  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS: SECONDARY
ALUMINUM PRODUCTION

PART A

1.0	Identification of the Information Collection

(a)	Title and Number of the Information Collection.

	“National Emission Standards for Secondary Aluminum Production.”
This is a new information collection request (ICR), and the EPA tracking
number is 2453.02.

(b)	Short Characterization.

	This ICR covers information collection requirements in these final
amendments to the Secondary Aluminum NESHAP (40 CFR part 63, subpart
RRR).

	The potential respondents are owners or operators of any existing, new,
or reconstructed secondary aluminum production plant. Per the
applicability section of subpart RRR, the following affected sources at
a secondary aluminum production plant are covered: 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,
which includes group 1 furnaces and  in-line fluxers. The secondary
aluminum industry consists of approximately 161 secondary aluminum
production facilities, of which the EPA estimates 53 to be major sources
of HAP. The final rule corrects and clarifies various rule requirements
and provisions. Specifically, the final rule   requires selected
affected sources to comply with the emissions limits at all times
including periods of startup and shutdown; adds a requirement to report
performance testing through the Electronic Reporting Tool (ERT); adds
provisions allowing owners and operators to change furnace
classifications; adds requirements for testing uncontrolled furnaces;
adds requirements to test for hydrogen fluoride; adds operating
requirements such as monitoring of lime injection rates; adds
alternative operating requirements for sweat furnaces; and makes
corrections and clarifications to the applicability, definitions,
operating, monitoring, and performance testing requirements. The
information collection requirements associated with the final amendments
to the Secondary Aluminum Production NESHAP are listed in Attachment 1.

2.	Need For and Use of the Collection

(a)	Need/Authority for the Collection.

	Section 112 of the Clean Air Act (CAA) requires the EPA to establish
NESHAP for both major and area sources of HAP that are listed for
regulation under CAA section 112(c). A major source is a stationary
source that emits or has the potential to emit more than 10 tons per
year (tpy) of any single HAP or more than 25 tpy of any combination of
HAP. An area source is a stationary source that is not a major source
(i.e., an area source does not emit and does not have the potential to
emit more than 10 tpy of any single HAP or more than 25 tpy of any
combination of HAP). Both major and area sources are subject to subpart
RRR. For major sources, these technology-based standards must reflect
the maximum degree of emission reductions of HAP achievable (after
considering cost, energy requirements, and non-air quality health and
environmental impacts) and are commonly referred to as maximum
achievable control technology (MACT) standards. Section 112(d)(6)
requires the EPA to review these technology-based standards and to
revise them “as necessary (taking into account developments in
practices, processes, and control technologies)” no less frequently
than every 8 years. In addition, section 112(f) of the CAA requires the
EPA to determine for source categories subject to certain CAA section
112(d) standards whether the emissions limitations provide an ample
margin of safety to protect public health. For MACT standards for HAP
“classified as a known, probable, or possible human carcinogen” that
“do not reduce lifetime excess cancer risks to the individual most
exposed to emissions from a source in the category or subcategory to
less than 1-in-1 million,” the EPA must promulgate residual risk
standards for the source category (or subcategory) as necessary to
provide an ample margin of safety to protect public health. In doing so,
the EPA may adopt standards equal to existing MACT standards, if the EPA
determines that the existing standards are sufficiently protective. The
EPA must also adopt more stringent standards, if necessary, to prevent
an adverse environmental effect, but must consider cost, energy, safety
and other relevant factors in doing so.

	Certain records and reports are necessary for the Administrator to
confirm the compliance status of sources subject to NESHAP, identify any
new or reconstructed sources subject to the standards, and confirm that
the standards are being achieved on a continuous basis. These
recordkeeping and reporting requirements are specifically authorized by
section 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the
part 63 NESHAP General Provisions. The recordkeeping and reporting
requirements for operating permits (i.e., title V permits) are contained
in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63 and 70 or 71, the owner
or operator must keep each record for 5 years following the date of each
occurrence, measurement, maintenance, corrective action, report or
record.

(b)	Use/Users of the Data.

	The information will be used by the delegated authority (state agency,
or Regional Administrator if there is no delegated state agency) to
ensure that the standards and other requirements are being achieved.
Based on review of the recorded information at the site and the reported
information, the appropriate authority can identify facilities that may
not be in compliance and decide which facilities, records or processes
may need inspection.

3.	Nonduplication, Consultations and Other Collection Criteria

(a)	Nonduplication.

A computer search of the EPA’s ongoing ICRs revealed no duplication of
information-gathering efforts.

