
continuous
emission
monitors
(
CEMs)
are
not
applicable
to
HF
CEMs
because
such
specifications
have
not
yet
been
developed
for
that
device.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
MACT
standards.
2
Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
occurrence,
measurement,
maintenance,
corrective
action,
report
or
record.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

Approximately
23
major
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
new
sources
per
year
will
become
subject
to
the
standard.
It
is
further
assumed
that
one
source
per
year
will
have
a
new
affected
facility.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
Amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
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
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."

In
the
Administrator's
judgment,
emissions
of
hydrogen
fluoride
(
HF),
polycyclic
organic
matter
(
POM)
which
includes
hazardous
air
pollutants
(
HAPs)
and
particulate
matter
smaller
than
10
microns
in
diameter
(
PM
10)
from
primary
aluminum
reduction
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
MACT
standards
were
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
LL.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
hydrogen
fluoride
(
HF),
polycyclic
organic
matter
(
POM)
which
includes
hazardous
air
pollutants
(
HAPs)
and
particulate
matter
smaller
than
10
microns
in
diameter
(
PM
10)
from
primary
aluminum
reduction
plants
requires
not
only
the
installation
of
3
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
hydrogen
fluoride
(
HF),
polycyclic
organic
matter
(
POM)
which
includes
hazardous
air
pollutants
(
HAPs)
and
particulate
matter
smaller
than
10
microns
in
diameter
(
PM
10)
from
primary
aluminum
reduction
plants
are
the
result
of
operation
of
potlines,
paste
production
plants,
pitch
storage
tanks
and
anode
bake
furnaces.

These
standards
rely
on
the
reduction
of
emissions
of
hydrogen
fluoride
(
HF)
and
polycyclic
organic
matter
(
POM)
which
includes
hazardous
air
pollutants
(
HAPs)
from
potlines
and
anode
bake
furnaces,
the
reduction
of
POM
from
pitch
storage
tanks,
and
the
capture
of
particulate
matter
smaller
than
10
microns
in
diameter
(
PM
10)
from
paste
production
plants.

The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
excess
emissions
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
MACT
continue
to
operate
the
control
equipment
and
achieve
continuous
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63
Subpart
LL.

3(
a)
Nonduplication
If
the
standard
has
not
been
delegated,
the
information
is
sent
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
Local
Agency.
If
a
State
or
Local
Agency
has
adopted
their
own
similar
regulation
to
implement
the
Federal
Regulation,
a
copy
of
the
report
submitted
to
the
State
or
Local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
Standard.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
December
31,
2000.
4
3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
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
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
new
or
existing
primary
aluminum
reduction
facilities.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
Classification)
3334
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
331312
for
Primary
Production
of
Aluminum.

4(
b)
INFORMATION
REQUESTED.
5
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
LL.

A
source
must
make
the
following
reports:

Reports
for
MACT
SUBPART
LL
Construction/
reconstruction
63.5
Initial
compliance
status
63.850(
a)(
6)

Compliance
approach
63.850(
a)(
8)

Initial
notifications
when
becoming
subject
to
standard
63.9(
b),
63.850(
a)

One­
time
notification
for
each
affected
source
of
the
intent
to
use
an
HF
continuous
emission
monitor
63.850(
a)(
7)

Performance
test
results/
reports
63.10(
d)(
2),
63.850(
a)(
5),
63.850(
b)

Initial
performance
test
63.7(
b),
63.9(
e)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system,
if
applicable
63.9(
g)

Compliance
status
including
excess
emissions
report
63.9(
h)

Opacity
or
visible
emissions
63.10(
d)(
3),
63.845(
h)
and
(
i)

Periodic
startup,
shutdown,
malfunction
reports
and,
if
applicable,
Implementation
Plan
63.10(
d)(
5)(
I),
63.850(
c)

Semiannual
reports
are
required
for
periods
of
operation
during
which
measured
emissions
exceed
an
applicable
limit
or
control
device
operating
parameters
are
outside
of
the
established
ranges,
unless
quarterly
reports
are
required
as
a
result
of
excess
emissions.
63.850(
d)

A
source
must
maintain
the
following
records:
6
Recordkeeping
for
(
NSPS,
NESHAP,
MACT)
SUBPART
LL
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2)

Emission
test
results
and
other
data
needed
to
determine
emissions
61.13(
g)

All
reports
and
notifications
63.10(
b)

A
copy
of
the
Startup,
Shutdown,
and
Malfunction
Plan
and
(
if
applicable),
of
the
Implementation
Plan
for
emissions
averaging
63.850(
e)(
4)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
(
CEMS)
if
it
were
used
63.10(
3)

