SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Secondary Aluminum Production 

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NESHAP for Secondary Aluminum Production (40 CFR part 63, subpart RRR)  

( Renewal)

	1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP),
for semiconductor manufacturing were proposed on February 11, 1999,
promulgated on March 23, 2002, and final rule amendments published on
December 30, 2002.  These regulations apply to component processes at
secondary aluminum production plants that are major sources and area
sources including aluminum scrap shredders, thermal chip dryers, scrap
dryers/delacquering kilns/decoating kilns, secondary aluminum processing
units (SAPUs) composed of in-line fluxers and process furnaces
(including both melting and holding furnaces of various configurations),
sweat furnaces dross-only furnaces, and rotary dross coolers, commencing
construction, or reconstruction after the date of proposal.  As a result
of a rule amendment in the year 2002, owners and operators of certain
aluminum die casting facilities, aluminum foundries, and aluminum
extrusion facilities were excluded from the rule coverage.  Respondents
do not include the owner or operator of any facility that is not a major
source of HAP emissions except for those that are area sources of
dioxins/furans emissions

	In general, all NESHAP standards require initial notifications,
performance tests and periodic reports.  Owners/operators are also
required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction (SSM) in the operation of an affected
facility, or any period during which the monitoring system is
inoperative.  These notifications, reports, and records are essential in
determining compliance, and are required of all affected facilities
subject to NESHAP.  Semiannual summary reports are also required.

	Any owner/operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  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 United States Environmental Protection
Agency (EPA) regional office.

	Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

	There are approximately 1,484 sources (i.e. 81 major sources and 1,403
sweat furnaces) that are subject to the regulations.  It is estimated
that there will be an increase of 5 percent of new sources subject to
the dioxins/furans requirements of the rule based on the number of new
sweat furnaces meeting the requirements over the three years period of
this ICR (i.e. approximately 70 sweat furnaces per year) for an average
of 1,624 sources per year that will become subject to the regulations. 
There will be no additional new major sources over the three-year period
of this ICR. 

The Office of Management and Budget (OMB) approved the current
Information Collection Request (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/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, HAP emissions from facilities in
semiconductor manufacturing cause or contribute to air pollution that
may reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP were promulgated for the source category at 40 CFR
part 63, subpart RRR.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	The notifications required in the standard 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, that leaks are being detected and
repaired, and that the standards are being met.  The performance test
may also be observed.

	The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

	The requested recordkeeping and reporting are required under 40 CFR
part 63, subpart RRR.

	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 its 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

	An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (70 FR 55368) on September 20,
2005.  No comments were received on the burden published in the Federal
Register.

	3(c)  Consultations

	We were unable to get in contact with the Trade Associations.  After
repeated calls to the associations they did not return any of our calls.

	We also referenced the most recent ICR, consulted with the preparer of
the active ICR, and used other resources to obtain the most recent data
available.  We reviewed information available from the United States
Census Bureau, the AIRS Facility Subsystem (AFS), which is the primary
source of information regarding the number of existing sources, and
websites covering secondary aluminum production.  We also consulted with
EPA's Office of Air Quality Planning and Standards, Information Transfer
and Program Integration Division.

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 that 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 the respondents 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.  If records were retained for less than five
years, EPA would be prevented from pursuing the worst violators due to
the destruction or nonexistence of records.

	3(f)  Confidentiality

	Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, Part 2, Subpart B -
Confidentiality of Business Information (CBI)  (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
secondary aluminum production.  The United States Standard Industrial
Classification (SIC) code, for the respondents affected by the standard
which corresponds to the North American Industry Classification System
(NAICS) is listed below:

Standard for 40 CFR part 63, subpart RRR	

SIC Codes	

NAICS Codes

Secondary Smelting and Alloying of Aluminum	3341	331314

Primary Aluminum Production	3334	331312

Aluminum Sheet, Plate, and Foil Manufacturing	3353	331315

Aluminum Extruded Product Manufacturing	3354	331316

Other Aluminum Rolling and Drawing	3355	331319

Aluminum Die-Casting Foundries	3363	331521

Aluminum Foundries (except Die-Casting)	3365	331524

Secondary Smelting and Alloying of Aluminum	3399	331314

  

	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
NESHAP for Secondary Aluminum Production (40 CFR Part 63, Subpart RRR).

