SUPPORTING STATEMENT

FOR OMB REVIEW OF EPA ICR No. 2400.01:

INFORMATION COLLECTION REQUEST FOR SECONDARY ALUMINUM PRODUCTION
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) RISK
AND TECHNOLOGY REVIEW (RTR)

Sector Policies and Programs Division

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

June 30, 2010

SUPPORTING STATEMENT

INFORMATION COLLECTION REQUEST FOR SECONDARY ALUMINUM PRODUCTION
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS RESIDUAL RISK
AND TECHNOLOGY REVIEW 

Part A of the Supporting Statement

1.	Identification of the Information Collection

(a)	Title of the Information Collection 

“Information Collection Request for Secondary Aluminum Production
National Emission Standards for Hazardous Air Pollutants (NESHAP)
Residual Risk and Technology Review (RTR).”  This is a new information
collection request (ICR). 

(b)	Short Characterization

This information collection is being conducted by EPA’s Office of Air
and Radiation (OAR) to assist the EPA Administrator, as required by
sections 112(d)(6), and 112(f) of the Clean Air Act (CAA), as amended,
to determine the current affected population of secondary aluminum
production processes and to reevaluate emission standards for this
source category.  The information from this ICR would also be made
available to the public.

This is a one-time information collection.  Currently, information
necessary to identify secondary aluminum production facilities is
available from EPA’s National Emissions Inventory (NEI).  The NEI does
not contain all of the information (equipment, capacity, materials
processed, emissions collection and control systems, regulatory
alternatives used, and emission test data) necessary to characterize
secondary aluminum production NESHAP affected sources for purposes of
regulatory analyses.  Although some of the needed information may be
included in Title V or state air emission permits, most permits do not
contain all of the information needed and are not readily available from
any single source.  Furthermore, there are no readily available sources
for previously conducted performance test results that will provide data
for emissions of the variety of pollutants under consideration.  To
obtain this information, EPA is soliciting information with a survey,
under authority of CAA section 114, from all affected units.  EPA
intends to administer the survey in electronic (spreadsheet) format. 
The survey will be sent to all companies that own or operate secondary
aluminum manufacturing facilities.

The EPA estimates the cost to industry of the electronic information
collection (gathering, entering, and quality assuring (QA) of data
submitted in response to the survey) will be 36,248 hours and
$3,429,747, which includes $1,200 in operation and maintenance (O&M)
costs for mailing survey responses to EPA.  

2.	Need for and Use of the Collection

(a)	Need/Authority for the Collection

The secondary aluminum production source category includes any
establishment using clean charge, aluminum scrap, or dross from aluminum
production, as the raw material and performing one or more of the
following processes:  scrap shredding, scrap
drying/delacquering/decoating, thermal chip drying, furnace operations
(i.e., melting, holding, sweating, refining, fluxing, or alloying),
recovery of aluminum from dross, in-line fluxing, or dross cooling.  A
secondary aluminum production facility may be independent or part of a
primary aluminum production facility.  For purposes of this subpart,
aluminum die casting facilities, aluminum foundries, and aluminum
extrusion facilities are not considered to be secondary aluminum
production facilities if the only materials they melt are clean charge,
customer returns, or internal scrap, and if they do not operate sweat
furnaces, thermal chip dryers, or scrap dryers/delacquering
kilns/decoating kilns.  The federal emission standard that is the
subject of this information collection is the National Emission
Standards for Hazardous Air Pollutants for Secondary Aluminum Production
(40 CFR part 63, subpart RRR).

 The existing subpart RRR NESHAP regulates HAP emissions from facilities
that are major sources of HAP that operate aluminum scrap shredders,
thermal chip dryers, scrap dryers/delacquering kilns/decoating kilns,
group 2 furnaces, sweat furnaces, dross only furnaces, rotary dross
coolers, and secondary aluminum processing units (SAPUs).  SAPUs include
group 1 furnaces and in-line fluxers.  Area sources of HAP are regulated
only with respect to emissions of dioxins/furans (D/F) from thermal chip
dryers, scrap dryers/delacquering kilns/decoating kilns, sweat furnaces,
and SAPUs.