Records
are
required
to
be
retained
for
5
years.
The
most
recent
2
years
of
records
must
be
retained
at
the
facility.
63.850(
e)(
1­
2)

Aluminum
production
rate
and
anode
production.
63.850(
e)(
4)

Records
associated
with
an
owner
or
operator
request
to
monitor
similar
potlines,
to
perform
reduced
sampling,
or
to
establish
an
alternative
limit
for
a
HF
CEM
system.
63.850(
e)(
4)

Design
information
for
paste
production
plant
capture
systems
and
alternative
control
devices
63.850(
e)(
4)

Emissions
values
from
process
and
control
devices.
63.850(
e)(
4)

Documentation
that
daily
inspections
of
process
and
control
devices
were
performed
and
corrective
action(
s)
taken
as
required.
63.850(
e)(
4)

ii.
Respondent
Activities
include:

Respondent
Activities
Read
instructions.

If
approved
by
the
appropriate
regulatory
agency,
a
respondent
may
install,
calibrate,
maintain,
and
operate
a
HF
CMS
for
the
monitoring
of
TF
secondary
emissions
as
an
alternative
method.

Install,
calibrate,
maintain,
and
operate
a
continuous
parameter
monitor
for
each
emission
control
device
including
dry
alumina
scrubbers,
dry
coke
scrubbers,
wet
scrubbers,
electrostatic
precipitators
and
wet
roof
scrubbers.
Respondent
Activities
7
Perform
performance
test
using
reference
methods
specified
in
Appendix
A
of
40
CFR
Part
60
including
initial
performance
test.
An
alternative
test
method
for
TF
and
POM
emissions
may
be
used
provided
the
owner
or
operator
has
demonstrated
the
equivalency
of
the
alternative
method
to
a
specific
plant
and
has
received
previous
approval
from
the
applicable
regulatory
authority
for
its
use
or
it
meets
the
criteria
specified
in
63.848(
d)(
1)
and
(
d)(
3)
through(
d)(
6).

Comply
with
emission
monitoring
requirements
to
measure
TF,
POM
and
opacity
as
required.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
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.

Transmit,
or
otherwise
disclose
the
information.

The
owner
may
retain
records
on
microfilm,
on
a
computer,
on
computer
disks,
on
magnetic
tape,
or
on
microfiche.
It
may
also
report
using
a
labeled
computer
disc
using
a
compatible
software.

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.
Agency
Activities
8
Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
database.

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
regulatory
authority
might
inspect
paste
production
plants
and
review
site
records
to
determine
initial
compliance
with
the
standards.
The
regulatory
authority
will
use
performance
test
reports
conducted
for
anode
bake
furnaces
and
potlines,
as
well
as
for
primary
and
secondary
control
systems,
to
discern
the
source's
initial
capability
to
comply
with
the
standards
and
note
the
operating
conditions
under
which
compliance
will
be
achieved.
The
regulatory
authority
will
use
performance
tests
reports
or
design
evaluation
findings
for
pitch
storage
tanks
to
determine
initial
compliance
with
the
standard.
Subsequently,
the
semiannual
emission
reports,
unless
quarterly
reports
are
required
as
a
result
of
excess
emissions,
are
used
by
the
regulatory
authority
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
No
existing
primary
aluminum
plants
are
classified
as
small
entities.
The
EPA
does
not
expect
that
any
primary
aluminum
plants
subject
to
the
standards
would
experience
adverse
impacts.

The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant(
s).
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
The
requirements
reflect
the
burden
on
small
businesses.
Even
though,
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.
9
5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory
(
40
CFR
Part
63,
Subpart
LL).

The
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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
121,277.3
(
total
from
industry
table)
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
MACT
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
78.54
per
hour
for
Executive,
Administrative,
and
Managerial,
$
55.34
per
hour
for
Technical,
and
$
35.64
per
hour
for
Clerical.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.
The
wage
rates
have
been
loaded
by
adding
110%
overhead:
Executive,
Administrative,
and
Managerial:
$
78.54
($
37.40
+
110%)
Technical:
$
55.34
($
26.35
+
110%)
Clerical:
$
35.64
($
16.97
+
110%))

