SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production ( 40 CFR P art 63, S ubparts AA and BB) (Renewal)
1. Identification of the Information Collection 1(a) Title of the Infor mation Collection NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR Part 63, S ubparts AA and BB) (Renewal) , EPA I CR Number 1790.05, OMB Control Number 2060

- 0361 1(b) Short Characterization/Abstract The National Emiss ion Standards for Hazardous Air Pollutants (NESHAP) for P hosphoric A cid M anufacturing and P hosphate F ertilizers P roduction were : proposed on December 27, 1996 ; promulgated on June 10, 1999 ; and amended on June 12, 2002. These standards apply to owners , o r operators of existing phosphoric acid manufacturing and phosphate fertilizers production facilities. The rule applies to component processes at these facilities and to any new, modified, or reconstructed sources. Component processes include wet process phosphoric acid plants, superphosphoric acid plants, purified phosphoric acid plants, phosphate rock dryers, phosphate rock calciners, diammonium and monoammonium phosphate plants, and granular triple superphosphate (GTSP) plants. Since many of the facil ities affected by the standards also are subject to new source performance standards (NSPS), the standards include an exemption from the NSPS for those sources. The exemption eliminates a duplication of information collection requirements. Consistent with the General Provisions for National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories (40 CFR part 63, subpart A), respondents are major sources. Respondents are required to submit one

- time notifications (where applicable) a nd a one - time report on performance test results and must notify the United States Environmental Protection Agency

(EPA) if annual performance tests indicate a change in the baseline operating range of emission control equipment. P lants must develop and i mplement a startup, shutdown, and malfunction plan, and submit semiannual reports of any event in which the plan was not followed

. Quarterly reporting is required when excess emissions occur. General requirements applicable to all NESHAP require records of applicability determinations, test results, exceedances, periods of startups, shutdowns, or malfunctions; monitoring records, and all other information needed to determine compliance with the applicable standard. Records and reports must be retained fo r a total of five years (two years at the site; the remaining three years of records may be retained off

- site). Respondents are required to install monitoring devices to measure the pressure drop and liquid flow rate for wet scrubbers. These operating parameters are permitted to vary within ranges determined concurrently

with performance tests. Respondents must perform annual performance tests to verify , or reestablish operating ranges for purposes of determining exceedances.2

The standards require sourc es to determine and record the amount of phosphatic feed material processed , or stored on a daily basis. This requirement allows verification of plant operating rates, which is one of the factors considered in establishing the operating ranges of control devices. This requirement poses no additional burden upon the industry . This is so because proper plant operation and industry practice include daily

recording of phosphate

- bearing feed stocks processed. This practice predates the regulations and would c ontinue in their absence. Even considering this daily recording requirement , it places no additional burden upon sources; thus, no estimate has been made for this requirement. Based on our consultations with industry r epresentatives during a previous ren ewal , there is an average of one affected facility at each plant site and that each plant site has only o ne respondent (i.e., the owner/operator of the plant site). Approximately

1 2 sources currently are subject to the regulation, and it is estimated that no additional sources will become subject to the regulation in the next three years. The active (previous) In formation Collection Request ( IC R) had the following Terms of Clearance (TOC):

The cost of labor assumptions underlying the respondent and agen cy burden cost calculations should be updated in the next renewal. This IC R has been updated to include estimates of the respondent and agency burden costs based on the most recent rates for managerial, technical, and clerical labor

. Labor rates for the respondents are from the United States Department of L abor, Bureau of Labor Statistics, S eptember 2009, ” Table 2. Civilian Workers, by Occupational and Industry group .” Labor rates for the agency

are from the Office of Personnel Management (OPM), 2010 Gen eral Schedule, which excludes locality

rates of pay

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

- NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Productio n (40CFR part 63, subp arts AA and BB) (Renewal) . The burden to the “Federal Government” is attributed entirely to work performed by

F ederal employees or government contractors; this burden may be found below in Table 2: Average Annual EPA Burden

- NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40CFR part 63, subparts AA and BB) (Renewal)

