# SUPPORTING STATEMENT

ENVIRONMENTAL PRO TECTION AGENCY

Phosphoric Acid Manufacturing and Phosphate Fertilizer Production RTR and Standards of

Performance for Phosphate Processing

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

Phosphoric Acid Manufacturing (40 CFR part 63, subpart AA) and Phosphate Fertilizer

Production (40 CFR part 63, subpa rt BB) RTR and Standards of Performance for Phosphate

Processing (40 CFR part 60, subpa rts T, U, V, W, and X)

1(b) Short Charac terization/Abstract

This supporting statement addresses informati on collection activities that will be imposed

by amendments to the National Emission Sta ndards for Hazardous Air Pollutants (NESHAP)

from Phosphoric Acid Manufacturing and P hosphate Fertilizer Pr oduction, 40 CFR part 63,

subparts AA and BB, referred to as the Phosphor ic Acid and Phosphate Fertilizer NESHAP and

information collection activities imposed by amendm ents to the Standards of Performance for the

Phosphate Fertilizer Industry, 40 CFR part 60, subpart s T, U, V, W, and X, referred to as the

Phosphoric Acid Manufacturing and Phosphate Fertilizer NSPS. In 1999, the Environmental

Protection Agency (EPA) promulgated national emission standards for hazardous air pollutants

for new and existing phosphoric ac id manufacturing and phosphate fertilizer produc tion facilities

under 40 CFR part 63, subparts AA and BB (64 FR 31358, June 10, 1999). On June 13, 2002

EPA amended subpart AA to revise PM emissions limits for existing phosphate rock calciners, in

response to a petition from The Fertilizer In stitute. Phosphoric Acid Manufacturing and

Phosphate Fertilizer NSPS requirements were promulgated in 1975 for subparts T and U and in

1977 for subparts V, W, and X. As part of th e residual risk review for the NESHAP and

technology reviews for both the NESHAP and N SPS, EPA issued proposed rules in 2014 and

finalized rules in 2015. This information co llection request documents the additional

recordkeeping and reporting requirements and burden imposed by the finalized rules.

This ICR includes the burden for activities that will be conducted in the first three years

following promulgation of the Phosphoric Acid and Phosphate Fertilizer NESHAP. These

activities include reading the rule, performance testing, comple ting performance evaluations,

developing a gypsum dewatering stack and coo ling pond management plant, and monitoring,

recordkeeping, and repo rting requirements.

This ICR does not include burden for the finalized Phosphoric Acid and Phosphate

Fertilizer NSPS requirements. These finalized requirements will only apply to new sources, and

we are not aware of any planned new sources. Also, we believe that most, if not all, new sources

will be exempt from NSPS compliance due to the likelihood of the new source being subject to

NESHAP subpart AA or BB.

# The use of the term "Designated Administra tor" throughout this document refers to the

U.S. EPA Administrator or a delegated authority such as a state agency. The term

"Administrator" alone refers to the U.S. EPA Administrator.

This ICR presents the burden to respondents and the Designated Administrator (State or

Federal Government) that will be imposed by th e plans developed to implement the Phosphoric

Acid and Phosphate Fertilizer NESHAP. Respondent s are owners or operators of existing major

source phosphoric acid manufacturing and phos phate fertilizer pr oduction facilities.

The requirements described below are the minimum requirements established by the

finalized Phosphoric Acid and Phosphate Fertilizer NESHAP. Although the Designated

Administrator may choose to impos e more stringent requirements, it is assumed for this burden

estimate that the implemented plans mirror th e Phosphoric Acid and Phosphate Fertilizer

NESHAP.

Over the next three years, 13 phosphoric acid manufacturing and phosphate fertilizer

production facilities (12 facili ties produce phosphoric acid an d 11 facilities produce phosphate

fertilizer) will be subject to this standard, and the cost of this ICR will be $671,500. The burden

to the “Affected Public” for each facility may be found in Tables 1 through 4 in Attachment 1.