	A source must make the following reports:

Notifications for 40 CFR part 63, subpart RRR	Standard Citation by
Sections

Initial notification	63.9(b)(1)-(2)

Intention to construct/reconstruct	63.9(b)(4), 63.1515(4)

Initial performance test and visible emission observations	63.10(d)(2)

Anticipated and actual date of startup	63.1515(a)(3) 

Reschedule initial performance test	63.7(b)(2)

Special compliance obligations for a new source	63.1515(5)

Demonstration of continuous monitoring systems	63.9(g)

Opacity or visible emissions for major sources	63.10(d)(3),
63.1515(a)(6)

Notification of compliance status	63.9(h), 63.1515(b)

Periodic startup, shutdown, malfunction reports	63.10(d)(5)(i)

Operation, maintenance, and monitoring plan for each emission unit to be
approved by the permitting authority	63.6(e)(1)-(2)

Semiannual report	63.10(e), 63.1516(b)

	A source must make the following reports:

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)

Record of applicability	63.10(b)(3)

Records for sources with continuous monitoring systems	63.10(3)

Records are required to be retained for five years	63.10(b)(1), 63.1517



Electronic Reporting

	At the present, respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

	Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the responses are done
electronically.

		(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate continuous parameter monitors
(e.g. temperature monitors), continuous opacity monitors, flow monitors
and bag leak detectors, if applicable.

Perform initial performance test using required referenced methods, as
specified in Section 63.1511(c), and repeat performance test if
necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

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 sources 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 AIRS Facility Subsystem (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 are used
by the Agency to discern a source’s initial capability to comply with
the emission standard.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.

	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
data for approximately 125,000 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/operator for five years.

	5(c)  Small Entity Flexibility

	A majority of the respondents are large entities (i.e., 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 Industry Burden for NESHAP for
Secondary Aluminum Production (40 CFR part 63, subpart RRR).

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 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 93,725
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
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	$100.99 ($48.09 + 110%)

		Technical	$87.97   ($41.89 + 110%)

		Clerical	$43.81   ($20.86 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December, 2005, “Table 2. Civilian Workers, 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 standard are labor costs which are addressed
elsewhere in this 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 monitor and
other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	(B)

Capital/Startup 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)

Bag leak detectors	$29,786	0	$0	$5,250 1	27	$141,750

Flow meters 2	$3,000	0	$0	$0	0	$0

Temperature monitors 3	$1,200	70	$84,000	$0	0	$0

Continuous opacity monitors 4	$36,000	0	$0	$7,500	0	$0

Assume that 34 percent (or 27 respondents) will use bag leak detectors
on fabric filters with an average cost to industry at $29,786.  The
actual cost of the bag leak detectors depends on the number of probes on
the unit, and O&M costs for bag leak detectors is approximately $5,250.

All chlorine injection systems already have chlorine flow meters and the
operation and maintenance costs are negligible.

Temperature monitors will be installed at new sweat furnaces (70 per
year) at a cost of $1,200.  The O&M costs for temperatures monitors are
negligible.

Sources with fabric filters will be complying with the monitoring
requirements through the use of a bag leak detector or visible emissions
observations and not continuous opacity monitors.

The total capital/startup costs for this ICR are $84,000.  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
$141,750.  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 $226,000 (rounded).  This cost will not be
shown on the OMB 83-I form in block 14(c), Total annualized cost
requested.  It is too minuscule a total to be used, since 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
emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $13,872.  This cost is based on the average hourly labor
rate as follows:

		Managerial	$57.20   (GS-13, Step 5, $35.75 x 1.6)

		Technical	$42.45   (GS-12, Step 1, $26.53 x 1.6)

		Clerical	$22.96   (GS-6, Step 3, $14.35 1.6)

These rates are from the Office of Personnel Management (OPM) “2006
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 Secondary Aluminum Production (40 CFR part 63,
subpart RRR).

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

	Based on our research for this ICR, on average over the next three
years, approximately 1,624 existing respondents will be subject to the
standard.  It is estimated that an additional 70 respondent per year
will become subject.  The chart below only accounts for sweat furnaces
with an average of 1,543, but there are also 81 major sources for a
total of 1,624 respondents per year.

	The 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	(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	70	1,403	0	0	1,473

2	70	1,473	0	0	1,543

3	70	1,543	0	0	1,613

Average	70	1,473	0	0	1,543



	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 one.  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: 

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	70	1	0	70

Notification of construction/reconstruction	0	0	0	0

Notification of actual startup	0	0	0	0

Notification of special compliance requirements	0	0	0	0

Notification of performance test	0	1	0	0

Notification of compliance status	81	1	0	81

Waiver application	0	1	0	0

Semiannual reports	1,554	2	0	3,108

Startup, shutdown, malfunction report	2	1	0	2



	Total	3,261



	The number of Total Annual Responses is 3,261.  This number is shown on
the OMB 83-I form in block 13(b), Total annual responses.

	6(e)  Bottom Line Burden Hours Burden and Cost Tables

	The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

	

	(i) Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor costs are $7,938,143.  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,
NESHAP for Secondary Aluminum Production (40 CFR part 63, subpart RRR). 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 29 hours per
response.

	The total annual capital/startup and O&M costs to the regulated entity
are $141,750.  This number is shown on the OMB 83-I form in block 14(c),
Total annualized cost requested.  The cost calculations are detailed in
Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M)
Costs.