Section 112(f)(2) of the CAA directs EPA to conduct risk assessments on
each source category subject to maximum achievable control technology
(MACT) standards and determine if additional standards are needed to
reduce residual risks.  The section 112(f)(2) residual risk review is to
be done within 8 years after promulgation.  Section 112(d)(6) of the CAA
requires EPA to review and revise the MACT standards, as necessary,
taking into account developments in practices, processes, and control
technologies.  The section 112(d)(6) technology review is to be done at
least every 8 years.  The NESHAP for Secondary Aluminum Production (40
CFR part 63, subpart RRR) was first promulgated in 2000.  

The data used as the basis for the originally promulgated secondary
aluminum production NESHAP are over 15 years old.  The Agency is aware
that significant changes have been made in the intervening years in the
number of affected facilities, in industry ownership practices, and  in
emission collection and control configurations.  Further, in light of
the statutory requirements for reviewing emission standards under CAA
section 112, the Agency has concluded that obtaining updated information
will be important to informing its decisions on the secondary aluminum
production NESHAP RTR.  

Additional facility-specific information is needed to better
characterize emission sources, refine the risk analysis, and develop
revisions to the NESHAP, as appropriate.  An update of the 2005 National
Air Toxics Assessment (NATA)/National Emissions Inventory (NEI) data
sets and more specific information needed for further rulemaking would
be derived from the ICR.  Information collected directly from companies
owning or operating secondary aluminum production facilities will have
the greatest practical utility for purposes of performing the RTR as
information from the affected industry will contain the most up-to-date,
accurate, and reliable equipment and operational data for each facility.
 The ICR will request information for current equipment information and
emissions from the most recent years of production, and therefore, will
not suffer from the considerable “lag time” that can be associated
with different permit review cycles (e.g., where the currently available
inventory does not yet reflect recent changes in equipment).

CAA section 114(a) states that the Administrator may require any owner
or operator subject to any requirement of the 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.

(b)	Use/Users of the Data

As mentioned previously, the data used for the originally promulgated
NESHAP are incomplete, outdated and do not adequately reflect changes in
emissions collection and control configurations that have occurred since
promulgation of the MACT standards.  The MACT standards contain a number
of compliance alternatives to allow for a variety of equipment
configurations and process changes to be used in meeting the emission
standards.  At present, the EPA does not have a database reflecting the
post-MACT configurations of secondary aluminum production affected
sources and air pollution control systems.  It is essential for the EPA
to have updated information to use in the regulatory analyses required
under CAA sections 112(d) and 112(f)(2).  The data would also allow the
Agency to evaluate compliance options for startup and shutdown periods. 


The data collected will be used to update facility information and
equipment configuration, develop new estimates of the population of
affected units, and identify the control measures and emission limits
being used for compliance with the existing NESHAP.  This information,
along with existing permitted emission limits will be used to establish
a baseline for purposes of the regulatory reviews.  The emissions test
data collected will be used to verify the performance of existing
control measures, examine variability in emissions, evaluate emission
limits, and to determine the performance of superior control measures
that may be considered for purposes of reducing residual risk. 
Emissions data may also be used along with process and emission unit
details to consider subcategories for further regulation and to estimate
the environmental and cost impacts associated with any regulatory
options considered.  

In addition to informing the RTR regulatory analyses for the secondary
aluminum production industry, it is EPA’s intent that the NATA NEI
updates supplied through this information collection be used in future
versions of the NATA NEI and its successor, the Emissions Inventory
System (EIS).  The NEI is used by EPA, States, and the public for a
variety of purposes including tracking of national trends in emissions
of criteria and hazardous air pollutants.  More information in the NEI
can be found at http://www.epa.gov/air/data/neidb.html.

The non-confidential information collected with this ICR would also be
available to the public, including aluminum industry trade groups that
may find the information useful for their ongoing data gathering,
analyses, and publications.  In addition, such trade groups may wish to
use the data collected to review and verify EPA’s regulatory
conclusions. 