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

	This section is not applicable because this is a rule-related ICR.

(c)	Consultations.

The final rule was developed in consultation with individual secondary
aluminum production companies and trade associations. The non-EPA
persons consulted on the information collection activities are
identified in Table 1.

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact	Organization	Telephone No.

Charles Johnson, Jr.	The Aluminum Association, Inc.	703-358-2981

Mike Palazzolo	Alcoa, Inc.	412-553-4832

Gary Barnett	Aleris International, Inc.	216-910-3697

Steve Royer	Logan Aluminum, Inc.	270-755-6390



(d)	Effects of Less Frequent Collection.

	If the relevant information was collected less frequently, the
delegated permitting authority (state or the EPA) will not be reasonably
assured that a facility is in compliance with the standards.

(e)	General Guidelines.

	None of the guidelines in 5 CFR 1320.6 are being exceeded.

(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/NAICS Codes.

Potential respondents under subpart RRR are owners or operators of any
existing or new facility engaged in Secondary Aluminum Productions
operations. Secondary Aluminum Production facilities are primarily
classified under NAICS code 331314, Secondary Aluminum Production. There
are an estimated 161 facilities that would be subject to the final rule
for the Secondary Aluminum Production NESHAP.

 (b)	Information Requested.

	(i) Data Items, Including Recordkeeping Requirements. Attachment 1,
Information Requirements, summarizes the data items, including
recordkeeping and reporting requirements, for the Secondary Aluminum
Production source category.

	(ii) Respondent Activities. The respondent activities that will be
required by the final amendments to the Secondary Aluminum Production
NESHAP are identified in Table 2 and are introduced in section 6(a).

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

(a)	Agency Activities.

	The Agency activities associated with the final amendments to the
Secondary Aluminum Production NESHAP are provided in Table 3 and are
introduced in section 6(c).

(b)	Collection Methodology and Management.

	Data and records maintained by the respondents are tabulated and
published for use in compliance and enforcement programs of the
appropriate authority. The EPA is the appropriate authority until the
state or local agency is delegated authority to implement the final
amendments to the rule. Therefore, information contained in any report
submitted to the Regional Administrator will be entered into the Air
Facility System (AFS), which is operated and maintained by the EPA’s
Office of Compliance. AFS is the EPA’s database for the collection,
maintenance, and retrieval of compliance data for approximately 125,000
industrial and government-owned facilities. The EPA uses the AFS for
tracking air pollution compliance and enforcement by local and state
regulatory agencies, EPA regional offices and EPA headquarters. The EPA
and its delegated authorities can edit, store, retrieve and analyze the
compliance data.

(c)	Small Entity Flexibility.

	The Small Business Administration defines a small entity engaging in
Secondary Aluminum Production as a firm having no more than 750
employees. Of the 28 entities affected by this final rule, nine of them
are small. Of these nine, all of them are estimated to experience a
negative cost (i.e., a cost savings) as a result of the final amendments
to the rule. After considering the economic impacts of these changes on
small entities, this action will not have a significant economic impact
on a substantial number of small entities. To reduce impacts, we are
finalizing new provisions that would increase the industry’s
flexibility as to how they operate group 1 furnaces and sweat furnaces.
In addition, we corrected certain provisions of the rule as well as made
revisions to help clarify the rule’s intent. 

(d)	Collection Schedule.

	The specific frequency for each information collection activity within
this request is shown in Table 2 for the Secondary Aluminum Production
source category.

6.	Estimating the Burden and Cost of the Collection

(a)	Estimating Respondent Burden.

	The annual burden estimates for the final amendments to the Secondary
Aluminum Production NESHAP are shown in Table 2. These numbers were
derived from estimates based on the EPA’s experience with other
standards. No burden estimates are provided for new sources because no
new facilities are expected to become affected sources during the
three-year implementation period of this ICR.

(b)	Estimating Respondent Costs.

	(i) Estimating Labor Costs. Table 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 2011, “Table 2. Civilian
Workers, by occupational and industry group,” available at
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
$47.21 per hour for technical, $57.82 per hour for managerial and $23.72
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 $99.14, management at $121.42 and clerical at $49.81.

	(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. An
estimated 107 furnaces and 27 facilities would need to have temporary
hoods installed every 5 years and testing conducted for a total capital
cost of $17.3 million and a total annualized capital cost of $2.3
million. Total annualized cost per furnace would average $21,650 per
year. As a result of the requirement to measure HF emissions, 8 affected
facilities would incur a total annual O&M cost of $11,000. The final
rule also allows owners/operators to switch furnace classifications,
which would result in total annual O&M costs for testing of $500,000/yr
or, for an estimated 50 furnaces, a cost of $10,000 per furnace, or
$14,706/yr per facility at 34 facilities. 

