**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS f o**  **r Phosphate Fertilizer Industry ( 40 CFR Par**  **t 60, Subparts T, U, V, W and X) (**  **Renewal) 1. Identification of**  **the Information Collection 1(a) Title of the Information Collection**  NSPS for Phosphate Fertilizer Industry ( 40 CFR Part 60, S ubpart s T, U, V, W and X) ( Renewal), EPA I CR Numbe r 1061 .12 , OMB Control Number 2060

- 0037. **1(b) Short Characterization/Abstra ct**  The New Source Performance Standards (NSPS) for Phosphate Fertilizer Industry ( 40 CFR part 60, subparts T, U, V, W and X ) were proposed on October 22, 1974, and promulgated on August 6, 1975. These standards apply to existing facilities and new facili ties that engage in the manufacture of phosphate fertilizers, and have a desi gn capacit y of more than 15 tons of equivalent phosphorous pentoxide (P 2 O 5 ) feed per calendar day. These standards also appl y to existing facilities and new facilities that store granular triple superphosphate. These standards establish fluoride emission limitations as a measure of phosphorus

- bearing feed material at affected facilities. The affected facilities may include a combination of reactors, filters, evaporators, hot wel ls, acid sumps, cooling tanks, granulators, dry ers, coolers, screens, mills, mixers, curing belts (dens), cookers, and facilities which store run

- of

- pile triple superphosphate, depending on the t ype of plant. New facilities include those that commenced co nstruction, modification or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 60, subparts T, U, V, W and X. In general, all NSPS standards require initial notifications, performance test s, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of an y startup, shutdown, or malfunction in the operation of an affected facility, or an y period durin g which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two 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 su ch delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Approximately

13 sources are currentl y subject to the regulation, and it is estimated that no new sources will becom e subject to the r egulation over the next three years. The Office of Management and Budget (OMB) approved the currentl y active I CR without any “ Terms of Clearance. ”2

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– N SPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V, W and X) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed b y either F ederal employees or government contractors. This burden may be found b elow in Table 2: Average Annual EPA Burden and Cost

– NSPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V, W and X) (Renewal).
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or an y non - air qualit y health and environmental impact and energy requirements) the A dministrator determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best

- demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such s tandards every four years. 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 in formation as the Administrator may reasonabl y require. In the Administrator's judgment, particulate emissions from the ammonium sulfate manufacturing industry

cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source3

category at 40 CFR part 60, subpart s T, U, V, W and X

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard(s) ensure compliance with th e applicable regulations which where 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. The notifications required in the standard are used to inform the Agency or delegate d 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 properl y installed and operated and the standard are being met. The perfor mance 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. The standards require recordkeeping to document information relating to the daily feed rate and storage of equivalent P 2 O 5 . Amounts of P 2 O 5 are determined from continuous monitoring sy stem (CMS) records of phosphate

- bearing feed material or accounts for triple superphosphate stored. The standards also limit total fluoride emission to 100 grams per megagram (Mg) of equivalent P 2 O 5 feed as measured in Mg/hour. Therefore, the regulations require the hourly

recording of data and the maintenance of dail y records for purposes of determin ing the feed rate used in the standard. The informat ion generated by the monitoring and recordkeeping requirements described above is used by the Agency

to ensure that facilities affected b y the NSPS continue to operate and control equipment used to achie ve compliance with the NSPS
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 60, subpart s T, U, V, W and X

. **3(a) Non** 
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y of the report submitted to the state or local agency can4

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Pub lic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (77 FR 47631) on August 9, 2012 . No comments were received on the burden published in the Fede ral Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary

source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the OTIS which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is an ywa y for EPA to reduce the recordkeeping and reporting burden or improve the language in th e standard to make it easier to comply . In developing this I CR, EPA contacted : 1) the Florida Institute for Phosphate Research , at (863) 534

- 7160 ; and 2) the Fertilizer Institute , at (202) 256

- 9986. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. **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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 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

- ye ar records retention requirement is consistent with5

the Part 70 permit program and the five

- ye ar statute o f limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, an y pattern of non

