SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Primary Aluminum Reduction Plants 

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 primary aluminum reduction plants were proposed on
September 26, 1996, promulgated on October 7, 1997 and amended on
November 2, 2005.  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 a level of control
at least as low as the better controlled and lower emitting sources in
each category.  This 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 (PM10), 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.  With the exception of the
performance specifications for continuous emission monitors (CEMs) in
the general provisions, which are not applicable to HF CEMs because such
specifications have not yet been developed for that device, all the
general provisions requirements apply to sources subject to the NESHAP
for primary aluminum reduction plants.  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.  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, 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 16 existing primary aluminum facilities major sources of
hazardous air pollutants 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.  However, we expect that one source per year will
become subject to the standard over the next three years due to the
reconstruction of an existing affected facility.  The number of
facilities decreased for the renewal of this ICR due to more accurate
estimates of the number of existing and new facilities and closure of a
few facilities due to economic factors, including cost of energy and
market dynamics related to the amount of aluminum being recovered to
produce aluminum products.  The average annual cost to industry over the
next three years of this Information Collection Request (ICR) is
estimated to be $7,130,009 (rounded).

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

The 16 major source facilities in the United States, which are
respondents to this ICR, are publicly owned and operated by primary
aluminum reduction plants.  None of the facilities are owned by either
state, local and tribal agencies or the Federal Government.

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, HAP emissions from hydrogen fluoride
(HF), polycyclic organic matter (POM), and particulate matter smaller
than 10 microns in diameter (PM10) 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

The control of emissions of HAP emissions from HF, POM and PM10, 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.  These emissions are the result of
operation of specific point sources at these plants including 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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register 72 FR 10735 on March 9, 2007.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

	The assumptions made in the development of this ICR, including the
estimate on the number of primary aluminum reduction plants subject to
the NESHAP subpart LL rule, were reviewed and updated by the Agency in
consultation with Mr. Robert Strieter of the Aluminum Association, who
in turn consulted with some of the committee members.

	In addition, we consulted the Agency’s internal data sources
including Donnalee Jones, the Agency contact for the residual risk rule
on the primary aluminum industry sector, and the AFS (AIRS Facility
Subsystem), which is the EPA database for the collection, maintenance,
and retrieval of all compliance data.  The information in AFS is
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard.  AFS is operated and maintained by the
Office of Compliance at EPA.  We have estimated that there are
approximately 16 existing respondents subject to the standard and no new
sources will become subject to the standard over the three year period
covered by this ICR.

	The Agency also has the policy to respond after a thorough review of
comments received from the public since the last ICR renewal as well as
those submitted in response to the first Federal Register.  In this
case, no comments were received.  

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 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
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:

Notifications

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)

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.
63.13(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)

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, electronic reporting is
increasingly allowed by regulatory agencies which, in turn, reduces the
reporting burden.  At this time, 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).

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 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 conducted for
anode bake furnaces and potlines, as well as for primary and secondary
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 test 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 Cost and 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, we have
identified the specific tasks and the underlying assumptions.  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 80,046
hours (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	$105.86 ($50.41 + 110%)   

Technical	$92.61   ($44.10 + 110%)

Clerical	$45.32  ($21.58 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2006, 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 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.

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)

HF CEMs (similar potlines)	$100,000	0	$0	$1,669	16	$26,704

Method 14 (manifolds at potlines)	$200,000	0	$0	$3,339	12	$40,068

Method 14A (alcan cassettes)	$92,000	0	$0	$1,536	16	$24,576

Total

	$0

	$91,348



There is no annualized capital/startup cost for this ICR, as identified
in the total of column D of the above table.  The total operation and
maintenance (O&M) cost for this ICR are $91,348, as identified in the
total of column G of the above table.  Therefore, the total annualized
capital/startup cost and the operation and maintenance cost to industry
over the next three years of the ICR is estimated to be $91,348.  

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 $10,247.  This cost is based on the average hourly labor
rate as follows:

Managerial	$58.18   (GS-13, Step 5, $36.36 + 60%)

Technical	$43.17   (GS-12, Step 1, $26.98+ 60%) 

Clerical	$23.36   (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) 2007
General Schedule which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Annual Burden and Cost
to the Federal/State Government: 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 16 existing primary
aluminum reduction plants 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.

The number of respondents over the three years period of this ICR is
calculated using the following table:

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	16	0	1	16

2	1	16	0	1	16

3	1	16	0	1	16

Average	1	16	0	1	16



As shown in the above table, the average Number of Respondents over the
three-year period of this ICR is 16.  Please note that new respondents
include sources with constructed, reconstructed and modified affected
facilities.  To avoid double-counting respondents, the total number of
respondents that are also new respondents in column D is subtracted.  In
this standard, existing respondents that are also new respondents are
required to submit initial notifications. 