. 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 esta blish 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 will require the maximum degree of em ission reduction. In addition, se ction 114(a) states that the Administrator may require any

owner , or operator subject to any requirement3

of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain s uch 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 prescrib e); (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 i nformation as the Administrator may reasonably

require.
Inthe Administrator's judgment, hazardous air pollutants (HAPs) emissions from phosphoric acid manufacturing and phosphate fertilizers plants cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 63, subparts AA and BB. 2(b) Practical Utility/Users of the Data The control of emissions of HAP from phosphoric acid manufacturing and phosphate fertilizers plants requires the installation of properly designed equipment and the operation and maintenance of that equipment. Emissions of HAP from phosphoric acid manufacturing and phosphate fertilizers plants are the result of operation of the affected facilities. The subject standards are achieved by the reduction of HAP emissions using control technology and/or leak detection and repair procedures. The notifications required in the applicable regulations are used to infor m 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 ensure that the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and that the regulations are being met. Performance test reports are needed as the se are the Agency records of a source's initial capability t o comply

with the emission standards, and serve as a record of the operating condit ions under which compliance was achieved. T he semiannual 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 report ing requirements described in this IC R is used by

the Agency

t o ensure that facilities affected by the NESHAP continue to operate the control equipment in compliance with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary to e nsure compliance with the applicable regulations, as required by the Clean Air Act. The information collected from recordkeeping and reporting requirements also is used for targeting inspections, and is of sufficient quality to be used as evidence in cour t. 3. Non
- duplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under (40 CFR part 63, subparts AA and BB).4

3(a) Non
- duplication If the subject standards have not been delegated, the informati on is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state , or local agency . I f a state , or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state , or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists. 3(b) Public Notice Required Prior to ICR Submission to OMB
An announcement of a public comment period for the renewal of this IC R was published in the Federal Register 74 FR 38004 on July 30 , 200 9 . No comments were received on the burden published in the Federal Register

. 3(c) Consultations Several consultations were conduct ed during a previous renewal of this I CR. First, the most recent I CR and the preparer of the active I CR were referenced. Then , the most recent data available on the Air Facility Sy stem (AFS) database as maintained by the Office of Compliance were accesse d

. Information available from the Office of Compliance Sector Notebook ’s ” Profile of the Agricultural Chemical, Pesticide, and Fertilizer Industry ,” the United States Census Bureau via the Internet , and other websites covering off

- site waste and recovery operations were also reviewed . In a dditionally , the following people were consulted: EPA ’ s Office of Air Quality Planning and Standards, Information Transfer and Program Integration Division; The Fertilizer In stitute (TFI ), Mr. William Herz, (202) 544

- 812 3; the Florida Department of Environmental Protection (FDAP), Ms. Cindy Phillips, (805) 921

- 9534; and the PCS Phosphate Company In corporated, Mr. William Schimming, (847) 849

- 4302. 3(d) Effects of Less Frequent Collection Less frequent information colle ction 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 emiss ion limitations are met. I f 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 the se reporting or recordkeeping requirements violate s any of the regulations establis hed by

OMB at 5 CFR part 1320, s ection 1320.5. These standards require affected facilities to maintain all records, including reports and notifications, for at least five years. T his is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with P art 70 permit programs and the five

- ye ar statute of limitations on which the permit progra m is based.5

Also, the retention of records for five ye ars would allow EPA to establish the compliance history o f 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 ye ars. 3(f) Confidentiality Any i nformation submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to th e Agency policies set forth in t itle 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 s sensitive qu estions. 4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes The respondents to the recordkeeping and reporting requirements are phosphoric acid manufacturing and phosphate fertilizers production facilities. The United States Standard In dustrial Classification (SI C) code for the respondents affected by the standards is SI C 2874 which corresponds to the North American Industry Classification Sy stem (NAI CS) 325312 for phosphoric acid manufacturing and phosphate fertilizers produc tion facilities. 4(b) Information Requested None of these reporting , or recordkeeping requirements violate s any of the regulations establis hed by

OMB at 5 CFR part 1320, s ection 1320.5. (i) Data Items All data in this IC R that are recorded and/or rep orted are required by the National Emission Standards for Hazardous Air Pollutants for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR part 63, s ubparts AA and BB). A source must make the following reports:

Notifications Standa rd Citation by Sections Notification and application of construction/reconstruction 63.5(d) Notification of initial startup 63.09(b), 63.607, and 63.6276
Notifications Standa rd Citation by Sections Notification of initial performance test 63.7(b), 63.9(e), 63.607, and 63.627 Extension of compliance 63.607, 63.627, and 63.9(c) Special compliance requirements 63.607, 63.627, and 63.9(d) Waiver of performance testing 63.607, 63.627, and 63.7(h) Notification of compliance status 63.607, 63.627, and 63.9(h)