- compliance, and to determine the appropriate level of enforcement action. EPA has f ound that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any information submitt ed 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** The reporting or recordkeeping requirements in the standard do not include sensitive questions.
**4. The Respondents and the Information Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are phosphate fertilizer facilities. The United States Standard Industrial Classification (SI C) code for the respondents affected b y the standard is 2874, which corresponds to North American In dustry Classification Sy stem (NAI CS) code 325312 for phosphatic fertilizer manufacturing. **4(b) Information Requested (i) Data Items**  In this ICR, all the data that is recorded or reported is required b y the NSPS for Phosphate Fertilizer Industry (4 0 CFR Part 60, S ubparts T, U, V, W and X). A source must make the following reports: **Notifications/Reports** Notification of construction/reconstruction. 60.7(a)(1) Notification of initial startup including compliance method. 60.7(a)(3) Initial performance test results. 60.8(a)6 **Notifications/Reports** Initial performance test. 60.8(d) Demonstration of continuous monitoring sy stem. 60.7(a)(5) Phy sical or operational change. 60.7(a)(4) Semiannual or as indicated by the Administrator reports of exceedances or monitoring s ys tems performance. 60.7(c) Site

- specific methodology plan for demonstrating compliance with standards for fluorides. 60.243(d)
A source must keep the following records: **Recordkeeping** Startups, shutdowns or malfunctions, periods where the continuous monitoring sy stem is inoperative. 60.7(b) A file with records of all data measured during performance tests to demonstrate compliance with the standard including the equipment operating parameters and records of periods of operations during which the parameters where established. The file shall be retained for two ye ars following the date of such measurements, maintenance, reports, and records. 60.7(f)

Daily record of equivalent P 2 O 5 feed rate. 60.203(b), 60.213(b), 60.223(b), 60.233(b), 60.243(b) Total pressure drop across any process scrubbing sy stem. 60.203(c), 60.213(c), 60.223(c), 60.233(c), 60.243(c) Mass of granular triple superphosphate in storage. 60.243(a) Other records specified in an EPA approved site

- specific plan. 60.243(d) Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not7

widely used. At this time, it is estimated that approximately 2 0 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate monitoring devices that continuously measure the total pressure drop across the process scrubbing s ys tem. Install, calibrate, maintain, and operate a flow monitoring device which can be used to determine the mass flow of phosphorus bearing feed material to the process. As part of the performance test, determine the P 2 O 5 content in megagrams per hour (Rp) of the feed, using the Association of Official Anal yt ical Chemists (AOAC) Method 9 and Method 13A or 13b to determine the total fluoride concentration of volumetric flow rate of the effluent gas from each of the emission points. 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing an d providing information. Adjust the existing way s to comply with 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 monitoring equipment that provides parametric data in an automated way

(e.g., pressure drop and volumetric flow rate). Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. In addition, some regulatory agencies are setting up electronic reporting s ys tems to allow sources to report electronically which is reducing the reporting burden. However, electronic reporting s ys tems are still not widely used b y the regulatory

agencies.

**5. The Information Collected: Agency Activities, Collection Methodology, and**8

**Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, 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 quarterl y reports of excess emissions reports or semiannual reports of no excess emission, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S)

. **5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to compl y with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports of exceedances are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA ’s O ffice of Compliance. OT IS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 1 25 ,000 industrial and government

- owned facilities. EPA uses OTI S for tracking air pollution compliance and enforcement activi ty

by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and anal yz e the data. The records required b y this regulation must be retained by the owner/operator for tw o ye ars. **5(c) Small Entity Flexibility** The majority

of the respondents are large entities (i.e. large businesses) as the number of employees at a t ypical fertilizer plant currently exceeds the criterion for small business

. Due to technical considerations involving the process operations and the t ypes 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 compliance9

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 below Table 1: Annual Respondent Burden and Cost

– NSPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V, W and X) (Renewal). **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 each of the subparts included in this I CR. 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

. Th e 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 requirement s is estimated to be 1,37 3 hours ( Total Labor Hours from Table 1 below ). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency knowledg e and experience with the NSPS program, the previously

approved IC R, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs**10

The ty pe of industry

costs associated with the information collection activities in the subject standards are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital/startup costs are one time costs when a facility become s subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocop ying 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)
Pressure drop mo nitor $27,720 0 $ 0 $24,630 13 $320,190
**TOTAL $320,190** 
T here are no capital/startup costs for this I CR. This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 320,190