The average number of annual responses over the three year period of
this ICR 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	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 initial performance test	1	1	N/A	1

Notification of compliance status/approach	1	1	N/A	1

Semiannual report of monitoring exceedances	1.6	2	N/A	3.2

Semiannual report of no excess emissions	14.4	2	N/A	28.8

Startup, shutdown, malfunction report	1.6	2	N/A	3.2

Total



40.2



As shown on the above table, the Total Annual Responses is 40 (rounded).
 This estimate is based on the assumption that the results from the
monthly, quarterly and annual performance tests will be submitted with
the semiannual compliance reports. 

The total annual labor burden and costs to industry are 80,046 hours and
$7,130,009, respectively.  The details regarding the respondent total
labor burden and costs are found in Table 1. Annual Respondent Burden
and Cost: NESHAP for Primary Aluminum Reduction Plants (40 CFR part 63,
subpart LL), attached. 

The total annual capital/startup and O&M costs to the regulated entity
are $91,348, as discussed in Section 6(b)(iii), Capital/Startup vs.
Operation and Maintenance (O&M) Costs, above.

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 2,001
(rounded) hours per response.

6(f)  Reasons for Change in Burden

The decrease in labor burden to industry from the most recently approved
ICR is due a decrease in the number of existing primary aluminum
reduction plants that are subject to NESHAP subpart LL.  The number of
facilities decreased for the renewal of this ICR due to a more accurate
estimate of the number of existing facilities subject to the rule and
closure of a few facilities due to economic factors, including cost of
energy and market dynamics related to the amount of aluminum being
recovered to produce aluminum products.  The reduction in the number of
respondents to this ICR also resulted in a decrease on the average
annual cost for capital/startup and operation and maintenance costs to
industry over the next three years of the ICR.

In addition, there was a decrease in the burden to the Federal/State
government in the renewal of the ICR is due to the decrease in the
number of respondents.  The costs associated with regulators attending
performance tests were also removed from this ICR because this is an
enforcement activity related to case development and, therefore, exempt
from the requirements of the Paperwork Reduction Act.  

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 2,001 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
EPA-HQ-OECA-2007-0127.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 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
docket center is (202) 566-1752.  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
EPA-HQ-OECA-2007-0127 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.

  SEQ CHAPTER \h \r 1 Table 1.  Annual Respondent Burden and cost:
NESHAP for Primary Aluminum Reduction Plants (40 CFR Part 63,  Subpart
LL)

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	(E)

Technical

person-

hours per

year

(E=CxD)	(F)

Management

person-hours

per year

(E=0.05)	(G)

Clerical

person-

hours 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	

8	

1	

8	

1 b	

8.0	

0.4	

0.8	

819.48

4. Reporting Requirements









A. Read instructions	4	1	4	1 b	21.2	1.1	2.1	409.74

B. Required activities









   Initial performance test 	100 c	1	100	1 b	120	6.0	12.0	12,292.20

   Annual performance test 	100 c	5.1 d	510	16 e	8160.0	408.0	816.0
835,,869.60

   Monthly performance test

   (Method 13/14)	200 f	12	2400	12 g	28800.0	1440.0	2880.0	2,950,128.00

   Monthly performance test

   (CEM or Alcan cassette)	40 h	18 i	720	16	11520.0	800.0	1600.0
1,180,051.20

   Quarterly performance test	200 j	16 k	3200	2 l	6400.0	320.0	640
655,584.00

   Daily monitoring 	2 	365	730	16	11,680.0	584.0	1,168.0	1,196,440.80

C. Create information	See 4B







	D. Gather existing information	See 4B







	E. Write report









   Notification of applicability	2	1	2	1 b 	2.0	0.1	0.2	204.87

    Notification of                                                     
                            

    construction./reconstruction 	2	1	2	1 b 	2.0	0.1	0.2	204.87

   Notification of actual startup	2	1	2	1 b	2.0	0.1	0.2	204.87

   Notification of special    

   compliance requirements	N/A







	   Notification of performance test	2	1	2	16 b	32.0	1.6	3.2	3,277.92

   Notification of compliance                                           
                                                                        
                                  

   status	4	1	4	16 b	64.0	3.2	6.4	6,555.84

   NESHAP waiver application	N/A







	   Report of performance test	See 4B







	   Report of monitoring 

   exceedances	16	2 m	32	1.6 n	51.2	2.56	5.1	5,244.67

   Report of no excess emissions	8	2 m	16	14.4 o	230.4	11.5	23.0
23,601.02

   Startup, shutdown, malfunction

   report	8	2 m	16	1.6  p	25.6	1.3	2.6	2,622.34

   Startup, shutdown, malfunction

   plan	40	1	40	1 b 	0.0	 0.0	0.0	0.00

5.  Recordkeeping Requirements









A.  Read instructions	See 4B







	B.  Plan activities	N/A







	C.  Implement activities	See 4B







	D.  Develop record system	N/A







	E.  Time to enter information









  Records of all information  

  required by standards	3 q	52 q	156	16	2496.0	124.8	249.6	255,677.76

F.  Time to train personnel	N/A







	G.  Time to adjust existing ways t          to comply with previously

applicable requirements	

N/A







	H.  Time to transmit or disclose

Information	0.25 r	2 m	0.5	16	8.0	0.4	0.8	819.48

I.  Time for audits	N/A







	Subtotal



	69,605.2	3,480.3	6,960.5	7,130,008.66

TOTAL LABOR BURDEN AND COST (Rounded)