Reports for 40 CFR part 63, subparts AA and BB In itial performance test report 63.607(a)(1), 63.627(a)(1), and 63.10(d) Semiannual report 63.10(e) and 63.607(c)(2) Quarterly report 63.10(e) and 63.607(c)(2) Annual report 63.10(e) and 63.607(c)(1) A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart AA and BB Performance test report 63.607(b)(1), 63.627(b)(1), and 63.10(b) Excess emissions report. 63.607(b)(2), 63.627(b)(2), and 63.10(b) Summary report 63.607(b)(3), 63.627(b)(3), and 63.10(b) Reports and notifications 63.10(b) Records retained for 5 years 63.10(b)(1) Electronic Reporting Presently , sources are using monitoring equipment that provides parameter data in an automated way , e.g., leaks and spills of phosphoric acid. 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 sy stems to allow sour ces to report electronically , so as to reduce the reporting burden. H owever, electronic reporting sy stems are still not widely u sed by the regulatory agencies. Iti s estimated that approximately 2 0 percent of the respondents use electronic reporting. (i i) Respondent Activities7 Respondent Activities Read instructions. In stall, calibrate, maintain, and operate devices for HAPs. Perform initial performance test, Reference Methods 5 and 13 test, and repeat performance tests if necessary

. Write the no tifications 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 informatio n. 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 and providing information. Adjust the existing way s 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 ty pe of monitoring equipment has significantly

reduced the burden associated with monitoring and recordkeeping.
5. The Information Collect ed: 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 Activitie s 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, anal yz e, and maintain data in the Air Facility Sy stem (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 inst alled and operational. Performance test reports are used by the Agency

to discern a source ’ s initial capability to comply8

with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by th e respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formatio n contained in the reports is entered into the AFS which is operated and maintained by the EPA Office of Compliance. AFS is the EPA 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 l ocal and state regulatory a gencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analy ze the data. The records required by

this regulation must be retained by the owner , or operator for five ye ars. 5(c) Small Entity Flexibility The exact number of small entities affected by this rule could not be determined based on a r eview of available documents related to the rule, including the full text of the Final Rule (60 FR 62930). A ccording to both the Final Rule and the Wood Manufacturing Operations NESHAP Implementation Document (EPA

- 456/R

- 97

- 005, updated March 2004), additi onal mechanisms for exempting smaller sources from the standards were put in place. The Implementation Document states: “In order to lessen the burden on ... small sources ... the EPA included material usage and emission limits in the NESHAP

. Facilities belo w these limits are designated by rule as area sources and are therefore not subject to the NESHAP.” 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 ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and l arge entities. T he Agency c onsiders 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

f or each information collection activity w ithin this request is shown below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Phosphoric Acid Manufacturing and Phosphat e Fertilizers Pr oduction (40 CFR part 63, s ubparts AA and BB) (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 indus try for each of the subparts included in this I CR.9

T he individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major as sumptions 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 Numbe r. 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 1,5 34 (Total Annual Burden from Table 1). These hours are based on Agency studie s and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previously approved I CR, and any

comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs
This I CR u ses the following labor rates: Managerial $114.77 ($54.65 + 110%) Technical $97.59 ($46.47 + 110%) Clerical $48.26 ($22.98 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2009, ” Tab le 2. Civilian W orkers, 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/St artup and Operation and Maintenance Costs The ty pes of industry

cost associated with the information collection activity in the standards are labor and continuous emission monitoring sy stems ( CEMs ) . The cap ital/startup costs are one

- time costs when a fa cility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs , such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capit al/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)10 Capit al/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) Tem perature mo nitoring device $2,700 0 0 $886 12 $10,632

The total capital/startup costs for this IC R are zero. T he cost of the temperature monitoring device would likely

b e written off the first year, so n o amortization of the cost is indicated. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $10,632. This is the total of column G. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with analy sis of the reported information. The EPA 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 I CR is estimated to be $ 47,12 9

. This cost is based on the average hourly labor rate as follows: Managerial $61.36 ( GS

- 13, Step 5, $38.35 + 60%) Technical $45.52 (GS

- 12, Step 1, $28.45 + 60%) Clerical $24.64 (GS

- 6, Step 3, $15.40 + 60%) These rates are from the Office of Personnel Management (OPM), 2009 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

- NESHAP for Phosphoric Acid Manufacturing and Phosph ate Fertilizers Production (40 CFR part 63, subparts AA and BB) (Renewal)