	(iii) Annualizing Capital Costs. Annualized capital costs are
approximately $2.3 million or about $85,800/facility.

 (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 collection requirements. Because
reporting and recordkeeping requirements on the part of the respondents
are required under the operating permits rules in 40 CFR part 70 or part
71 and the part 63 NESHAP General Provisions, 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 the
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 3.

	The Agency labor rates are from the Office of Personnel Management
(OPM) 2011 General Schedule, which excludes locality rates of pay. These
rates can be obtained from Salary Table 2011-GS available on the OPM
website,   HYPERLINK "http://www.opm.gov/oca/11tables/pdf/gs_h.pdf" 
http://www.opm.gov/oca/11tables/pdf/gs_h.pdf . The government employee
labor rates are $15.63/hour for clerical (GS-6, Step 3), $28.88 for
technical (GS-12, Step 1) and $38.92/hr for management (GS-13, Step 5).
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 $25.01/hour, technical at $46.21/hour and
management at $62.27/hour.

(d)	Estimating the Respondent Universe and Total Burden and Costs.

There are an estimated 161 existing facilities that are currently
subject to the Secondary Aluminum Production NESHAP. No new major
sources are expected the year following promulgation of these
amendments. Consequently, the number of secondary aluminum respondents
in the year following promulgation is 161 respondents per year.

For the final amendments to the Secondary Aluminum Production NESHAP,
the components of the total annual burden attributable to this ICR
include reading the amendments to the NESHAP; monthly verification of
lime injection rates; analysis of performance test samples for HF;
construction of temporary hooding and performing emissions tests on
uncontrolled group 1 furnaces; and when a furnace classification is
being changed, the requisite reporting and emissions testing to
demonstrate compliance. All other recordkeeping and reporting activities
are already accounted for in the ICR for the NESHAP.

(e)	Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs
presented in Table 2 are calculated by adding person-hours per year down
each column for technical, managerial and clerical staff, and by adding
down the cost column. The average annual burden for the recordkeeping
and reporting requirements in the final rule amendments to subpart RRR
for the 161existing facilities that are subject to the Secondary
Aluminum Production NESHAP is 1,695 person-hours, which is the sum of
the technical, management and clerical labor hours, with an annual
average cost of $162,379. The estimated annual operations and
maintenance costs (O&M) as a result of these amendments is $511,000.
Estimated annualized capital costs to the industry for the final rule
amendments are $2.3 million for a total estimated annualized costs
(annualized capital and O&M) of $2.8 million.

	(ii) The Agency tally. The average annual Federal Government cost is
$12,231 for 271 hours (i.e., the sum of the technical, management and
clerical labor hours) for the final rule amendments to subpart RRR. The
bottom line Agency burden hours and costs presented in Table 4 are
calculated by adding person-hours per year down each column for
technical, managerial and clerical staff and by adding down the cost
column.

	(iii) Variations in the annual bottom line. This section does not apply
since no significant variation is anticipated.

(f)	Reasons for Change in Burden.

The EPA provides an adjustment to this ICR that estimates the costs of
the notification, recordkeeping and reporting requirements associated
with the final rule amendments that would add provisions allowing owners
and operators to change furnaces classifications; add requirements for
testing uncontrolled furnaces; add requirements to test for hydrogen
fluoride; and add requirements for the monitoring of lime injection
rates.

 (g)	Burden Statement

	The average annual respondent burden for the final rule amendments to
the Secondary Aluminum Production NESHAP is estimated at 11
person-hours.

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 the EPA’s
regulations in 40 CFR part 63 are listed in 40 CFR part 9.

	To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates and any suggestions for minimizing
respondent burden, including through the use of automated collection
techniques, the EPA has established a public docket for this ICR under
Docket ID No. EPA-HQ-OAR-2010-0544 which is available for online viewing
at   HYPERLINK "http://www.regulations.gov"  http://www.regulations.gov
, or in person viewing at the Air and Radiation Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room B-102, 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)
566-1927. An electronic version of the public docket is available at  
HYPERLINK "http://www.regulations.gov."  http://www.regulations.gov. 
This site can be used 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. When
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 Officer for EPA.
Please include the relevant Docket ID Number (EPA-HQ-OAR-2011-0797) in
any correspondence.