		(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is
estimated to be 13,872 labor hours at a cost of $574,271.  See Table 2.
Annual Agency Burden and Cost, NESHAP for Secondary Aluminum Production
(40 CFR part 63, subpart RRR).

	6(f)  Reasons for Change in Burden

	The increase in burden cost from the most recently approved ICR is due
to a change in labor rates.  There was a decrease in burden hours which
was due to a decrease in the number of sources.  This decrease in
sources was due to a number of sweat furnaces going out of business
because of grieve economic outlook the industry is experiencing.  There
is also four less additional sources per-year as compared to the
previous ICR.

	There was a decrease in the capital/startup and operations and
maintenance (O&M) costs from the previous ICR.  This was due to the fact
that there are four less sources as compared to the previous ICR.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 29 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; 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 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
EPA-HQ-OECA-2005-0072, which is available for online viewing at 
www.regulations.gov,  or in person viewing at the Enforcement and
Compliance  Docket and  Information Center in the EPA Docket Center
(EPA/DC),  EPA West, Room B102, 1301 Constitution Avenue, 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 is (202)566-1752.  An electronic version of the
public docket is available through EPA Dockets 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.  You can also 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 Number:  EPA-HQ OECA-2005-0072, and OMB
Control Number 2005-0072 in any correspondence.

Part B of the Supporting Statement

	This part is not applicable because no statistical methods were used in
collecting this information.  

Table 1:  Annual Respondent Burden and Cost – NESHAP for Secondary
Aluminum Production (40 CFR part 63, subpart RRR) 

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $  b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Acquisition, installation, and utilization        of technology and
systems c	54	1	54	70	3,780	189	378	$368,173.89

4.  Reporting Requirements









   A. Read instructions d	0.13	1	0.13	70	9.1	0.455	0.91	$886.35

   B. Required activities









        Initial performance test e, f	24	1	24	0	0	0	0	$0

        Repeat performance test e, f	24	0.20	4.8	0	0	0	0	$0

        Operating, maintenance and                          monitoring
plan e, f	32	1	32	70	2,240	112	224	$218,177.12

        Startup, shutdown, malfunction

        (SSM) plan g	32	1	32	70	2,240	112	224	$218,177.12

   C.  Create information 	See 4B







	   D. Gather existing information	See 4B







	   E. Write reports









         Notification of applicability e, f	2	1	2	70	140	7	14	$13,535.07

         Notification of construction/                         
reconstruction	N/A







	         Notification of actual startup	N/A







	         Notification of special compliance                requirements
N/A







	         Notification of performance test e	2	1	2	0	0	0	0	$0

         Notification of compliance status e	4	1	4	81	324	16.2	32.4
$31,557.76

         Waiver application h	2	1	2	0	0	0	0	$0

         Report of performance test	See 4B







	         Semiannual reports i	8	2	16	1,554	24,864	1,243.2	2,486.4
$2,421,766.03

         SSM report j	8	1	8	2	16	0.8	1.6	$1,557.40

5.  Recordkeeping requirements









   A. Read instructions 	4	1	4	81	324	16.2	32.4	$31,557.76

   B. Plan activities	See4E







	   C. Implement activities 	See 4B







	   D. Develop record system	N/A







	   E. Time to enter/ transmit information 









         Records of all information required              by the
standards









             Major sources k	1.5	52	78	81	6,318	315.9	631.8	$615,370.04

             Sweat furnaces l	0.5	52	26	1,543	40,118	2,005.9	4,011.8
$3,907,513.26

   F. Time to train personnel m	4	1	4	70	280	14	28	$27,272.14

  G. Time to adjust existing ways to comply        with previously
applicable                            requirements	N/A







	  H. Time to disclose information









             New sources n	0.25	2	0.5	70	35	1.75	3.5	$3,409.02

             All sources o	0.25	2	0.5	1,624	812	40.6	81.2	$79,089.200

  I.  Time for audits	N/A







	Subtotals Labor Burden and cost  



	81,500.1	4,075.005	8,150.01	$7,938,143.16

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	93,725	$7,938,143



Assumptions:

a  We have assumed that the average number of respondent that will be
subject to the rule will be 1,624.  There are approximately 1,403 sweat
furnaces and 81 major sources that are currently subject to the rule. 
It is estimated that there will be an additional 5 percent new source
subject to the dioxins/furans requirements of the rule based on the
number of new sweat furnaces meeting the requirements over the three
year period of the ICR (i.e. approximately 70 sweat furnaces per year). 
There will be no additional new major sources over the three-year period
of this ICR.