	80,046	7,130,009



Assumptions:

a This ICR uses the following labor rates: $105.86 for Managerial labor,
$92.61 for Technical labor, and $45.32 for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December 2006, (Table 10. Private industry, 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.

b Assumes that one plant per year will have to comply with initial rule
requirements due to a reconstruction of an affected facility (i.e.,
pitch storage tank).  It is assumed that the plant has a startup,
shutdown and malfunction plan in place.

c Assumes it takes 100 hours each for Method 13 and Method 315 for
primary controls of potlines and bake furnaces.

d Assumes 59 Method 13 tests and 22 Method 315 tests will be conducted
each year (primary control systems) for a total of 81 tests for 16
respondents (81/16 = 5.1 per respondent).

e Assumes that there are 16 primary aluminum plants subject to this
standard.  f Assumes it takes 200 hours for Method 13/14 for secondary
emissions from potlines.

g Assumes that 12 potlines must perform manual sampling as a result of
the NESHAP.  Testing was already required by the States for other
potlines.

h Assumes it takes 40 hours for testing of similar potlines (CEM or
Alcan cassette).

i Assumes that 24 potlines will be monitored under the alternative
monitoring provisions for similar potlines.  This is 18 per respondent
(24*12/16 = 18).

j Assumes it takes 200 hours for a Method 315 test for secondary
emissions.

k Assumes that a total of 8 Soderberg potlines at two plants, this is 16
per respondent (8*4/2 = 16).

l Assumes that two Soderberg plants will conduct quarterly performance
tests.

m This rule requires that all existing respondents submit semiannual
reports.  Performance test results will be submitted with the semiannual
reports.

n Assumes that 10 percent fail to meet the standard (0.1 x 16).

o Assumes that 90 percent meet the standard (0.9 x16).

p Assumes that 10 percent must file startup, shutdown, malfunction
report (0.1 x 16).

q Assumes it takes 3 hours per week per plant to enter monitoring data
into records.

r Assumes it takes 15 minutes to transmit recorded information.

N/A = Not Applicable. 

Table 2.  Annual Burden and Cost to the Federal/State Government:
NESHAP for Primary Aluminum Reduction Plants (40 CFR part 63, subpart
LL)

Burden Item	(A)

Person Hours Per Occurrence	(B)

Number  of Occurrences 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 Costs    

Per Year, $ a





New or reconstructed Facilities











Notification of applicability	

2	

1	

2	

1 b	

2.0	

0.1	

0.2	

96.83



Notification of construction           and reconstruction	

2	

1	

2	

1 b	

2.0	

0.1	

0.2	

96.83



Notification of actual startup	

2	

1	

2	

1 b	

2.0	

0.1	

0.2	

96.83



Notification of special                 compliance requirements	

N/A	

	

	









Notification of initial                   performance test	

2	

1	

2	

1 b	

2.0	

0.1	

0.2	

96.83



Notification of compliance          status	

8	

1	

8	

1 b	

2.0	

0.1	

0.2	

96.83

Existing Facilities	

	

	

	









Review of performance               test report	

8	

1	

8	

16 d	

128.0	

6.4	

12.8	

6,197.12



Review of excess emissions        report	

8	

1	

8	

1.6 c	

12.8	

0.6	

1.3	

617.85



Review of no excess                    emissions report	

2	

2	

4	

14.4 e 	

57.6	

2.9	

5.8	

2,790.80 



Review of NESHAP waiver        application	

N/A	

	

	









Review of startup, shutdown,      malfunction report	

2	

1	

2	

1.6 f	

3.2	

0.2	

0.3	

156.79



Subtotal	

	

	

	

	

211.6	

10.6	

21.2	

10,246.71

TOTAL LABOR BURDEN and COST (rounded)	

	

	

243	

10,247



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: $58.18 for Managerial (GS-13, Step 5, $36.36 + 60%), $43.17
for Technical (GS-12, Step 1, $26.98+ 60%) and $23.36 Clerical (GS-6,
Step 3, $14.60 + 60%).  These rates are from the Office of Personnel
Management (OPM) (2007 General Schedule( which excludes locality rates
of pay.  

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

c Assumes that 10 percent of the 16 plants (1.6) will have excess
emissions.

d Assumes that EPA/State personnel will review summary of performance
tests requirements to be submitted by all 16 existing plants on an
annual basis for purposes of calculating the burden.  However, plants
are expected to submit performance test results with the semiannual
reports.    

e Assumes that the remaining 90 percent of the 16 plants (14.4) will not
have excess emissions.

f Assumes that 10 percent of plants per year (1.6) will report a
startup, shutdown, malfunction incident.

N/A = Not Applicable. 

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