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry

over the next three years of the IC R is estimated to be $ 320,190

. These are the recordkeeping costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program i ncludes activiti es 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 $1,347

. This cost is based on the average hourl y labor rate as follows:
Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%)11 Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%) Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%)
These rates are from the Office of Personnel Management (OPM) , 201 2 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Phosphate Fertilizer Industry

(40 CFR Part 60, Subparts T, U, V, W and X) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs**  Based on our research for this I CR, on average over the next three ye ars, approximately 13 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondent s, as shown in the table below, is 13 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Year (A) Number of Ne w 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 0 13 0 0 13
2 0 13 0 0 13
3 0 13 0 0 13 Average 0 13 0 0 13 1 New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard existing respondent s submit initial notifications. Column D is subtracted to avoid double

- counting respondents. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 13. The total number of annual responses per ye ar is calculated using the following table:12 **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

Semiannual Report 13 2 N/A 26 The number of Total Annual Responses is 26

. The total annual labor costs are $132,900. Details regarding these estimates may be found below in Table 1 : Annual Respondent B urden and Cost

– NSPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V, W and X) (Renewal). **6(e) Bottom Line Burden Hours 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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 1,37 3 hours at a cost of $132,900 . Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V, W and X) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 53 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $320,190. 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 next three years is estimated to be 30 labor hours at a cost of $1,347. See Table 2 below : Average Annual EPA Burden and Cost

– NSPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V, W and X) (Renewal). **6(f) Reasons for Change in Burden** The increase in burden from the most recentl y approved ICR is due to an adjustment of respondent and Agency

labor hours

. T he previous I CR assumed that burden hours accounted for all technical, managerial, and clerical hours. T o be consistent with the estimation methodology13

used in other ICRs, this ICR assumes that labor hours account for technical hours only . C lerical and managerial hours require additional time, and equal 10 and 5 percent of technical hours, respectivel y. Additionally , this ICR uses updated labor rates, resulting in an increase to the total burden cost s
. **6(g) Burd en Statement**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 53 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, ret ain, 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 O MB Control Number. The OMB Control Numbers for EPA 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 t his I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0533. 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 sy stem , select “search,” then key in the docket ID number identified in this document. The documents are al so 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 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center is (202) 566

- 17 52 . Also, you can send comments to the Office of In formation 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

- 2012

- 0533 and OMB Control Number 2060

- 0037 in any correspondence.
**Par t B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this14

information.15

**Table 1: Annual Respondent Burden and Cost**

**– NSPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V,**  **W and X) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H**

**Person Hours**  **P er**  **O ccurrence**  **Number of**

**O ccurrences**  **P er**  **R espondent**  **P er**  **Y ear**  **Person**

**H ours**  **P er**  **R espondent**  **P er**  **Y ear**  **(C=AxB) Respondents** 

**P er**  **Y ear**  **a Technical** 

**P erson**  **** **H ours**  **P er**  **Y ear**  **(E=CxD) Management** 

**P erson**  **H ours**  **P er**  **Y ear**  **(E x 0.05) Clerical** 

**P erson**  **H ours**  **P er**  **Y ear**  **(E x 0.10) Total**  **C osts** 

**P er**  **Y ear**  **($) b**  1. Applications N/A 2. S urvey and S tudies N/A 3. R eporting R equirements A. Read Instructions 1 1 1 0 0 0 0 $ 0 B. Required activities **New Sources** Initial Performance Test AOCA Method 9 tests **c** 29.7 1 29.7 0 0 0 0 $ 0 Reference Method 13A or 13B tests **d** 4 1 4 0 0 0 0 $ 0 Repeat performance test **e** 4 0.2 0.8 0 0 0 0 $ 0 C. Create Information Included in 3B D. Gather existing information Included in 3E E. Write Report **New Sources** Notification of construction/reconstruction 2 1 2 0 0 0 0 $ 0 Notification of actual startup 2 1 2 0 0 0 0 $ 0 Notification of initial performance test 2 1 2 0 0 0 0 $ 0 Notification of CMS demonstration 2 1 2 0 0 0 0 $ 0 Report of initial performance test Included in 3B16

