Summary of Comments and Responses for the Information Collection Request
for National Emissions Standards for Hazardous Air Pollutants (NESHAP)
for Secondary Aluminum Production Residual Risk and Technology Review
(RTR); EPA ICR Number 2400.01 

(75 FR 43520, July 26, 2010) 

Metals and Minerals Group

Sector Policies and Program Division

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

October 6, 2010

INTRODUCTION

On July 26, 2010, EPA published a notice in the Federal Register (75 FR
43520) announcing their intent to submit a request to the Office of
Management and Budget (OMB) for a new Information Collection Request
(ICR).  The ICR will be used to collect certain information from
secondary aluminum production facilities for the National Emissions
Standards for Hazardous Air Pollutants (NESHAP) for Secondary Aluminum
Production Residual Risk and Technology Review (RTR); EPA ICR Number
24001.01.

	The notice included a request for comments on specific aspects of the
proposed ICR; we received comments from one commenter in response to the
notice.  The comments were submitted by Robert P. Strieter, VP,
Environment Health and Safety, The Aluminum Association.  The comments
are located in docket number EPA-HQ-OAR-2010-0469-0007. The EPA
responses to the comments follow the comments below, as appropriate.  

 

SUMMARY OF COMMENTS AND RESPONSES

Comment:  Requests for information relating to collocated (non-subpart
RRR regulated) sources of emissions are outside the scope of the RTR
project and are not justified in the Supporting Statement.   The
commenter cited requests for information pertaining to HAP emissions,
control devices, discharge characteristics, criteria air pollutants and
energy usage for these sources.  

Response:  During the RTR processes, EPA examines the risks from the
entire “facility”, where the “facility” includes all
HAP-emitting operations within a contiguous area and under common
control.  In other words, for each facility EPA examines 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
analyzes risks due to the inhalation of HAP that are emitted
“facility-wide” for the populations residing within 50 km of each
facility.  For these facility-wide risk analyses, 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 analysis.  The
facility wide risk analyses will also be used to determine the potential
for any environmental justice issues that might be associated with each
category as required under Executive Order 12898.  EPA evaluates 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 categories are located.  We are
requesting these data in order to conduct an accurate facility-wide risk
analysis.  In addition to the facility-wide risk analysis, we are
requesting information on criteria pollutants from all air emission
sources consistent with EPA’s new multi-pollutant sector based
strategy. 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 benefits of
multi-pollutant and sector-based analyses and approaches include the
ability to identify optimum control strategies, considering feasibility,
costs, and benefits across the different pollutant types while
streamlining administrative and compliance complexities and reducing
conflicting and redundant requirements.  Obtaining facility-wide
emissions are needed to determine if any 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
any future control strategies for this sector.  

EPA has revised the supporting statement to include justification for
requesting these data.  In addition, EPA has revised the questionnaire,
as suggested by the commenter, to eliminate the request for respondents
to reenter criteria pollutant data if this data is included in emissions
inventory reports.  

Comment:  The proposed survey data form is extremely long and the
specified 60 day response time is inadequate.  The commenter requested
that this be extended to 120 days.

Response:  EPA has agreed to complete the RTR, and propose and
promulgate a rule in accordance with a court-ordered deadline.  Because
of the time required to review and analyze the responses, including
sufficient time for quality assurance, EPA must limit the response time
to 60 days.  It should also be noted that respondents also have had time
to review the draft questionnaire to determine in advance the types of
information that will be requested. 

Comment:  The commenter has noted several instances where the
questionnaire is ambiguous or potentially confusing.  

Response:  EPA has revised the questionnaire on the basis of this
comment to clarify the questions and terminology to convey the
information requested more precisely.  