. 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our research for this IC R, approximately 1 2 existing sources currently are subject to the standard. It is estimated that no additional sources per year will become subject to the regulation in the next three years. The number of respondents is calculated using the following table which addresses the three years covered by

this I CR.11 Number of Respondents Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records but Do Not Submit Reports (D)

Number of Existing Resp ondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)
1 0 12 0 0 12 2 0 12 0 0 12 3 0 12 0 0 12 Average 0 12 0 0 12
To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this I CR is 12

. The number of responses per year is calculated using the following table: Total Annual Responses (A) Average Number of New Respondents per Year (B)

Number of Reports for New Sources (C)

Number of Existing R espondents (D)

Number of Reports for Existing Sources (F)

Number of Respondents That Keep Records but Do Not Submit Reports (E)

Total Annual Responses E=(AxB)+(CxD)+F

0 0 12 7 0 84 The number of Total Annual Responses is 84. The total annual labor cos ts are $ 144,297 . Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR part 63, s ubparts AA and BB) (Renewal)

. Note that the total annual capital and O&M cost to the regulated entity is $1 0,632 . These costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. The average annual Agency burden and cost over next three ye ars is estimat ed to be 1,062 labor hours at a cost of $ 47 , 12 9 . See below Table 2 Average Annual EPA Burden and Cost

- NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (4 0 CFR part 63, s ubparts AA and BB) (Renewal)

. 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 are estimated to average 18 hours per response.12

6(f) Reasons for Change in Burden There is no change in the calculation methodology for labor hours in this I CR compared to the previous I CR. This is du e to two considerations: 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three ye ars; and 2) the growth rate for the respondents is very low, negative or non

- existent. However, due to a mathematical correction, there is a decrease of eight hours in respondent labor hours.
T his I CR has been updated with the most recent available labor rates for each of the three labor categories

. There is an increase in both r espondent and Agency costs resulting from labor rate increases from 2003 to 2009. This I CR uses 2009 labor rates bec ause burden and cost calculations in Tables 1 and 2 of this I CR were expanded to include managerial and clerical labor rates, and the previous I CR only provided a technical la

bor rate. The cost figure has also been updated to the nearest dollar , where as the previous I CR rounded the figure to the nearest thousand dollar. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 18 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 sy stems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; adjust the existing way s 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 r equired 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 ac curacy of the provided burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Numbe r EPA

- HQ

- OECA

- 2009

- 0535

. An el ectronic 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 acc ess those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key i n the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Com pliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, R oom 3334, 1301 Constitution Avenue , N

. W

. , Washington, D

. C. 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

- 1752 . Also, you can send comments to the Office of Information and13

Regulatory

Affairs, Office of Management and Budge t, 725 17th Street, N

. W

. , Washington, D

. C

. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2009

- 0535 and OMB Control Number 2060

- 0361 in any correspon dence. Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.14

T ABLE 1: Annual Respondent Burden and Cost
- NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR p art 63, s ubparts AA and BB) (Renewa l)
Burden item (A) (B) (C) (D) ( E ) ( F ) ( G) ( H ) Hours per Occurrence Occurrences/

respondent/ per year Hours/

Respondent/ year (C = AxB) Respondents

per year Managerial

Hours/Year a Technical

Hours/Year a Clerical

Hours/Year a Cost/year

($) 1. Applicatio ns N/A 2. Survey and Studies N/A 3. Acquisition, Installation, and Utilization of Technology and Systems N/A 4. Reporting Requirements A. Read instructions 4 1 4 0 0 0 0 $0 B. Required activities Initial performance test 28 1 28 0 0 0 0 $0 Repeat of initial performance test 28 0.1 2.8 0 0 0 0 $0 Startup, shutdown, malfunction plan 40 1 40 0 0 0 0 $0 Annual performance test 28 1 28 12 b 14.6 292.2 29.2 $31,600 Repeat annual performance test 28 0.2 5.6 0.84 c 0.2 4.1 0.4 $442 C. Create information See 4B D. Gather existing information See 4B E. Write report j Notification of applicability N/A Notification of construction./reconstruction 2 1 2 0 0 0 0 $0 Notification of actual startup N/A Notification of compliance requirements N/A Notification of performance test 2 1 2 0 0 0 0 $0 No tification of compliance status 4 1 4 0 0 0 0 $0 Report of performance test See 4B Report of monitoring exceedances 16 4 64 1.2 d 3.3 66.8 6.7 $7,22315