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
10
standards
are
labor
and
cost
of
CEMs
for
HF
and
other
monitoring
parameters
of
control
devices.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors.
The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
There
are
no
annualized
capital
cost
for
monitoring
devices
over
the
period
of
the
ICR
since
all
existing
plants
have
installed
the
necessary
equipment
to
comply
with
this
regulation
over
the
period
of
the
currently
approved
ICR.
The
operation
and
maintenance
cost
was
assumed
to
be
about
10
percent
of
the
initial
annualized
capital
cost
for
the
monitoring
equipment
for
all
23
facilities
in
compliance
with
the
regulation
at
an
average
of
$
39,000
per
year
over
the
3­
year
period
for
a
total
of
$
117,000,
as
indicated
in
the
table
below.
This
estimate
was
based
on
the
operation
of
12
of
Method
14
manifolds,
24
Alcan
cassettes
and
24
HF
continuous
monitors
operating
at
all
23
facilities.
The
operation
and
maintenance
costs
associated
with
other
monitoring
equipment
is
assumed
to
be
negligible
since
we
assumed
that
the
CEMS
for
monitoring
control
devices
parameters
(
i.
e.,
for
the
measurement
of
air
flow,
liquid
flow,
voltage
and
current
at
primary
and
secondary
control
devices
including
dry
alumina
scrubbers,
dry
coke
scrubbers,
wet
scrubbers
for
primary
system,
electrostatic
precipitators,
and
wet
roof
scrubbers)
were
installed
prior
to
the
effective
date
of
this
regulation
and
do
not
represent
an
additional
burden
to
comply
with
this
regulation.
.

Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
(
A)

Continuous
Monitoring
device
(
B)

Start
up
cost
($)
for
1
affected
facility
(
C)

#
of
new
affected
facilities
to
start
up
(
D)

Total
start
up
(
B
X
C)
(
E)

Annual
O&
M
costs
($)
for
1
affected
facility
(
F)

#
of
affected
facilities
with
O&
M
(
G)

Total
O&
M
(
E
X
F)

HF
CEMs
(
similar
potlines)
0
0
$
1,669
24
$
40,069
Method
14
manifolds
at
potlines
0
0
0
$
3,339
12
$
40,069
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
11
Alcan
cassettes
(
Method
14A)
0
0
0
$.
92X
24
$
36,862
TOTAL
$
117,000
As
mentioned
above,
there
are
no
capital/
start­
up
costs
for
this
ICR.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
a:
Total
annualized
capital/
startup
costs.

The
total
operating
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
117,000
over
the
3­
year
period
of
the
ICR
or
an
average
of
$
39,000
per
year.
This
is
the
total
of
column
G.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b:
Total
annual
costs
(
O&
M).
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

Therefore,
the
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs
is
$
39,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c:
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
57,259.1
(
from
Table
1).
This
cost
is
based
on
an
average
wage
of
an
employee
hourly
rate
plus
110%
overhead
cost
of
a
GS­
14
for
managerial
staff
($
68.19),
of
a
GS­
10
for
technical
staff
($
36.86),
and
a
GS­
7
for
administrative/
clerical
staff
($
27.36).
These
rates
are
from
OPM's
2001
General
Schedule
(
GS)
hourly
salary
data,
excluding
locality
pay,
basic
rates,
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
12
Respondent
Universe
Regulation
Title
(
A)
#
sources
with
a
new
affected
facility
(
B)
#
of
initial
reports
for
new
sources
(
C)
#
existing
major
sources
(
D)
#
of
reports
for
existing
sources
(
E)
total
annual
responses
(
A.
xB.)+(
CxD)

MACT,
Subpart
LL
1
6
23
1.92
*
6+
44.2*
=
50.9
*
This
number
was
calculated
using
Table
2,
attached.
It
is
the
sum
of
the
Number
of
Occurrences
per
Respondent
per
Year
times
Respondent
per
Year
(

columns
(
BxD))
under
Section
4E
for
existing
sources
(
average
for
23
major
sources).

The
number
of
total
respondents
is
23.
There
are
no
major
sources
anticipated
over
the
3­
year
period.
Although
the
number
of
affected
facilities
(
sources)
is
expected
to
increased
one
per
year
over
the
three
year
period
at
the
23
plants.
A
new
affected
facility
(
i.
e.,
new
or
reconstructed
pitch
storage
tank)
will
only
require
owners
and
operators
of
existing
plants
to
submit
one­
time
notifications
and
will
not
affect
significantly
the
reporting
requirements
other
than
for
the
first
time
notifications.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13
a.
This
is
the
number
of
existing
sources
plus
the
number
of
new
sources
anticipated
in
one
year.

The
total
annual
responses
is
50.9.
This
number
is
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
costs
are
$
6,625,917.6.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
Refer
to
the
Attachment
for
Tables
1
and
2.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
the
assumption
that
all
23
existing
primary
aluminum
plants
are
100
percent
in
compliance
with
the
rule
requirements.
The
most
recently
approved
ICR,
assumed
staggered
compliance
dates
over
the
3
year
period
of
the
ICR
because
it
was
the
first
ICR
that
was
developed
upon
promulgation
of
this
rule.
However,
the
mostly
recently
approved
ICR
expired
on
December
31,
2000.
We
have
also
assume
that
there
will
be
one
new
affected
facility
per
year
due
to
the
installation
of
a
new
or
reconstructed
pitch
storage
tank
at
an
existing
plant.
Lastly,
the
labor
rates
were
updated
both
for
government
and
industry
using
the
latest
information
available.

