SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
part
63,
subpart
LL)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
part
63,
subpart
LL)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
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.

In
general,
all
the
NESHAP
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
involves
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
fluorides
(
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).

All
the
NESHAP
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
the
NESHAP
standards.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
occurrence,
2
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
there
will
be
no
new
growth
in
the
industry
over
the
next
three
years,
with
the
exception
of
one
additional
source
per
year
that
will
become
subject
to
the
standard
over
the
next
three
years
due
to
the
reconstruction
of
an
existing
affected
facility.
The
average
annual
cost
to
industry
over
the
next
three
years
of
this
Information
Collection
Request
(
ICR)
is
estimated
to
be
$
7,756,195
(
rounded).

The
Office
of
Management
and
Budget
(
OMB)
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance."

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,
HAPs
emissions
from
hydrogen
fluoride
(
HF),
polycyclic
organic
matter
(
POM),
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,
the
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
LL.

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

The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
regulations
are
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
standards,
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
NESHAP
continue
to
operate
the
control
equipment
and
achieve
continuous
compliance
with
the
regulation.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
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
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
LL.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
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
standards
to
implement
the
Federal
standards,
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
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
4
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
68
FR
62289
on
November
3,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
the
preparer
of
the
active
ICR,
and
accessed
the
most
recent
data
(
March
8,
2004)
available
on
the
Air
Facility
System
(
AFS)
database.
We
reviewed
information
available
from
the
Office
of
Compliance
Sector
Notebook
"
Profile
of
the
Nonferrous
Metals
Industry,"
the
United
States
Census
Bureau
via
the
internet,
and
other
websites
covering
primary
aluminum
production.
We
consulted
with
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer
and
Program
Integration
Division,
and
Mr.
Richard
Thomas,
Century
Aluminum
of
West
Virginia,
(
304)
273­
6280.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
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
at
5
CFR
part
1320,
section
1320.5.

These
standards
require
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
records
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
5
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
to
the
recordkeeping
and
reporting
requirements
are
primary
aluminum
reduction
facilities.
The
United
States
Standard
Industrial
Classification
(
SIC)
code
for
the
respondents
affected
by
the
standards
is
SIC
3334
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS)
331312
for
Primary
Production
of
Aluminum.

4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
1320.5.

(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
part
63,
subpart
LL).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
and
application
of
construction/
reconstruction.
63.05
Notification
of
initial
compliance
status.
63.850(
a)(
6)

Notification
of
compliance
approach.
63.850(
a)(
8)

Initial
notification
when
source
becomes
subject
to
standard.
63.9(
b)
and
63.850(
a)

One­
time
notification
for
each
affected
source
of
the
intent
to
use
an
HF
continuous
emission
monitor.
63.850(
a)(
7)
6
Performance
test
results/
reports.
63.10(
d)(
2),
63.850(
a)(
5)
and
63.850(
b)

Initial
performance
test.
63.07(
b)
and
63.09(
e)

Rescheduled
initial
performance
test.
63.07(
b)(
2)

Demonstration
of
continuous
monitoring
system,
if
applicable.
63.09(
g)

Compliance
status
including
excess
emissions
report.
63.09(
h)

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

Periodic
startup,
shutdown,
malfunction
reports
and,
if
applicable,
implementation
plan.
63.10(
d)(
5)(
I)
and
63.850(
c)

Semiannual
reports
are
required
for
periods
of
operation
during
which
measured
emissions
exceed
an
applicable
limit.
If
control
device
operating
parameters
are
outside
of
the
established
ranges,
quarterly
reports
are
required
as
a
result
of
excess
emissions.
63.859(
d)

A
source
must
keep
the
following
records:

Recordkeeping
Startup,
shutdown,
malfunction
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(
b)(
3)

Records
are
required
to
be
retained
for
five
years.
The
most
recent
two
years
of
records
must
be
retained
at
the
facility.
63.850(
e)(
1­
2)
7
Recordkeeping
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
and
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.
63.859(
e)(
4)

Documentation
that
daily
inspections
of
process
and
control
devices
were
performed
and
corrective
action(
s)
taken
as
required.
63.859(
e)(
4)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
hydrogen
fluoride
and
polycyclic
organic
matter
emit
HAPs
from
these
facilities.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically,
which
is
reducing
the
reporting
burden.
It
is
estimated
that
approximately
50
percent
of
the
respondents
use
electronic
recordkeeping.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

If
approved
by
the
appropriate
regulatory
agency,
a
respondent
may
install,
calibrate,
maintain,
and
operate
an
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.

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
sections
63.848(
d)(
1)
and
(
d)(
3)
through
(
d)(
6).
8
Respondent
Activities
Comply
with
emission
monitoring
requirements
to
measure
TF,
POM
and
opacity
as
required.

Write
the
notification
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

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.

Currently,
sources
are
using
automated
monitoring
equipment
that
provides
parameter
data.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.