The burden to the “Federal Government” is attr ibuted entirely to work performed by federal

employees or government contractors; this bu rden may be found in Tables 5 through 8 of

Attachment 2.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under CAA Section 112, as amended, to establish standards of

performance for each category or subcategory of major sources and area sources of hazardous air

pollutants (HAP). These standards are applicable to new or existing sour ces of HAP and require

the maximum degree of emission reduction. In addition, CAA section 114(a) states that the

Administrator may require any owner/operator su bject to any requirement of this Act to:

(A) Establish and maintain such re cords; (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 peri ods, and in such manner as the

Administrator shall prescribe) ; (E) keep records on control

equipment parameters, production vari ables or other indirect data

when direct monitoring of emi ssions is impractical; (F) submit

compliance certifications in accordance with Section 114(a)(3);

and (G) provide such other inform ation as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from phosph oric acid manufacturing

# and phosphate fertilizer production f acilities cause or contribute to air pollution that may

reasonably be anticipated to endanger public heal th or welfare. Therefore, the NESHAP were

promulgated for major sources in th is source category at 40 CFR part 63, subparts AA and BB.

2(b) Practical Utilit y/Users of the Data

The information will be used by Designate d Administrators' enforcement personnel to

ensure that the requirements ar e being implemented and are comp lied with on a continuous basis.

Specifically, the information will be used by the Designated Administrator to: (1) identify

sources subject to the standards; (2) ensure th at the Phosphoric Acid and Phosphate Fertilizer

NESHAP being properly applied; (3) ensure that the Phosphoric Acid an d Phosphate Fertilizer

NESHAP being complied with; and (4) ensure, on a continuous basis, that the operating

parameters established during perf ormance tests are not exceeded.

In addition, records and reports are necessary to enable the Designated Administrator to

identify phosphoric acid manuf acturing and phosphate fertilizer production facilities that may

not be in compliance with the standards. Based on reported information, the Designated

Administrator can decide which facilities should be inspected and what records or processes

should be inspected. The records that facilitie s maintain would indica te to the Designated

Administrator whether the pers onnel are operating and maintaining control equipment properly

and whether they have met the qualification requirements.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporti ng will be required under 40 CFR part 63,

subparts AA and BB.

3(a) Nonduplication

If the subject standards have not been delega ted, the information is sent directly to the

appropriate EPA regional office. Othe rwise, the information is sent directly to the delegated state

or local agency. If a state or local agency has adopted its own similar st andards 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 re port required by the Fe deral standards. Ther efore, no duplication

exists.

3(b) Public notice prior to ICR submission to OMB

A public notice of this collecti on is provided in the Federal Register notice of rulemaking

published for the Phosphoric Acid Manufacturin g and Phosphate Ferti lizer Production RTR and

Standards of Performance for Phosphate Processing.

3(c) Consultations

The public was provided the opportunity to re view and comment on the burden estimated

in this Information Collection Request during the comment period for the proposed rulemaking.

# In addition, industry representatives includi ng The Fertilizer Institute, and all member

companies, provided information concerning th e Phosphoric Acid and Phosphate Fertilizer

NESHAP at meetings with the EPA prior to rule proposal and af ter rule proposal.

3(d) Effects of Less Frequent Data Collection

The Phosphoric Acid and Phospha te Fertilizer NESHAP requ ires initial and periodic

testing, continuous operating parameter monitori ng, performance evaluations, a notification of

compliance status, and summary reports. The freque ncy of these activities was chosen by EPA as

the period that will provide an adequate margin of assurance that affect ed facilities will not

operate for extended periods in violation of the standards.

Although continuous monitoring of operating parameters cannot provide a direct

measurement of emissions, it is less expensive than continuous emissions monitoring systems

(CEMS), and the information provided can be us ed to ensure that the air pollution control

devices are operating properly. This information assures EPA and the public that the reductions

envisioned by the regulations are being achieve d. Less frequent monitoring would not ensure

continuous compliance.

Requirements for information gathering and recordkeeping are useful techniques to

ensure that good operation and maintenance pr actices are applied and emission limitations are

met. If the information required by these stan dards 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 requireme nts do not violate any of the regulations

promulgated by OMB under 5 CFR part 1320, section 1320.5.

