SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

(Renewal), EPA ICR Number 1061.12, OMB Control Number 2060-0037.

1(b) Short Characterization/Abstract

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 facilities that engage in 

the manufacture of phosphate fertilizers, and have a design capacity of more than 15 tons of 

equivalent phosphorous pentoxide (P2O5) feed per calendar day. These standards also apply 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 wells, acid sumps, cooling tanks, granulators, dryers, coolers, screens, mills, 

mixers, curing belts (dens), cookers, and facilities which store run-of-pile triple superphosphate, 

depending on the type of plant. New facilities include those that commenced construction, 

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 tests, and 

periodic reports by the owners/operators of the affected facilities. They 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 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 such delegated authority, the reports are sent directly to the U.S.

Environmental Protection Agency (EPA) regional office.

Approximately 13 sources are currently subject to the regulation, and it is estimated that 

no new sources will become subject to the regulation over the next three years. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”
2

The burden to the “Affected Public” 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). The burden to the “Federal Government” is attributed entirely to work 

performed by either Federal employees or government contractors. This burden may be found 

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).

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 system of continuous 

emissions reduction which (taking into consideration the cost 

of achieving such emissions reduction, or any non-air quality 

health and environmental impact and energy requirements) the 

Administrator determines has been adequately 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 standards 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 information as the Administrator may

reasonably 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 source 
3

category at 40 CFR part 60, subparts 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 

the 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 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 standard 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.

The standards require recordkeeping to document information relating to the daily feed 

rate and storage of equivalent P2O5. Amounts of P2O5 are determined from continuous 

monitoring system (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 P2O5 feed as measured in Mg/hour. Therefore, the regulations 

require the hourly recording of data and the maintenance of daily records for purposes of 

determining the feed rate used in the standard. The information generated by the monitoring and

recordkeeping requirements described above is used by the Agency to ensure that facilities 

affected by the NSPS continue to operate and control equipment used to achieve compliance 

with the NSPS

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subparts 

T, U, V, W and X.

3(a) Non-duplication

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 
4

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

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 (77 FR 47631) on August 9, 2012. No comments were received on the 

burden published in the Federal 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 anyway for EPA to reduce the recordkeeping and reporting burden or 

improve the language in the standard to make it easier to comply. In developing this ICR, 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 frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations

promulgated by 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-year records retention requirement is consistent with 
5

the Part 70 permit program and the five-year statute of 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, any pattern of non-compliance, and to determine the appropriate level of 

enforcement action. EPA has found 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 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

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 (SIC) code for the respondents 

affected by the standard is 2874, which corresponds to North American Industry Classification 

System (NAICS) 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 by the NSPS for 

Phosphate Fertilizer Industry (40 CFR Part 60, Subparts 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)
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Notifications/Reports

Initial performance test. 60.8(d) 

Demonstration of continuous monitoring system. 60.7(a)(5)

Physical or operational change. 60.7(a)(4)

Semiannual or as indicated by the Administrator reports of 

exceedances or monitoring systems 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 system 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 

years following the date of such measurements, maintenance, reports, 

and records.

60.7(f)

Daily record of equivalent P2O5 feed rate.

60.203(b), 60.213(b), 

60.223(b), 60.233(b),

60.243(b)

Total pressure drop across any process scrubbing system.

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 

systems to transmit data electronically. However, electronic reporting systems are still not 
7

widely used. At this time, it is estimated that approximately 20 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 system.

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 P2O5content in megagrams per hour (Rp) of the 

feed, using the Association of Official Analytical 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 

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.

Adjust the existing ways 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 type of monitoring equipment has significantly reduced the 

burden associated with monitoring and recordkeeping. In addition, some regulatory agencies are 

setting up electronic reporting systems to allow sources to report electronically which is reducing 

the reporting burden. However, electronic reporting systems are still not widely used by the 

regulatory agencies.

5. The Information Collected: Agency Activities, Collection Methodology, and 
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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 quarterly reports of 

excess emissions reports or semiannual reports of no excess emission, required to be submitted 

by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

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 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. The semiannual reports of 

exceedances are used for problem identification, as a check on source operation and 

maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA’s Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses OTIS for tracking air pollution compliance and 

enforcement activity 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 two 

years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e. large businesses) as the number of 

employees at a typical fertilizer plant currently exceeds the criterion for small business. 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 
9

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 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 1,373 hours (Total Labor Hours from Table 1

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NSPS 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 $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

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 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
10

The type of industry costs associated with the information collection activities in the 

subject standards are both 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(s) 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)

Pressure 

drop 

monitor

$27,720 0 $ 0 $24,630 13 $320,190

TOTAL $320,190

There are no capital/startup costs for this ICR. This is the total of column D in the above 

table. 

The total operation and maintenance (O&M) costs for this ICR 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 ICR 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 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 

$1,347. 

This cost is based on the average hourly 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), 2012 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 ICR, on average over the next three years, approximately

13 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, 

as shown in the table below, is 13 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

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 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 respondents submit initial notifications.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 13. 

The total number of annual responses per year 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 Burden 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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 1,373 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 recently approved ICR is due to an adjustment of 

respondent and Agency labor hours. The previous ICR assumed that burden hours accounted for 

all technical, managerial, and clerical hours. To be consistent with the estimation methodology
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used in other ICRs, this ICR assumes that labor hours account for technical hours only. Clerical 

and managerial hours require additional time, and equal 10 and 5 percent of technical hours, 

respectively. Additionally, this ICR uses updated labor rates, resulting in an increase to the total 

burden costs.

6(g) Burden 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 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 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-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 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 Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the 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-2012-0533 and OMB Control Number 2060-0037 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 
14

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 Per 

Occurrence

Number of 

Occurrences 

Per 

Respondent 

Per Year

Person 

Hours Per 

Respondent 

Per Year 

(C=AxB)

Respondents 

Per Year 

a

Technical 

PersonHours 

Per Year 

(E=CxD)

Management 

Person Hours 

Per Year

(E x 0.05)

Clerical 

Person 

Hours Per 

Year

(E x 0.10)

Total Costs 

Per Year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Read Instructions 1 1 1 0 0 0 0 $0

 B. Required activities

New Sources

 Initial Performance Test

 AOCA Method 9 tests c29.7 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 e4 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 

3B
16

 Site-specific methodology plan f

2 1 2 0 0 0 0 $0

Existing Sources

 Notification of operational change g2 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. Recordkeeping Requirements

 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 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 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 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. This ICR assumes that Managerial hours are 5 percent of Technical 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 required to use 

the spectrophotometric molybdovanadophosphate method (AOAC) Method 9 published in the 11 Edition of the Official Methods of Analysis of the Association 

of Official Analytical Chemists dated 1970, to determine the P2O5 feed rate.
17

d. As specified in the general provisions, each performance 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 parameters (e.g., determine equivalent P2O5 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 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

EPA Hours 

per 

Occurrence

Number of 

Occurrences 

Per Year

EPA 

Person 

Hours Per 

Year

(A x B)

Plants Per 

Year

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 

Per Year

($) b

Report Review

 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

 Existing 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 follows: 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 Technical hours. These rates are from the OPM, 2012 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.

c.

 We have assumed that each plant will take one hour twice per year to review semiannual report.