6(
g)
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
13
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
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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
Mail
code
2822,
1200
Pennsylvania
Avenue,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
Control
Number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
FINAL
STANDARD
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)

Technical
personhours
per
year
(
E=
CxD)
(
F)

Managemen
t
person­
hours
per
year
(
E=
0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
80
1
80
1c
80.0
4.0
0.8
5,026.5
4.
Reporting
Requirements
A.
Read
instructions
4
1
4
1c
4.0
0.2
0.04
251.3
B.
Required
activities
Initial
performance
test
120
1
120
1c
120
6.0
12
7,539.7
Annual
performance
test
100d
6.7e
670
23f
15,410.0
770.5
154.0
968,186.4
Monthly
performance
test
200g
12
2,400
12h
28,800.0
1,440.0
288.0
1,809,532.8
Monthly
performance
test
40i
25j
1,000
23
23,000.0
1,150.0
230.0
1,445,113.0
Quarterly
performance
test
200k
14.7l
2,940
6m
17,640.0
882.0
176.4
1,108,338.8
Daily
monitoring
2n
365
730
23e
16,790.0
839.5
1,679.0
1,054,932.5
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Notification
of
applicability
2
1
2
1c
2.0
0.1
0.2
125.7
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)

Technical
personhours
per
year
(
E=
CxD)
(
F)

Managemen
t
person­
hours
per
year
(
E=
0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
Notification
of
constr./
reconstr.
2
1
2
1
c
2.0
0.1
0.2
125.7
Notification
of
anticipated
startup
2
1
2
1
c
2.0
0.1
0.2
125.7
Notification
of
actual
startup
2
1
2
1c
2.0
0.1
0.2
125.7
Notification
of
special
compliance
requirements
N/
A
Notification
of
performance
test
See
4B
Notification
of
compliance
status/
approach
(
intent
to
use
HF
CEM)
4
1
4
1
c
4.0
0.2
0.4
238.5
NESHAP
waiver
application
N/
A
Report
of
performance
test
See
4B
Report
of
monitoring
exceedances
16
4o
32
2.3p
73.0
3.7
7.30
4,590.6
Report
of
no
excess
emissions
8
2o
16
20.7q
331.0
16.6
33.10
20,808.1
Startup,
shutdown,

malfunction
report
8
2r
16
2.3r
36.8
1.84
3.68
2,312.2
5.
Recordkeeping
Requirements
A.
Read
instructions
See
4B
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)

Technical
personhours
per
year
(
E=
CxD)
(
F)

Managemen
t
person­
hours
per
year
(
E=
0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
all
info.
required
by
standards
3s
45.63s
156
23
3,148.5
157.4
314.9
197,821.4
F.
Time
to
train
personnel
N/
A
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
N/
A
H.
Time
to
transmit
or
disclose
information
0.25t
2o
0.5
23
11.5
0.6
1.2
723.0
I.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
105,458.8
5,272.9
10,545.6
6,625,917.6
a
There
are
still
23
existing
primary
aluminum
reduction
plants,
although
some
have
reduce
their
capacity
due
to
power
shortage.

b
Costs
are
based
on
the
following
hourly
rates:
$
78.54
per
hour
for
Executive,
Administrative,
and
Managerial,
$
55.34
per
hour
for
Technical,
and
$
35.64
per
hour
for
Clerical.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.

c
Assume
one
plant
per
year
over
the
next
3
years
will
install
a
new
or
reconstructed
pitch
storage
tank.

d
100
hours
each
for
Method
13
and
Method
315
for
primary
emission
controls
(
of
TF
and
POM)
systems
at
potlines
and
anode
bake
furnaces.

e
Estimate
96
hours
for
Method
13
tests
and
58
hours
for
Method
315
tests
each
year
for
primary
control
systems
for
a
total
of
154
hours
for
23
respondents
(
154/
23
=
6.7
per
respondent).

f
All
23
primary
aluminum
reduction
plants
will
conduct
TF
and
POM
monitoring
at
anode
bake
furnaces.

g
200
hours
for
Method
13/
14
for
secondary
emissions
from
potlines.

h
Estimate
12
potlines
have
to
install
a
Method
14
manifold
and
will
perform
manual
sampling.

i
Estimate
40
hours
for
testing
of
similar
potlines
(
CEM
or
Alcan
cassette).