3.	Non-duplication, Consultations, and Other Collection Criteria 

(a)	Non-duplication 

The Agency recognizes that some of the information requested in the
information collection effort may already be included in the submittals
made by individual companies, pursuant to State and national emission
inventories, operating permits applications, initial notification forms,
and compliance reports.  However, the complete extent of the data fields
requested under this survey is not available in any consistent or usable
format.  Additionally, these sources do not provide detailed emissions
test data.  As mentioned previously, there is a lag time associated with
State and national emission inventories, and permit review cycles. 
There is also a lag time associated with obtaining emission test reports
from State agencies (i.e., agencies may be reluctant to release emission
test results they have not yet processed).  The EPA’s proposed
information collection seeks up-to-date equipment configuration and
operational data for the most recent years of production.  Although some
State permits are provided to the public as searchable portable document
format files (pdfs), many States do not provide electronic versions of
their issued Title V permits.  Even when the permit is available, the
unit-specific operating data are often not contained within the permit. 
Some of the initial notifications and compliance reports submitted are
available in hard-copy only, whereas only the facility-level information
(facility name, location, contact) is available in an electronic format.
 In order to address startup and shutdown issues, the Agency has
obtained semi-annual compliance reports for secondary aluminum
production processes and found the reports to contain a widely varying
level of detail.  Such variation in the level of detail of permits and
compliance reports means that it would be extremely time consuming for
the Agency to mine the level of process detail needed for regulatory
analyses from existing documents (assuming that these documents were
readily available to EPA), and that significant data gaps would remain
even after data from existing documents were compiled.  Emissions test
reports are often retained as hard copies by State agencies and thus are
not readily available for all facilities.    

To summarize, the information requested relevant to the current
(post-MACT) equipment configuration and operation, regulatory
alternatives, emissions data, and effectiveness of various control
systems at removing HAP is not readily available from other sources.  In
the absence of an industry data collection, the EPA would be forced to
try an obtain permits, compliance reports, and emissions test reports
from States; extract information from these reports (which vary in
detail); and then to fill data gaps where information is not available
from the reports obtained.  This process of acquiring and mining data
from existing reports would require more time than an industry data
collection, and ultimately can be expected to yield incomplete
information.  Information collected directly from companies operating
secondary aluminum production processes would provide the most timely
and complete post-MACT data set with the greatest practical utility for
purposes of performing the RTR reviews that are due to be completed
under CAA sections 112(d) and (f)(2).  

(b)	Public Notice Required Prior to ICR Submission to OMB

This ICR is being submitted for public review as required by the
Paperwork Reduction Act of 1995 (PRA) and the subsequent rule issued by
the Office of Management and Budget (OMB) on August 29, 1995 (60 FR
44978).  EPA will address public comments before submitting the ICR to
OMB.

(c)	Consultations 

Feedback was received from the Aluminum Association and the Institute of
Scrap Recycling Industries regarding the scope of the secondary aluminum
production industry survey.  An opportunity for detailed comments on the
electronic survey will be provided by the Federal Register notice
concerning the availability of the ICR for public review and comment.

(d)	Effects of Less Frequent Collection

This ICR will require the owner/operator of each secondary aluminum
production facility to complete an electronic update of their 2005
National Air Toxics Assessment (NATA) NEI data set to be used for RTR
purposes.  In addition, facilities will be asked to complete an
electronic survey of general facility information (production processes
and capacities), equipment details, permit limits, emission control
measures, and emissions test data (previously conducted tests only). 
EPA expects the information requested in this survey to be a one-time
effort.

 (e)	General Guidelines

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5

 (f)	Confidentiality

Respondents will be required to respond under the authority of CAA
section 114.  If a respondent believes that disclosure of certain
information requested would compromise a trade secret, it should be
clearly identified as such and will be treated as confidential until and
unless it is determined in accordance with established EPA procedure as
set forth in 40 CFR Part 2 not to be entitled to confidential treatment.
 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).  Any
information subsequently determined to constitute a trade secret will be
protected under 18 U.S.C. 1905.  If no claim of confidentiality
accompanies the information when it is received by EPA, it may be made
available to the public without further notice (40 CFR 2.203, September
1, 1976).  Because CAA section 114(c) exempts emission data from claims
of confidentiality, the emission data provided may be made available to
the public.  Therefore, emissions data should not be marked
confidential.  A definition of what EPA considers emissions data is
provided in 40 CFR 2.301(a)(2)(i).

 (g)	Sensitive questions 

This section is not applicable because this ICR will not involve matter
of a sensitive nature.