Report of no excess emissions 8 2 16 10.8 e 7.5 150.3 15.0 $16,251 Startup/ shutdown/ malfunction report 8 1 8 1 f 0.3 7.0 0.7 $752 Subtotal for Reporting 598 $56,269 5. Recordkeeping Requirements A. Read instructions 4 1 4 0 0 0 0 $0 B. Plan activities See 5E C. Implement activi ties See 5E D. Develop record system See 5E E. Time to enter information Records of operating parameters 1.5 g 52 h 78 12 b 40.7 813.9 81.4 $88,028 F. Time to train personnel i N/A G. Time to com

ply with applicable requirements See 4B
H. Time for audits N/A Subtotal for Recordkeeping 936 $88,028 TOTAL ANNUAL BURDEN (rounded) 1,534 $144,297 Assumptions:
a This ICR assume s that managerial hours are 5 percent of t echnical h ours, and clerical hours are 10 percent of t echnical hours. This ICR uses a labor rate of $114.77 for managerial hours, $97.59 for technical hours, and $48.26 for clerical hours

. b We have a ssume d that the average of respondents that will be subject to the rule will be twelve. T here will be no additional new sources per year that will become subjec t to the rule over the three

- year period of this ICR.
c We have assumed that 7 percent of respondents will fail the initial performance test and must repeat it. d We have a ssume d that 10 percent of respondents will report exceedances. Respondents are required to report quarterly.
e We have a ssume d that 90 percent of existing respondents report no excess emissions semiannually. f We have a ssume d that 1 of 12 sources will have to submit a startup, shutdown, or malfunction report. g We have a ssume d that it will take 1.5 hours per respondent to enter information. h We have a ssume d that information is entered one

- time per week for 52 w eeks per year. i There are no hours for training personnel since no tr aining is required by the rule and hours have been allotted under 5A for reading and understanding the recordkeeping/reporting requirements.16

TABLE 2: AVERAGE Annual EPA Burd en - NESHAP for Phosphoric Acid Manufacturing Plants and Phosphate Fertilizers Production (40 CFR p art 63, s ubparts AA and BB) (Renewal)
Burden Item (A) (B) (C) (D) (E) (F) (G) (H) EPA hrs/ Occurrence Occurrences

/plant / year EPA

person/ hour per plan t per year (C=AxB) Plants

per year Managerial

person /hours per year Technical

person /hours per year Clerical person

/hours per year EPA Cost

/year a

Initial performance test 40 1 40 0 0.0 0.0 0.0 $0 Repeat initial performance test R etesting preparation 8 1 8 0 0.0 0.0 0.0 $0 Retesting 40 1 40 0 0.0 0.0 0.0 $0 Excess Emissions Enforcement Activities N/A Report Review Notification of applicability 2 1 2 0 0.0 0.0 0.0 $0 Notification of constr uction./reconstruction N/A Notification of anticipated startup N/A Notification of actual startup N/A Notification of special compliance requirements N/A
Notification of initial performance test 2 1 2 0 0.0 0.0 0.0 $0 Notification of compliance status 2 1 2 0 0.0 0.0 0.0 $0 Annual performance test 40 1 40 12 20.9 417.4 41.7 $21,309 Repeat annual performance test 40 1 40 0.84 1.5 29.2 2.9 $1,492 Excess emissions report 20 4 80 1.2 4.2 83.5 8.3 $4,262 No excess emissions report 20 2 40 10.8 18.8 375.7 37.6 $19,178 Waiver application N/A 0.0 0.0 0.0 $017

Startup, shutdown, malfunction report 20 1 20 1 0.9 17.4 1.7 $888

TOTAL ANNUAL EPA BURDEN 1,062 $47,1 2 9
Assumptions : a The cost is based on rates from the Office of Personnel Management (OPM) ” 20 10 General Schedule “ which excludes locality rates of pay. b We have a ssume d that the average of respondents that will be subject to the rule wi ll be 12 . The re will be no additional new sources per year that will become subject to the rule over the three

- year period of this ICR.
c We have assumed that 7 percent of respondents will fail the initial performance test and must repeat it. d We have a ssume d that 10 percent of respondent will report exceedances. Respondents are required to report quarterly.
e We have a ssume d that 90 percent of existing respondents report no excess emissions semiannually. f We have a ssume d that 1 of 12 sources will have to submi t startup, shutdown, or malfunction report.