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.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
conducted
for
anode
bake
furnaces
and
potlines,
as
well
as
for
primary
and
secondary
9
control
systems,
are
used
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.
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
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
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
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
­­
NESHAP
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
part
63,
subpart
LL).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
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
10
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

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
to
be
122,607
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
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:

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standards
are
labor
costs
which
are
addressed
elsewhere
in
the
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
11
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startup
Cost
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

HF
CEMs
(
similar
potlines)
0
0
0
$
1,669
23
$
38,387
Method
14
(
manifolds
at
potlines)
0
0
0
$
3,339
12
$
40,068
Method
14A
(
alcan
cassettes)
0
0
0
$
1,536
23
$
35,328
$
113,783
The
total
capital/
startup
costs
for
this
ICR
are
zero.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
114,000
(
rounded).
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
114,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
40,391.
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.02
(
GS­
13,
Step
5,
$
33.76
x
1.6)
12
Technical
$
40.08
(
GS­
12,
Step
1,
$
25.05
x
1.6)
Clerical
$
21.70
(
GS­
6,
Step
3,
$
13.56
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
part
63,
subpart
LL).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
23
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
expected
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
1
23
0
1
23
2
1
23
0
1
23
3
1
23
0
1
23
Average
1
23
0
1
23
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.
In
this
standard,
existing
respondents
submit
initial
notifications.

To
avoid
double­
counting
respondents
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
23.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:
13
Total
Annual
Responses
(
A)
Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
of
applicability
1
1
N/
A
1
Notification
of
construction//
reconstruction
1
1
N/
A
1
Notification
of
actual
startup
1
1
N/
A
1
Notification
of
performance
test
1
1
N/
A
1
Notification
of
compliance
status/
approach
1
1
N/
A
1
Report
of
monitoring
exceedances
2.3
2
N/
A
4.6
Report
of
no
excess
emissions
20.7
2
N/
A
41.4
Startup,
shutdown,
malfunction
report
2.3
2
N/
A
4.6
Total
56
(
rounded)

The
number
of
Total
Annual
Responses
is
56.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
7,756,195.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost
­
­
NESHAP
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
part
63,
subpart
LL).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
114,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
2,189
(
rounded)
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
An
increase
in
burden
over
the
next
three­
years
of
this
ICR
resulted
from
an
increase
in
14
the
estimated
number
of
responses.
The
increase
in
labor
cost
from
the
most
recently
approved
ICR
is
due
to
a
revised
hourly
labor
rate
from
the
United
States
Department
of
Labor.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
2,189
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
to
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;
to
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
to
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
to
search
data
sources;
complete
and
review
the
collection
of
information;
and
to
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
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0139,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
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
EPA
Docket
ID
Number
OECA­
2003­
0139
and
OMB
Control
Number
2060­
0360
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1:
Annual
Respondent
Burden
and
Cost
­
NESHAP
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
part
63,
subpart
LL)

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
b
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
installation,

and
utilization
of
technology
and
systems
80
1
80
1
b
80
4
8
$
5,819.96
4.
Reporting
Requirements
A.
Read
instructions
4
1
4
1b
4
0.2
0.4
$
291.00
B.
Required
Activities
Initial
performance
test
120c
1
120
1b
120
6
12
$
8,729.94
Annual
performance
test
100d
6.7e
670
23
f
15,410
770.5
1,541
$
1,121,069.79
Monthly
performance
test
(
Method
13/
14)
200g
12
2,400
12h
28,800
1,440
2,880
$
2,095,185.60
Monthly
performance
test
(
CEM
or
Alcan
cassette)
40i
25j
1,000
23
23,000
1,150
2,300
$
1,673,238.50
Quarterly
performance
test
200k
15.3l
3,060
6m
18,360
918
1,836
$
1,335,680.80
Daily
monitoring
2n
365
730
23
16,790
839.5
1,679
$
1,221,464.10
C.
Create
information
Included
in
4B
16
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
b
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
D.
Gather
existing
information
Included
in
4B
E.
Write
Report
Notification
of
applicability
2
1
2
1b
2
0.1
0.2
$
145.50
Notification
of
construction/
reconstruction
2
1
2
1
b
2
0.1
0.2
$
145.50
Notification
of
actual
startup
2
1
2
1b
2
0.1
0.2
$
145.50
Notification
of
performance
test
Included
in
4B
Notification
of
special
Compliance
requirements
N/
A
Notification
of
compliance
status/
approach
(
intent
to
use
HF
CEM)
4
1
4
1
b
4
0.2
0.4
$
291.00
NESHAP
waiver
application
N/
A
Report
of
performance
test
Included
in
4B
Report
of
monitoring
exceedances
16
2o
32
2.3p
73.6
3.68
7.36
$
5,354.36
Report
of
no
excess
emissions
8
2o
16
20.7q
331.2
16.56
33.12
$
24,094.64
Startup,
shutdown,

malfunction
report
8
2
16
2.3
r
36.8
1.84
3.68
$
2,677.17
17
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
b
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
5.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
4B
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
all
information
required
by
standards
3s
52
156
24
3,588
179.4
358.8
$
261,025.21
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
24
11.5
0.575
1.15
$
836.63
I.
Time
for
audits
N/
A
Subtotal
Labor
Burden
106,615
5,330.755
10,661.51
$
7,756,195.20
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
122,607
$
7,756,195
Assumptions:

a
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
18
occupational
and
industry
group."