4.	The Respondents and the Information Requested

(a)	Respondents/NAICS Codes.

Respondents affected by this action are owners/operators of secondary
aluminum production facilities.  In the U.S., there are approximately
400 secondary aluminum production facilities including approximately 100
major sources of HAP and 300 area sources of HAP.  Major sources are
currently regulated for emissions of particulate matter (PM) as a
surrogate for particulate metal HAP, hydrogen chloride, dioxins and
furans (D/F), and total hydrocarbon (THC) as a surrogate for organic HAP
other than D/F.  Area sources are regulated only for D/F. 

Approximately 200 companies operate secondary aluminum production
facilities with an average of approximately two facilities per company. 


The North American Industry Classification System (NAICS) codes for
respondents affected by the information collection include 331314 for
secondary smelting and alloying of aluminum as well as secondary
aluminum production facilities that are collocated at primary aluminum
production facilities (331312); aluminum sheet, plate and foil
manufacturing facilities (331315); aluminum extruded product
manufacturing facilities (331316); other aluminum rolling and drawing
facilities (331319); aluminum die casting facilities (331521); aluminum
foundry facilities (331524); and sweat furnaces which can be included in
various NAICS categories including, but not limited to, 562920,  493110,
811490, 423320, 423930, 423120, 423140, 339999, and 488410.

(b)	Information Collected   

(i)	Data Items.  Each owner/operator of each secondary aluminum
production facility will be required to complete an electronic survey
that contains several components.  The draft electronic survey is a
Microsoft Excel spreadsheet file that is divided into two worksheets
(“tabs” within the spreadsheet).  Respondents that own or operate
major sources of HAP will be required to complete the major source tab. 
Respondents that own or operate area sources of HAP will be required to
complete the area source tab.  Respondents will also be asked to supply
plant schematics; title V permits; operating permits; permit
applications; performance test reports; emission inventory reports;
copies of consent decrees or orders affecting their plants; notices of
operating violations; startup, shutdown and malfunction plans; and
site-specific operating, maintenance and monitoring plans.   Respondents
will also be required to correct, update or complete a table of data for
their plants for inclusion in the NATA NEI.  

Although a large amount of information is needed for regulatory review
of the NESHAP, the EPA has designed the secondary aluminum production
information collection in a way to minimize the burden associated
supplying and processing this information.  The EPA will pre-populate
survey spreadsheets with each facility's 2005 NATA NEI data set to be
reviewed (thereby reducing respondent burden to locate and import their
facility’s NEI data).  For facilities that are not presently included
in the NATA NEI, respondents will be provided with a blank spreadsheet
in which to enter data.  The secondary aluminum production information
collection is being administered in spreadsheet form (as opposed to data
base software) because respondents are likely to be more familiar with
spreadsheet use than with data bases and, following QA, data from the
Excel spreadsheet rows can be readily imported into Access data base
software for use by the Agency (eliminating the time required for EPA to
key-enter data).  The secondary aluminum production spreadsheets will be
provided to owners and operators on a compact disk which respondents can
use to save and submit their survey spreadsheets and other materials
such as electronic copies of flow diagrams and emission test reports. 
The burden associated with collection of emissions test data has been
reduced in several ways:  

(1) Area sources of HAP are being asked to respond to a shortened
worksheet that addresses affected sources that are regulated under the
NESHAP and other sources of HAP emissions.   

(2) Data are being requested for the HAP surrogates defined in the MACT
standards and any available data related to speciated HAP.

(3) Respondents may provide electronic or hard copy emissions test
reports, whichever they find to be less burdensome.

(4) Respondents are being asked to transmit the responses (except for
confidential business information) electronically.

(ii)	Respondent Activities.  The activities a respondent must undertake
to fulfill the requirements of the information collection are presented
in Attachment 2.  These include:  i) read instructions; ii) provide
information on each affected source through electronic survey; and iii)
submit hard or electronic copies of flow diagrams, previous emission
test reports, and available CEMS or COMS data.

5.	The Information Collected – Agency Activities, Collection
Methodology, and Information Management

(a)	Agency Activities

A list of activities required of the EPA is provided in Attachment 3. 
These include: i) develop electronic questionnaire and packages for mail
out; ii) answer respondent questions; iii) review and analyze responses
and emissions data; and iv) analyze requests for confidentiality.