This rule requires all records to be maintained at the source for a pe riod of five years. In

40 CFR part 63, subpart A, "Gen eral Provisions for National Em ission Standards for Hazardous

Air Pollutants for Source Categories," owners or operators of facilities ar e required to keep and

maintain records for a period of five years. The title V permit programs also require records to be

retained for five years. These records must be kept on file for use, if needed, by the regulating

authority to ensure that the plant personnel are operating and maintaining control equipment

properly.

3(f) Confidentiality

All information submitted to the Agency for wh ich a claim of confidentiality is made will

be safeguarded according to the Agency po licies set forth in 40 CFR 2, subpart B --

Confidentiality of Business Informati on (see 40 CFR 2; 41 FR 36902, September 1, 1976,

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR

17674, March 23, 1979).

# 3(g) Sensitive Questions

The reporting or recordkeepi ng requirements in the standard do not include sensitive

questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

The respondents to the recor dkeeping and reporting requirement s are owners or operators

of new or existing major source phosphoric ac id manufacturing and phosphate fertilizer

production facilities. This includes, but is not limited to, North American Industry Classification

System (NAICS) Codes 325312 and 325314.

4(b) Information Requested

(i) Data Items

Tables 1 through 4 of Attachment 1 pres ent a summary of the recordkeeping and

reporting requirements of this regulation.

(ii) Respondent Activities

The respondent activities required by the standa rds are provided under the first column of

Tables 1 through 4 of Attachment 1, introduced in section 6(a). All burden items are included in

these tables.

(iii) Summary of Requirements

The information collection activities in this ICR include the following: reading the rule,

performance tests, operating parameter monito ring, preparation of a monitoring plan with

performance evaluations, preparation of a gypsum dewatering stack and cooling pond

management plan, periodic reports, and the main tenance of records. The activities in this ICR

and the associated burden estimate are only for ru le requirements which were previously not

included in the 2002 NESHAP.

Facilities must develop a monitoring plan to describe their methods of conforming to the

operating parameter requirements. This includes discussion of CPMS and CEMS requirements,

if applicable. The monitoring plan also includes procedures fo r performance evaluations which

must be performed annually, at a minimum.

Phosphoric acid facilities must prepare a gypsum dewatering stack and cooling pond

management plan which provides additional deta ils on their active gypsum dewatering stacks

and cooling ponds. As part of this plan, phosphoric acid facilities must provide documentation

which shows at least one of the fugitive emission c ontrol measures is already in place or will be

# implemented for their existing gypsum dewatering stacks or cooling ponds.

Performance testing is now required for addi tional emission sources and pollutants. The

regulation requires an ini tial performance test for mercury (Hg) and total fluoride (total F) at

phosphate rock calciners and for total F at oxida tion reactors. During the in itial performance test

the owner or operator must establish limits fo r each operating parameter. Thereafter, the owner

or operator must continuously monitor the operating parameters and perform annual testing.

Owners or operators of phosphoric acid ma nufacturing and phosphate fertilizer

production facilities are required to keep records of certain pa rameters and information for a

period of five years. These records include the performance test and operating parameter values

consistent with the monitoring plan and performance evaluation data.

All reports are to be submitted to the Designated Administrator. The information will be

used to determine that all sources subject to the Phosphoric Acid and Phosphate Fertilizer

NESHAP are achieving the requirements.

5. THE INFORMATION COLLECTED -- AG ENCY ACTIVITIES, COLLECTION,

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

A list of Agency activities is provided in section 6(c) and in Tables 5 through 8 of

Attachment 2.

5(b) Collection Methodology and Management

Data obtained during periodic vi sits by EPA personnel, from records maintained by the

respondents, and from information provided in reports will be tabulated and published for

internal EPA use in compliance and enforcemen t programs. The Phosphoric Acid and Phosphate

Fertilizer NESHAP allows records to be retained in hardcopy or electronic format to allow

flexibility and minimize burden.

Information contained in the reports is entere d into the Air Facility System (AFS) which

is operated and maintained by EPA's Office of Compliance. AFS is EPA’s database for the

collection, maintenance, and retrieval of comp liance data for approximately 125,000 industrial

and government-owned facilities. EPA uses th e AFS for tracking air pollution compliance and

enforcement by local and state re gulatory 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 five

years.

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses) affected by this regulation.