J
Estimate
48
potlines
will
be
monitored
under
the
alternative
monitoring
provisions
for
similar
potlines.
This
is
25
per
respondent
(
12*
48/
23
=
25).

K
Estimate
200
hours
for
a
Method
315
test
for
secondary
emissions.

l
Assume
a
total
of
22
Soderberg
potlines
and
6
plants,
this
is
14.7
per
respondent
(
22*
4/
6
=
14.7).

m
Assume
all
of
the
6
Soderberg
plants
are
tested
each
year
for
an
average
of
6
respondents/
yr.

n
Assumes
2
hours
per
day
for
monitoring
of
operating
parameters
and
visible
emissions.
o
Semiannual
reports
required
(
2/
yr),
unless
quarterly
reports
are
required
as
a
result
of
excess
emissions.

p
Assumes
10
percent
fail
to
meet
the
standard
(
0.1
x
23).

q
Assumes
90
percent
meet
the
standard
(
0.9
x
23).

r
Assumes
10
percent
must
file
startup,
shutdown,
malfunction
reports
(
0.1
x
23).

s
Assumes
3
hours
per
week
per
plant
to
enter
into
records.

t
Assumes
15
minutes
to
transmit
recorded
information.
TABLE
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
OF
THE
FINAL
STANDARD
Activity
(
A)

Hours
per
occurrence
(
B)

Hours
per
plant
per
year
(
C)
Plants
per
year
(
D)
Technical
person­
hours
per
year
(
D=
BxC)
(
E)
Managemen
t
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
person­
hours
per
year
(
Dx0.1)
(
G)

Cost,
$
a
Initial
performance
test
120
120
1b
120
6
12
5,160.7
Litigation
2,080
2,080
0.23c
478
23.9
47.8
20,566.6
Excess
Emissions
Enforcement
Activities
120
120
2.3d
276
13.8
27.6
11,869.5
Report
Review
Notification
of
applicability
Notification
of
constr./
reconstr.

Notification
of
anticipated
startup
Notification
of
actual
startup
Notification
of
special
compliance
requirements
Notification
of
initial
performance
test
Notification
of
compliance
status
Review
of
performance
test
report
Review
of
excess
emissions
report
Review
of
no
excess
emissions
report
Review
of
NESHAP
waiver
application
Review
of
startup,
shutdown,
malfunction
report
2
2
2
2
N/
A
2
8
8
8
2
N/
A
2
2
2
2
2
2
8
8
8
2
2
1b
1b
1b
1b
1b
1b
23d
2.3e
20.7f
4.6g
2
2
2
2
2
184
184
18.4
41.4
9.2
0.1
0.1
0.1
0.1
0.1
9.2
9.2
.9
2.1
0.5
0.2
0.2
0.2
0.2
0.2
18.4
18.4
1.8
4.1
0.9
86.0
86.0
86.0
86.0
86.0
7,913.0
7,913.0
791.3
1,779.3
395.7
TOTAL
BURDEN
AND
COST
(
SALARY)
1,321.0
66.1
132.0
56,809.1
Travel
Expenses
for
Tests
Attended
(
1
person
x
1
plant/
yr
x
1
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
1
round
trips/
yr)
=
$
450
TOTAL
ANNUAL
COST
$
56,809.1
+
$
450
=
$
57,259.1
a
This
cost
is
based
on
an
average
wage
of
an
employee
hourly
rate
plus
110%
overhead
cost
of
a
GS­
14
for
managerial
staff
($
68.19),
of
a
GS­
10
for
technical
staff
($
36.86),
and
a
GS­
7
for
administrative/
clerical
staff
($
27.36).
These
rates
are
from
OPM's
2001
General
Schedule
(
GS)
hourly
salary
data,
excluding
locality
pay,
basic
rates,
and
travel
associated
with
compliance
activities.

b
Assume
one
plant
per
year
over
the
next
3
years
will
install
a
new
or
reconstructed
pitch
storage
tank.

c
One
plant
in
100
will
be
involved
in
litigation
(
0.01
x
23
=
0.23).

d
Assume
EPA/
State
personnel
will
review
summary
of
performance
tests
required
to
be
submitted
by
the
23
plants
on
an
annual
basis.

e
Assume
10
percent
of
the
23
plants
(
2.3)
have
excess
emissions.

f
Assume
90
percent
of
the
23
plants
(
20.7)
do
not
have
excess
emissions.

g
Assumes
10
percent
of
the
plants
per
year
(
2.3)
will
report
a
startup,
shutdown,
malfunction
incident.