 (b)	Collection Methodology and Management

In collecting and analyzing the information associated with this ICR,
EPA will use personal computers and applicable spreadsheet and database
software.  To better facilitate uniformity in the format of the
requested data, and, thus, increase the ease of database entry,
standardized survey questions, example responses, and Excel spreadsheet
forms will be distributed to respondents.  EPA will ensure the accuracy
and completeness of the collected information by reviewing each
submittal.  Flow diagrams may be used to answer any questions revealed
during quality assurance (QA) of each submittal.  The EPA may place
follow-up calls to respondents should questions remain after reviewing
all materials submitted.  Following QA of each submittal, the
spreadsheet information from each facility will be uploaded into an
Access data base for further analysis.  Portions of survey responses
claimed as CBI will be housed in a separate data base from the non-CBI
survey responses.  In addition, a copy of the NATA NEI updates submitted
will be routed for inclusion in EPA’s residual risk input data base,
and for inclusion in future versions of the NATA NEI and its successor,
the Emissions Inventory System (EIS).  Emissions test report data will
be entered into a data base by EPA (or EPA contractor personnel)
familiar with extracting test data from test reports. The resulting data
bases will be QA’d prior to and as part of regulatory analyses.

 (c)	Small Entity Flexibility

All respondents required to comply with the secondary aluminum
production survey will be subject to the same requirements.  EPA expects
that half of the respondents may be small entities.  Small entities are
likely to be area sources.  Small entities and other companies that own
and/or operate facilities that are not major sources of HAP emissions
(i.e., area sources) will have fewer affected sources per facility and
fewer data (because area sources are regulated only for D/F).  Even if
they are major sources of HAP emissions, small entities would have fewer
portions of the survey to complete, as their operations would likely be
less extensive.  The Agency also plans to use an electronic format of
the questionnaire in order to reduce the burden and improve the data
accuracy from all respondents, including small entities.  In addition,
the survey will contain a question to determine the small entity status
of a facility.  This question will help to identify, quantify, and
minimize the burden on small entities during the rulemaking process.  

(d)	Collection Schedule

EPA anticipates issuing the CAA section 114 letters by late-2010.  These
CAA section 114 letters would require the owner/operator of each
secondary aluminum production facility to complete the secondary
aluminum production facility survey spreadsheet (including NATA NEI
update) and submit emissions test data within 60 days of receipt of the
survey.  EPA will compile and analyze survey response data upon receipt.

6.	Estimating the Burden and Cost of the Collection

(a)	Estimating Respondent Burden and Costs

Attachment 2 presents estimated costs for the required data collection
activities.  Labor rates and associated costs are based on Bureau of
Labor Statistics (BLS) data.  Technical, management, and clerical
average hourly rates for private industry workers and were taken from
the United States Department of Labor, Bureau of Labor Statistics,
September 2009, “Table 2. Civilian Workers, by occupational and
industry group,” available at   HYPERLINK
"http://www.bls.gov/news.release/ecec.t02.htm" 
www.bls.gov/news.release/ecec.t02.htm .  Wages for occupational groups
are used as the basis for the labor rates with a total compensation of
$46.76 per hour for technical, $54.52 per hour for managerial, and
$23.11 per hour for clerical.  These rates represent salaries plus
fringe benefits and do not include the cost of overhead.  An overhead
rate of 110 percent is used to account for these costs.  The
fully-burdened hourly wage rates used to represent respondent labor
costs are: technical at $98.20, management at $114.49, and clerical at
$48.53.  These estimates represent the one-time burden that will be
incurred by the recipients.

(b)	Estimating Agency Burden and Costs

The costs the Federal Government would incur are presented in Attachment
3.  The Agency labor rates are from the Office of Personnel Management
(OPM) 2009 General Schedule which excludes locality rates of pay.  These
rates can be obtained from Salary Table 2010-GS, available on the OPM
website at   HYPERLINK "http://www.opm.gov/oca/10tables/html/gs_h.asp" 
www.opm.gov/oca/10tables/html/gs_h.asp .  The government employee labor
rates are $16.28 per hour for clerical (GS-7, Step 1), $34.34 for
technical (GS-13, Step 1), and $47.74 for managerial (GS-15, Step 1). 
These rates were increased by 60 percent to include fringe benefits and
overhead.  The fully-burdened wage rates used to represent Agency labor
costs are: clerical at $26.05, technical at $54.94, and managerial at
$76.38.