Site

- specific methodology plan **f** 2 1 2 0 0 0 0 $ 0 **Existing Sources** Notification of operational change **g** 2 1 2 2 4 0.2 0.4 $ 445.41 Semiannual report of exceedances **h** 2 2 4 13 52 2.6 5.2 $ 5,790.36 **Subtotal Reporting**  **Requirements 64**  **.4** 4 **.** R ecordkeeping R equirements
A. Read Instructions Included in 3A

B. Plan activities Included in 3B C. Implement activities Included in 3B D. Develop record system N/A E. Time to enter information Records of operation parameters and emissions **i** 0.25 350 87.5 13 1,137.5 56.88 113.75 $ 126,664.04 **Subtotal Recordkeeping**  **Requirements 1,308**  **.13**
**TOTAL LABOR BURDEN AND COST**  **(rounded) 1,373**  **$132,900**
Assumptions : a

. We have assume d that the average number of respondents that will be subject to the rule will be 13. There will be no additional new sources that will become subject to the rule over the three

- year period of this ICR. b. This ICR uses the following labor rates: Technical $100.23 ($47.73 + 110%); Managerial $121.44 ($57.83+ 110%); and Clerical $50.51 ($24.05 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Worker s, 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 em ploy ed by private industry. This ICR assumes that Managerial hours are 5 percent of Technica l hours, and Clerical hours are 10 percent of Technical hours. c. As specified in the general provisions, each performance test shall consist of three separate runs using the applicable test method. Sources are require d to use the spectrophotometric mo lybdovanadophosphate method (AOAC) Method 9 published in the 11 Edition of the Official Methods of Analysis of the Associat ion of Official Analytical Chemists dated 1970, to determine the P 2 O 5 feed rate.17

d. As specified in the general provisions, each pe rformance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specific in the applicable rule. For these rules, the total fluoride concentration and volumetric flow rate of the effluent gas shall be determined by Method 13 which requires a sampling time and a sample volume for each run of at least 60 minutes and 0 .85 dscm (30 dscf). e. We assume that 20 percent of initial performance tests must be repeated due to failure. f. Only sources that have a granular triple superphosphate storage facility are required to submit this initial plan. g. We assume that 15 percent of the source would be attributed to operational changes. h. We assume that each source will submit a semiannual report due to excess emission and monitoring systems performance over the three

- year period. i. Sources are required to maintain a daily record of operating parame ters (e.g., determine equivalent P 2 O 5 content and total pressure drop across the scrubbing system). We assume that the operation is 350 days per year as specified in the NSPS review document.18

**Table 2: Average Annual EPA Burden and Cost**

**– NSPS for Phosp**  **hate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V,**  **W and X) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H**
**EPA Hours per**  **Occurrence Number of** 

**Occurrences Per Year**  **EPA**

**Person Hours Per**  **Year (A x B)**  **Plants P**  **er**

**Y ear**  **a Technical** 

**Hours Per Year**  **(C x D) Management** 

**Hours Per Year**  **(E x 0.05) Clerical** 

**Hours Per Year**  **(E x 0.10) Total**  **Cost**

**P er Year**  **($) b** 

**R eport**  **R eview**  **New Plants**  Notification of construction/reconstruction 2 1 2 0 0 0 0 $ 0 Notification of initial startup 0.5 1 0.5 0 0 0 0 $ 0 Notification of actual startup 0.5 1 0.5 0 0 0 0 $ 0 Notification of initial test 0.5 1.2 0.6 0 0 0 0 $ 0 Review test results 8 1.2 9.6 0 0 0 0 $ 0 Notification of CMS demonstration 0.5 1 0.5 0 0 0 0 $ 0 **Ex isting Plants**  Semiannual report 1 2 2 13 26 1.3 2.6 $ 1,347.44

**TOTAL ANNUAL BURDEN AND COST (rounded)**  **30 $**  **1,347**
Assumptions: a
. We have assumed that the average number of respondents that will be subject to the rule will be 13. There will be no additional new sources that will become subject to the rule over the three

- year period of this ICR. b. This cost is based on the average hourly labor rate as follow s: Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%); Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%); and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Te chnical hours. These rates are from the OPM, 201 2 General Schedule, which excludes locality , rates of pay. The rates have been increased by 60 percent to account for the benefit packages avai lable to government employees.
c. We have assumed that each plant will take one hour twice per year to review semiannual report.