PART B

	This section is not applicable because statistical methods are not used
in data collection associated with the final rule.

TABLE 2. ANNUAL RESPONDENT BURDEN AND COST – FINAL AMENDMENTS TO
SECONDARY ALUMINUM NESHAPa

Burden item	(A)

Person-hours per occurrence	(B)

No. of occurrences per respondent	(C)

Person-hours per respondent (C=A*B)	(D)

Respondents per year	(E)

Technical person-hours per year (E=C*D)	(F)

Management person-hours per year

(E*0.05)	(G)

Clerical person-hours per year (E*0.1)	(H)

Costa, $

1.	Applications	N/A







	2.	Surveys and Studies	N/A







	3.	Acquisition, Installation, and Utilization of Technology and Systems
N/A







	4.	Reporting Requirements









A.	Read instructionsb	4	1	4	161	644	32.2	64.4	$70, 964

B.	Required activities









C.	Create information	N/A







	D.	Gather existing information	N/A







	 E. Write report (changing furnace classification)c	2	1	2	50	100	5	10
$11,019











5.	Recordkeeping Requirements









A.	Read instructions	See 4A







	B.	Plan activities	N/A







	C.	Implement activities 









Verify lime injection rate	0.1	36	3.6	161	579.6	28.98	57.96	$63,867

Changing furnace classification	2	1	2	50	100	5	10	$11,019

D.	Develop record system	N/A







	E.	Time to enter information	See 4C







	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	1	1	1	50	50	2.5	5	$5,510

I.	Time for audits	N/A







	TOTAL ANNUAL LABOR BURDEN AND COST (SALARY)



	1473.6	73.68	147.36	$162,379

ANNUAL COSTS (O&M)

	      HF testingd	$11,000

      Changing furnace classification, testingc	$500,000

ANNUALIZED CAPITAL COSTSe

$2,316,550

TOTAL ANNUALIZED COSTS (annualized capital cost and annual O&M costs)

$2,827,550

N/A = not applicable.

a	This ICR uses the following labor rates: $121.42 for managerial labor,
$99.14 for technical labor, and $49.81 for clerical labor. These rates
are based on the U.S. Department of Labor, Bureau of Labor Statistics,
Occupational Employment and Wages, September, 2011.

b	There is an estimated 161 existing facilities; no new facilities are
expected.

c   An estimated 50 facilities would change furnace classifications once
per year. Testing for furnace changing is estimated at a cost of $10,000
per facility.

d   An estimated 8 facilities would be required to test HF with a total
cost of $11,000/yr.

e	27 facilities would be required to construct temporary hoods for
testing at $226,000/facility every 5 years.

TABLE 3. ANNUAL BURDEN AND COST TO THE AGENCY – FINAL AMENDMENTS TO
SECONDARY ALUMINUM NESHAP

Burden item	(A)

Person-hours per occurrence	(B)

Occurrences per respondent	(C)

EPA person-hours/year (C=A*B)	(D)

Facilities per year	(E)

Technical person-hours/year (E=C*D)	(F)

Management person-hours/year (F=0.05*E)	(G)

Clerical person-hours/year (G=0.1*E)	(H)

Costa, $

Report Review:









Review performance test reports and reports from facilities changing
furnace  classificationb	4	1	4	59	236	11.8	23.6	$12,231

TOTAL BURDEN AND COST





$12,231

a	This ICR uses the following average hourly labor rates: $62.27 for
managerial (GS-13, Step 5), $46.21 (GS-12, Step 1) for technical, and
$25.01 (GS-6, Step 3) for clerical. These rates are from the Office of
Personnel Management (OPM) 2011 General Schedule, which excludes
locality rates of pay.

b	Assumes agency will review all of the annual reports - including the 4
HF tests/yr, 5 tests/yr for uncontrolled furnaces and 50 reports/yr for
changing furnace classification.

ATTACHMENT 1. INFORMATION REQUIREMENTS – FINAL AMENDMENTS TO
SECONDARY ALUMINUM NESHAP

Requirement	Citation for existing sources	Citation for new sources
General Provisions citation

Lime injection rate verification 	§63.1510(i)(4)	§63.1510(i)(4)

	Measurements of HF in addition to HCl	§63.1503, 63.1505,
63.1511(c)(9), 63.1513	§63.1503, 63.1505, 63.1511(c)(9), 63.1513

	Uncontrolled furnaces that do not comply with ACGIH hooding guidelines
§63.1512(e)(4)	§63.1512(e)(4)

	Changing furnace classification	§63.1514	§63.1514

	

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