b  This ICR uses the following labor rates: $100.99 per hour for
Executive, Administrative, and Managerial labor; $87.97 per hour for
Technical labor, and $43.81 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2. Civilian Workers, by
occupational

and industry group.”  The rates are from column 1, “Total
compensation.”  The rates have been increased by 110% to account for
the benefit packages available to those employed by private industry.

c  We have assumed that it will take each new respondent 54 hours to
complete the task.

d We have assumed that each respondent will take 0.13 hours to read
instructions.

e  We have assumed that all existing sources are in compliance with the
initial rule requirements.  It is further assumed that new sweat
furnaces will comply by meeting the equipment specifications rather than
by conducting performance tests.  Respondents that are major sources are
required to demonstrate initial compliance with the applicable emission
limit, equipment, work practice, or operational standard for affected
source or emission unit and report results in the notification of
compliance status report.

f  Since we have assumed that there will be no new major sources over
the next three-year period of this ICR, there will be no new sources
conducting initial performance tests.  We have determined that
respondents of new sweat furnaces will not be required to conduct
emissions testing to show compliance with the emission limit, since it
was determines that sweat furnaces sold in the United States now have an
afterburner installed and meet the design residence time of 0.8 seconds
or greater and an operating temperature of 1600 oF or greater.  All new
respondents are required to submit for approval an operation,
maintenance and monitoring plan for affected sources.

We have assumed that each respondent will take four hours two times per
year to write semiannual summary reports.

g  We have assumed that respondent of sweat furnaces may submit with the
notification of compliance report information on the manufacturers
specifications and the SSM plan.

h  It is assume that there will be no new sources requesting a waiver
from performance test requirements.

i  It is assumed that each respondent will take 8 hours to semiannual
report of excess emissions or no excess emissions.

j  It is assumed that two major sources will have a startup, shutdown,
malfunction occurrence per year that is not managed according to plan.

k  It is assumed that it will take1.5 hours for major sources to enter
and transmit records.

l  It is assumed that it will take 0.5 hours for existing sweat furnaces
respondents to enter and transmit records.

m  We have assumed that it will take 4 hours to train new sweat furnaces
employees.

n  We have assumed that it will take 0.25 hours for each new sweat
furnaces sources to disclose information.

o  We have assumed that it will take 0.25 hours for each source to
disclose information. 

Table 2:  Average Annual EPA Burden - NESHAP for Secondary Aluminum
Production (40 CFR part 63, subpart RRR) 

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

 per year	

(C)

EPA person

hours per

plant  per year

(C=AxB)	

(D)

Plants per year  a	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $ b

Initial performance tests	40	1.4	56	0	0	0	0	$0

Repeat performance test including retesting c	48	1	48	0	0	0	0	$0

Notification of applicability	0.5	1	0.5	70	35	1.75	3.5	$1,666.21

Notification of construction/reconstruction	N/A







	Notification of actual startup	N/A







	Notification of special compliance requirements	N/A







	Notification of performance test	2	1	2	0	0	0	0	$0

Notification of compliance status  d	2	1	2	70	140	7	14	$6,664.84

Waiver application	N/A







	Report of performance test c	40	1	40	0	0	0	0	$0

Repeat of performance test report c	40	1	40	0	0	0	0	$0

Semiannual reports e	4	2	8	1,484	11,872	593.6	1,187.2	$565,178.43

Startup, shutdown, malfunction report f	8	1	8	2	16	0.8	1.6	$761.71

Subtotals Labor Burden and cost



	12,063	603.15	1,206.3	$574,271.19

 TOTAL ANNUAL BURDEN AND     COST (rounded)	

	

	

	

	13,872	$574,271



Assumptions:

     a  We have assumed that the average number of respondent that will
be subject to the rule will be 1,624.  There are approximately 1,403
sweat furnaces and 81 major              sources that are currently
subject to the rule.  It is estimated that there will be an additional 5
percent new source subject to the dioxins/furans requirements of the
rule            based on the number of new sweat furnaces meeting the
requirements over the three year period of the ICR (i.e. approximately
70 sweat furnaces per year).  There will be      no additional new major
sources over the three-year period of this ICR.

 b This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $57.20 (GS-13, Step 5, $35.75 x 1.6),
Technical rate of $42.45 (GS-12, Step 1, $26.53 x 1.6), and Clerical
rate of $22.96 (GS-6, Step 3, $14.35 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2005 General Schedule” which
excludes locality rates of pay.

    c  We have assumed that all existing respondent are in compliance
with the initial rule requirements.  It is further assumed that new
sweat furnaces will comply by meeting      the equipment specifications
than by conducting performance tests.

    d  We have assumed that it will take 2 hours for each respondent to
complete notification of compliance status.

    e  We have assumed that each existing respondents will take 4 hours
twice a year to complete semiannual reports.

    f  It is assumed that two major sources will have a startup,
shutdown, malfunction occurrence per year that is not managed according
to plan.

 PAGE   12 

 PAGE   13 