# The Phosphoric Acid and Phosphate Fertiliz er NESHAP does not contain any provisions

reserved exclusively for the benefit of small en tities; however, there ar e provisions that reduce

the impact on all regulated entities, which w ould include any small entities. This includes

requiring operating parameter monitoring instead of CEMS.

5(d) Collection Schedule

In the first year following promulgation of the Phosphoric Acid and Phosphate Fertilizer

NESHAP owners or operators would read the rule and are required to submit an initial

notification. We also anticipate the one-time and annual activities, including Hg and total F

performance tests for phosphate rock calcine rs, development of a monitoring plan with

performance evaluations, development of a gypsum dewatering stack and cooling pond

management plan, installation of a bag leak det ection system, and the notification of compliance

status (including performance te sts results and operating parameter values) will occur for

facilities starting in the first year . Facilities are not subject to total F limits that include oxidation

reactors until one year after the rule is finalized, therefore, these incremental total F testing costs

are only included in years 2 and 3.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Tables 1 through 4 of Attachment 1 document the computation of individual burdens and

non-labor costs for the recordkeep ing and reporting requirements appl icable to the industry for

each year for the subpart included in this I CR. The individual burdens are expressed under

standardized headings believed to be consistent with the concept of burden under the Paperwork

Reduction Act. Where appropriate, specific tasks and major assumptions have been identified.

Responses to this information collection are ma ndatory. Tables 5 through 8 of Attachment 2

present a summary of the agency burden.

The agency may not conduct or sponsor, a nd a person is not required to respond to, a

collection of information unless it displa ys 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 673 hours. The average annual recordkeeping

hours are 66 and the reporting requirement hours are 608, both of which are shown in Tables 1

through 4 of Attachment 1.

6(b) Estimating Respondent Costs

The information collection activities for s ources subject to these requirements are

presented in Tables 1 through 4 of Attachment 1. The total cost for each respondent activity

includes labor costs, capital/startup costs, a nd operating and mainte nance (O&M) costs.

# (i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $148.72 ($70.82 + 110%)

Technical $84.04 ($40.02 + 110%)

Clerical $30.24 ($14.40 + 110%)

These rates are from the United States Depart ment of Labor, Bureau of Labor Statistics,

May 2013, “National Industry-Speci fic Occupational Employment and Wage Estimates, NAICS

325300.” The rates are from column 8, mean hourly wage. The rates have been increased by 110

percent to account for the benefit packages av ailable to those employed by private industry.

(ii) Estimating Capital/Start-up and Operation and Maintenance Costs

The capital costs associated w ith the finalized Phosphoric Ac id and Phosphate Fertilizer

NESHAP include installation of bag leak detection systems and start-up costs only include

reading the rule; these 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

complete performance evaluations, conduct perf ormance testing, and other costs such as

photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Below are the estimated capital and startup costs and O&M costs for the affected units

for the first three years after promulgation.

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Unit Type (B)

Number of

Respondents

(facilities) (C)

Total

Capital/Startup

Costs (D)

Total Annual

Capital/Startup and

O&M Costs (E)

Average Annual

Capital/Startup

and O&M Costs

Phosphoric Acid and Phosphate

Fertilizer Production Facilities 13 $119,000 $505,500 $168,500



# The total capital/startup costs for this ICR are $119,000; column C.

The total annualized capital/startup and O&M costs fo r this ICR are $505,500, or an

average of $168,500 per year; column E. These are recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the agency are those costs associated with anal ysis of the reported

information. The EPA's overall compliance and en forcement program includes activities such as

the examination of records maintained by the respondents, periodic insp ection of sources of

emissions, and the publication and dist ribution of collected information.

# The average annual agency cost during the th ree years of the ICR is estimated to be

$17,300.

This cost is based on the averag e hourly labor rates as follows:

Managerial $62.27 (GS-13, Step 5, $38.92+ 60%)

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 Personne l Management (OPM), 2013 General Schedule,

which excludes locality rates of pay. The rates have been increas ed by 60 percent to account for

overhead and fringe benefit costs. Details on th e line item estimates used to calculate these

burdens are presented in Tables 5 through 8 of Attachment 2.