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

c
We
have
assumed
that
it
will
take
120
hours
to
perform
initial
performance
test.

d
It
will
take
100
hours
each
for
Method
13
and
Method
315
for
primary
emission
controls
of
[
total
fluoride
(
TF)
and
polycyclic
organic
matter
(
POM)]
systems
at
potlines
and
anode
bake
furnaces.

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

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

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

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

i
It
is
estimated
to
take
40
hours
for
testing
similar
potlines
(
CEM
or
Alcan
cassette).

Assumptions
contd:

j
Assume
that
48
potlines
will
be
monitored
under
the
alternative
monitoring
provisions
for
similar
potlines,
with
25
potlines
per
respondent
(
12*
48/
23=
25).

k
It
is
estimated
to
take
200
hours
for
a
Method
315
test
for
secondary
emissions.

l
Assume
a
total
of
23
Soderberg
potlines
and
six
plants,
this
will
occur
15.3
per
respondent
(
23*
4/
6=
15.3).

m
Assume
all
of
the
six
Soderberg
plants
are
tested
each
year
for
an
average
of
six
respondents
per
year.

n
Assume
it
takes
two
hours
per
day
for
monitoring
of
operating
parameters
and
visible
emissions.

o
Semiannual
reports
are
required
(
2/
yr),
unless
quarterly
reports
are
required
as
a
result
of
excess
emissions.

p
Assume
that
10
percent
will
fail
to
meet
the
standard.

q
Assume
that
90
percent
will
meet
the
standard.

r
Assume
that
10
percent
must
file
startup,
shutdown,
malfunction
reports.

s
Assume
that
it
will
take
three
hours
per
week
per
plant
to
enter
records.

t
Assume
it
will
take
15
minutes
to
transmit
recorded
information.
19
Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Primary
Aluminum
Reduction
Plants
(
40
CFR
part
63,
subpart
LL)

Burden
Item
(
A)
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Plant
Per
Year
(
C)
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)

Plants
Per
Year
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
a
Costs,

Per
Year
Initial
Performance
Test
120
1
120
1b
120
6
12
$
6,983.28
Excess
Emissions
Enforcement
Activities
120
1
120
2.3c
276
13.8
27.6
$
19,115.76
Report
Review
Notification
of
applicability
2
1
2
1b
2
0.1
0.2
$
116.38
Notification
of
construction
and
reconstruction
2
1
2
1
b
2
0.1
0.2
$
116.38
Notification
of
actual
startup
2
1
2
1b
2
0.1
0.2
$
116.38
Notification
of
special
compliance
requirements
N/
A
Notification
of
initial
performance
test
2
1
2
1
b
2
0.1
0.2
$
116.38
Notification
of
compliance
status
8
1
8
1
b
8
0.4
0.8
$
465.55
Existing
Plants
Review
of
performance
test
report
8
1
8
23
d
184
9.2
18.4
$
8,270.98
Review
of
excess
emissions
report
8
1
8
2.3
c
18.4
0.92
1.84
$
827.10
20
Burden
Item
(
A)
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Plant
Per
Year
(
C)
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)

Plants
Per
Year
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
a
Costs,

Per
Year
Review
of
no
excess
emissions
report
2
2
4
20.7e
82.8
4.14
8.28
$
3,721.93
Review
of
NESHAP
waiver
application
N/
A
Review
of
startup,
shutdown,

malfunction
report
2
1
2
2.3
f
4.6
0.23
0.46
$
206.77
Subtotal
701.8
35.09
70.18
$
39,940.51
Travel
Expenses
(
1
person
x
1
plant/
yr
x
1
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
1
round
trips/
yr)
=

$
450.00
TOTAL
LABOR
BURDEN
and
COST
(
rounded)
807
$
40,391
Assumptions:

a
This
cost
is
based
on
the
following
hourly
labor
rates
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
$
54.02
for
Managerial
(
GS­
13,
Step
5,
$
33.76
x
1.6),
$
40.08
for
Technical
(
GS­
12,
Step
1,
$
25.05
x
1.6)
and
$
21.70
Clerical
(
GS­
6,
Step
3,
$
13.56
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

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

c
We
assume
that
10
percent
of
the
23
plants
(
2.3)
have
excess
emissions.

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

e
Assume
that
the
remaining
90
percent
of
the
23
plants
(
20.7)
do
not
have
excess.

f
Assume
that
10
percent
of
plants
per
year
(
2.3)
will
report
a
startup,
shutdown,
malfunction
incident.

g
Travel
expenses
are
incurred
for
one
employee
to
attend
testing.
21