(c)	Estimating the Respondent Universe and Total Burden and Costs

Estimates based on previous surveys of the industry and review of
operating permits indicate that the potential respondent universe
consists of 400 facilities. All 400 of these facilities will be required
to complete some portion of the electronic survey.  The government
burden estimate provided in Attachment 3 assumes that 5 percent of the
respondents will not be subject to the NESHAP.  However, it is not known
how many of these claims will be valid so all respondents are included
in the burden estimate for respondents (in Attachment 2).  Attachment 2
lists the various portions of the survey in detail.  

 (d)	Bottom Line Burden Hours and Costs Tables

(i)	Respondent tally.  The bottom line industry burden hours and costs,
presented in Attachment 2, are calculated by summing the person-hours
column and by summing the cost column.  The burden and cost to the
industry is 36,248 hours and $3,428,547.  No capital or annualized costs
are applicable because this is a one-time submittal.  O&M costs of
$1200.00 are estimated for postage to mail in the survey response to
EPA, for portions of the responses that can not be submitted
electronically.   

(ii)	Agency tally. The bottom line Agency burden and cost, presented in
Attachment 3 is calculated in the same manner as the industry burden and
cost.  The estimated burden and cost are 2,182  hours and $116,415,
which includes $6,900 in O & M costs to send CAA section 114 letters to
all respondents with electronic return receipt and a compact disk
containing the electronic spreadsheet, pre-populated NATA NEI
spreadsheets, questionnaire printing costs, and computer storage of data
received.

(iii)	The complex collection.  This ICR is a simple collection;
therefore, this section does not apply.

(iv)	Variations in the annual bottom line.  This section does not apply
as this is a onetime collection.

(e)	Reasons for Change in Burden

This is the initial estimation of burden for this information
collection; therefore, this section does not apply. 

(f)	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 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.

The total cost burden for the secondary aluminum production data
gathering effort is estimated to be 36,248 hours and $3,429,747 (91
hours and $8,571/respondent for 400 respondents.  This ICR does not
include any requirements that would cause the respondents to incur
either capital or start-up costs.  O&M costs of $1200 ($3/respondent)
are estimated for postage to mail portions of the survey response that
cannot be submitted electronically to EPA. 

INFORMATION COLLECTION REQUEST FOR SECONDARY ALUMINUM PRODUCTION
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
RESIDUAL RISK AND TECHNOLOGY REVIEW (RTR)

Part B of the Supporting Statement

1.	Respondent Universe

Estimates based on information collected in the development of the
current NESHAP and a review of operating permits indicate that the
potential respondent universe consists of 400 respondents.  All 400
respondents will be required to complete some portion of the electronic
survey.  The government burden estimate provided in Attachment 3 assumes
that 5 percent of facilities will provide documentation that they are
not subject to the secondary aluminum production NESHAP.  However, it is
not known how many of these claims will be valid so all facilities are
included in the burden estimate for respondents (in Attachment 2). 
Attachment 2 lists the various portions of the survey in detail and
provides an estimated number of respondents required to complete each
portion of the survey.  Assumptions used in the burden estimates are
that a total of 400 facilities composed of 100 major sources of HAP and
300 area sources of HAP will be subject to the NESHAP.   

2.	Response Rates

Since the information will be requested pursuant to the authority of CAA
section 114, EPA expects that all respondents requested to submit
information will do so.     

List of Attachments

1.	Draft Questionnaire Content

2.	Industry Burden and Costs for Responding to the Questionnaire

3.	Agency Burden and Costs

Attachment 1.

Draft Questionnaire Content

The draft questionnaire may be found in separate files accompanying this
supporting statement, including the following:

There is a “lag time” associated with compiling large State or
national emission inventories.  For example, an updated version of the
NEI database is compiled every three years, but the information
contained in the NEI may be based on prior years if states do not submit
current data.  There can also be a “lag time” associated with
posting of recent permits to State websites (particularly if permits are
only posted every 5 years as they are reviewed).  

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