6(d) Estimating the Respondent Universe and Total Burden Costs

The total number of respondents is also refe rred to as the respondent universe. Based on

research, 13 existing facilities wi ll be subject to the standard. No new respondents will become

subject. Industry burden is calculated based on the number of facilities in each subcategory and

the anticipated controls and monito ring that each unit will most lik ely utilize to comply with the

finalized rules.

Total Annual Responses

(A)

Unit Type (B)

Number of

Respondents

(facilities) (C)

Total Number

Responses for 3-

year Period (D)

Average Annual

Number of

Responses

Phosphoric Acid and Phosphate

Fertilizer Production Facilities 13 47 16



# The number of average annual responses is 16.

6(e) Bottom Line Burden Hours and Cost Tables

(i) The Respondent Tally

The total annual labor hour s are 2,019. Furthermore, the annual public reporting and

recordkeeping burden for this collection of info rmation is estimated to average 43 hours per

response. The total annual labo r costs are $166,000 or $55,000 per ye ar. Details regarding these

estimates may be found in Tables 1 through 4 of Attachment 1.

The total annual capita l/startup and O&M costs to th e regulated entity are $505,500. The

cost calculations are detailed in Section 6(b)(iii), Ca pital/Startup vs. Operation and Maintenance

Costs.

# (ii) The Designated Administrator Tally

The average annual burden over the first thr ee years for the Designated Administrator

would be 331 hours at a cost of $17,300 per year . The Designated Administrator burden hours

and costs are presented in Tables 5 through 8 of Attachment 2.

6(f) Reasons for change in burden

The burden has decreased from the proposed rule s to the final rules due to changes in the

rule requirements. This decrease in burden is du e to the fact that faci lities are not subject to

Method 320 testing for hydrogen fluor ide and defluorination units a nd clarifiers are not subject

to the rule. However, there was burden added for installing a bag leak detection system.

6(g) Burden Statement

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

is estimated to be 43 hours per response. Burden means 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; deve lop, acquire, install,

and utilize technology and systems for the purpo ses of collecting, validating, and verifying

information, processing and maintaining informa tion, and disclosing and providing information;

adjust the existing ways to comply with any prev iously applicable instru ctions and requirements;

train personnel to be able to res pond to a collection of information; search data sources; complete

and review the collection of info rmation; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, a nd a person is not required to respond to, a

collection of information unless it displays a currently valid OMB control number. The OMB

Control Numbers for EPA regulations are list ed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the agency's need for this in formation, the accuracy of the provided burden

estimates, and any suggested methods for mini mizing respondent burden, including the use of

automated collection techniques, the EPA has established a public docket for this ICR under

Docket ID Number EPA-HQ-OAR-2012-0522. An electronic version of the public docket is

available at http://www.regula tions.gov/ which may be used to obtain a copy of the draft

collection of information, submit or view pub lic comments, access the index listing of the

contents of the docket, and to access those docum ents 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 avai lable 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, Washi ngton, 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 Read ing Room is (202) 566-1744, and the telephone

number for the docket center is (202) 566-1927. Al so, 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-OAR-2012-0522 in any correspondence.

# PART B OF THE SUPPORTING STATEMENT

This section is not applicable because statistical methods ar e not used in data collection

associated with this regulation.

