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 1061.13, 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, promulgated on 

August 6, 1975, and amended on August 19, 2015. These regulations apply to both existing and 

new facilities that engage in the manufacture of phosphate fertilizers (wet-process phosphoric 

acid plants, superphosphoric acid plants, diammonium phosphate plants, and triple 

superphosphate plants), and have a design capacity of more than 15 tons of equivalent 

phosphorous pentoxide (P2O5) feed per calendar day. These standards also apply to new and

existing 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), 

coolers, 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, Subpart T, U, V, W, and X.

The August 2015 Phosphoric Acid Manufacturing and Phosphate Fertilizer Production 

NSPS rule amendments require owners and operators to establish an allowable range for the 

pressure drop through the process scrubbing system, keep records of the daily average pressure 

drop through the process scrubbing system, and keep records of deviations. The amendments did 

not result in any changes to the estimated burden in this ICR, because the requirements only 

apply to new sources constructed, modified, or reconstructed after November 7, 2014, and there 

are no projected new sources. In addition, most, if not all, new sources will be exempt from 

NSPS compliance due to the likelihood of the new source being subject to the NESHAP for 

Phosphoric Acid Manufacturing (40 CFR Part 63, Subpart AA) or Phosphate Fertilizer 

Production (40 CFR Part 63, Subpart BB).

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, 
2

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 five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U.S.

Environmental Protection Agency (EPA) regional office.

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 and can 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).

Over the next three years, 13 respondents per year will be subject to the standard, and no

additional respondents per year will become subject to these same standards.

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

without any “Terms of Clearance”.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 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 
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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, fluoride emissions from the phosphate fertilizer industry

either cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health and/or welfare. Therefore, the NSPS were promulgated for this source 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 these standards ensure compliance with 

the applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standards. Continuous emission monitors are used to 

ensure compliance with the standards at all times. 

The notifications required in the standards 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 standards are being met. The performance test may also be 

observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

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.
4

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 be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. The growth rate for the industry is based on our consultations 

with the Agency’s internal industry experts. 

Industry trade association and other interested parties were provided an opportunity to 

comment on the burden associated with the standards as they were being developed and the 

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) The Fertilizer Institute, at (202) 

515-2701; and 2) the Florida Industrial and Phosphate Research Institute (FIPR Institute), at 

(863) 534-7160. In this case, no comments were received.

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 
5

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.

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 standards is SIC 2874, which corresponds to the North American Industry

Classification System (NAICS) 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

Notification of construction/reconstruction. 60.7(a)(1) 
6

Notifications

Notification of initial startup including compliance method. 60.7(a)(3) 

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

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

Reports

Initial performance test results. 60.8(a)

Initial performance test. 60.8(d) 

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 were established. The file shall be retained for 

at least five years following the date of such measurements, 

maintenance, reports, and records.

60.7(f), 60.205

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 absorber.

60.203(c), 60.205(a), 

60.213(c), 60.215(a),

60.223(c), 60.225(a), 

60.233(c), 60.235(a),

60.243(c), 60.245(a)

Records of deviations

60.205(b), 60.215(b), 

60.225(b), 60.235(b),

60.245(b)

Mass of granular triple superphosphate in storage. 60.243(a)
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Recordkeeping

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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for the total pressure drop across the process 

absorber.

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 P2O5 content 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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.
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5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information:

Agency Activities

Review notifications and reports, including performance test reports and semiannual reports, 

required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 

and ICIS. 

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 are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

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

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters.

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for 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 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. 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. Wherever 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 1,390 hours (Total Labor Hours from Table 1).

These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the 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 $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “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 monitors 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 $320,000

TOTAL $320,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $320,000. 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 $320,000. 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 

$1,360.

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)
11

These rates are from the Office of Personnel Management (OPM), 2014 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 these standards. 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

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1

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 respondents include sources with constructed, reconstructed and modified affected facilities.

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: 

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
12

Total Annual Responses

Notification of Operational 

Change

2 1 N/A 2

Semiannual Report 13 2 N/A 26

Total 28

The number of Total Annual Responses is 28.

The total annual labor costs are $140,000 (rounded). 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 below, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 1,390 hours. 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). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 50 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $320,000. 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 $1,360. See below 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). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 
13

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

The increase in burden from the most-recently approved ICR is due to accounting for the 

assumption that all sources will spend one hour annually reviewing and understanding the rule 

requirements. Previously, the assumption was that only new sources would incur this burden.

There is a small decrease in O&M cost in this ICR due to rounding of all calculated 

values to three significant digits. In addition, there is an increase of two annual responses due to 

a minor correction. The previous ICR did not account for notifications of operational changes in 

calculating the number of responses. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 50 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), WJC 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, 
14

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 

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 and understand rule 

requirements 1 1 1 13 13 0.65 1.3 $1,503.39 

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 See 3B

D. Gather existing information See 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 See 3B

Site-specific methodology plan f 2 1 2 0 0 0 0 $0
16

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

Existing Sources

 Notification of operational change g2 1 2 2 4 0.2 0.4 $462.58 

 Semiannual report of exceedances h 2 2 4 13 52 2.6 5.2 $6,013.57 

Subtotal Reporting Requirements 79 $7,980 

4. Recordkeeping Requirements

 A. Read and understand rule 

requirements See 3A

 B. Plan activities See 3B

 C. Implement activities See 3B

 D. Develop record system N/A

 E. Time to enter information

Records of operation parameters 

and emissionsi 0.25 350 87.5 13 1137.5 56.88 113.75 $131,546.76 

Subtotal Recordkeeping Requirements 1,308 $131,547 

TOTAL LABOR BURDEN AND COST (rounded)j1,390 $140,000 

Total Capital/O&M Costs (rounded)j$320,000 

Grand Total (Labor and Capital/O&M Costs)(rounded)j$460,000 

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 $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%). These 

rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “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. 
17

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.

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.

j. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. 
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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 c1 2 2 13 26 1.3 2.6 $1,360.84 

TOTAL ANNUAL BURDEN AND COST (rounded)d30 $1,360 

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 $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 

60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 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, 2014 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.

d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.