# ATTACHMENT 1

TABLES 1, 2, 3, and 4

Tables 1 - 3: Annual Respondent Burden and Cost of Recordkeeping and Reporting

Requirements for the Phosphoric Acid and Phosphate Fertilizer NESHAP – Years

1-3

Table 4: Summary of Annual Respondent Bu rden and Cost of Recordkeeping and

Reporting Requirements for the Phosphoric Acid and Phosphate Fertilizer

NESHAPBurden Item(A)RespondentHours perOccurrence(Technicalhours)(B)Non-LaborCosts PerOccurrence(C)Number ofOccurrencesPerRespondentPer Year(D)TechnicalHours perRespondentPer Year(A X D)(E)Number ofRespondentsPer Year(F)TechnicalHours perYear(D X E)(G)ClericalHours perYear(F X 0.1)(H)ManagementHours perYear(F X .05)(I)Total LaborCosts PerYear(J)Total NonLabor CostsPer Year(B x C x E)(K)TotalNumber ofResponsesper Year(C X E) Footnotes1. ApplicationsNA2. Surveys and StudiesNA3. Reporting RequirementsA. Read Rule20$0120234604623$43,471$00aB. Required Activities1. Mercury testing - Calciners10$8,00011066063$5,670$48,0000b2. TF testinga. Oxidation Reactors10$5,6001100000$0$00ca. Calciners10$5,60011066063$5,670$33,6000j3. Performance evaluation0$2,0001023000$0$46,0000d4. BLDSia. Capital cost0$25,200103000$0$75,6000b. Annual cost0$9,900103000$0$29,7000C. Create InformationInc. in 3BD. Gather InformationInc. in 3EE. Report Preparation1. Performance test report10$011022021$1,890$02e2. Develop monitoring plan15$0115233453517$32,603$023f3. Prepare gypsum stack managementplan20 $0 1 20 12 240 24 12 $22,681 $0 12 gReporting Subtotal118511959$111,985$157,300374. Recordkeeping RequirementsA. Read InstructionsInc. in 3AB. Implements ActivitiesNAC. Develop Record SystemNAD. Record information1. Records of Hg testing3$01361821$1,701$00b2. Records of TF testing3$01361821$1,701$00c,j3. Records of BLDS alarm5$01531521$1,418$00hE. Personnel TrainingInc. in 3BF. Time for AuditsNARecordkeeping Subtotal5153$4,820$00TOTAL123612462$116,805$157,30037Total Hours Labor Non-Labor TotalSummary of Respondent Burden 1,421 $116,805 $157,300 $274,105Initial Capital and Startup$119,071Annualized Capital/Start-up and O & M$276,371Footnotes:(a) Facilities must read Subparts AA and BB, firstyear only. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.(b) Facilities are not subject to annual Hg testingthe first or second years, costs are provided in year 3.(d) Facilities must follow performance evaluation criteria (calibrations) for control devices. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.(h) Records of BLDS alarms must be kept, we assumeeach fabric filter will warrant 5 hours of documenting for this requirement.(j) There are 6 phosphate rock calciners that are subject to TF testing starting in year 1.Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid andPhosphate Fertilizers NESHAP - Year 1(g) Includes preparation of gypsum dewatering stackand cooling pond management plan for the 12 phosphoric acid facilities, year one only. Assumed that each facility would already be employing one of thecontrol measures, so additional costs to implementa control measure were not estimated.(c) There are 3 oxidation reactor emission points that are currently not tested, but are applicable asnoted in the subpart AA clarifications. These emissions points will conduct total fluoride tests starting in year(e) Includes additional data submitted for Hg and TF tests, for oxidation reactor and phosphate rock calciners. The facilities' emission points that currently conduct TF tests are not considered, as theymustalready report their data. Submitted test reports include: one test report for calciner TF testing inyear 1; 4 test reports in year 2 for calciner and oxidation reactor TF testing; and 5 test reports inyear 3 forcalciner and oxidation reactor TF testing plus calciner Hg testing.(i) Facilities that use fabric filters must installa bag leak detection system (BLDS).(f) Includes development of CPMS performance evaluations/calibration for scrubbers, year one only. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.Burden Item(A)RespondentHours perOccurrence(Technicalhours)(B)Non-LaborCosts PerOccurrence(C)Number ofOccurrencesPerRespondentPer Year(D)TechnicalHours perRespondentPer Year(A X D)(E)Number ofRespondentsPer Year(F)TechnicalHours perYear(D X E)(G)ClericalHours perYear(F X 0.1)(H)ManagementHours perYear(F X .05)(I)Total LaborCosts PerYear(J)Total NonLabor CostsPer Year(B x C x E)(K)TotalNumber ofResponsesper Year(C X E) Footnotes1. ApplicationsNA2. Surveys and StudiesNA3. Reporting RequirementsA. Read Rule20$01200000$0$00aB. Required Activities1. Mercury testing - Calciners10$8,00011066063$5,670$48,0000b2. TF testinga. Oxidation Reactors10$5,60011033032$2,835$16,8000ca. Calciners10$5,60011066063$5,670$33,6000j3. Performance evaluation0$2,0001023000$0$46,0000d4. BLDSia. Capital cost0$25,200100000$0$00b. Annual cost0$9,900103000$0$29,7000C. Create InformationInc. in 3BD. Gather InformationInc. in 3EE. Report Preparation1. Performance test report10$011055053$4,725$05e2. Develop monitoring plan15$01150000$0$00f3. Prepare gypsum stack managementplan20 $0 1 20 0 0 0 0 $0 $0 0 gReporting Subtotal2002010$18,900$174,10054. Recordkeeping RequirementsA. Read InstructionsInc. in 3AB. Implements ActivitiesNAC. Develop Record SystemNAD. Record information1. Records of Hg testing3$01361821$1,701$00b2. Records of TF testing3$01392731$2,552$00c,j3. Records of BLDS alarm5$01531521$1,418$00hE. Personnel TrainingInc. in 3BF. Time for AuditsNARecordkeeping Subtotal6063$5,671$00TOTAL2602613$24,571$174,1005Total Hours Labor Non-Labor TotalSummary of Respondent Burden 299 $24,571 $174,100 $198,671Initial Capital and Startup$0Annualized Capital/Start-up and O & M$174,100Footnotes:(a) Facilities must read Subparts AA and BB, firstyear only. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.(b) Facilities are not subject to annual Hg testingthe first or second years, costs are provided in year 3.(d) Facilities must follow performance evaluation criteria (calibrations) for control devices. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.(h) Records of BLDS alarms must be kept, we assumeeach fabric filter will warrant 5 hours of documenting for this requirement.(j) There are 6 phosphate rock calciners that are subject to TF testing starting in year 1.Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid andPhosphate Fertilizers NESHAP - Year 2(c) There are 3 oxidation reactor emission points that are currently not tested, but are applicable asnoted in the subpart AA clarifications. These emissions points will conduct total fluoride tests starting in year(e) Includes additional data submitted for Hg and TF tests, for oxidation reactor and phosphate rock calciners. The facilities' emission points that currently conduct TF tests are not considered, as theymustalready report their data. Submitted test reports include: one test report for calciner TF testing inyear 1; 4 test reports in year 2 for calciner and oxidation reactor TF testing; and 5 test reports inyear 3 forcalciner and oxidation reactor TF testing plus calciner Hg testing.(g) Includes preparation of gypsum dewatering stackand cooling pond management plan for the 12 phosphoric acid facilities, year one only. Assumed that each facility would already be employing one of thecontrol measures, so additional costs to implementa control measure were not estimated.(i) Facilities that use fabric filters must installa bag leak detection system (BLDS).(f) Includes development of CPMS performance evaluations/calibration for scrubbers, year one only. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.Burden Item(A)RespondentHours perOccurrence(Technicalhours)(B)Non-LaborCosts PerOccurrence(C)Number ofOccurrencesPerRespondentPer Year(D)TechnicalHours perRespondentPer Year(A X D)(E)Number ofRespondentsPer Year(F)TechnicalHours perYear(D X E)(G)ClericalHours perYear(F X 0.1)(H)ManagementHours perYear(F X .05)(I)Total LaborCosts PerYear(J)Total NonLabor CostsPer Year(B x C x E)(K)TotalNumber ofResponsesper Year(C X E) Footnotes1. ApplicationsNA2. Surveys and StudiesNA3. Reporting RequirementsA. Read Rule20$01200000$0$00aB. Required Activities1. Mercury testing - Calciners10$8,00011066063$5,670$48,0000b2. TF testinga. Oxidation Reactors10$5,60011033032$2,835$16,8000ca. Calciners10$5,60011066063$5,670$33,6000j3. Performance evaluation0$2,0001023000$0$46,0000d4. BLDSia. Capital cost0$25,200100000$0$00b. Annual cost0$9,900103000$0$29,7000C. Create InformationInc. in 3BD. Gather InformationInc. in 3EE. Report Preparation1. Performance test report10$011055053$4,725$05e2. Develop monitoring plan15$01150000$0$00f3. Prepare gypsum stack managementplan20 $0 1 20 0 0 0 0 $0 $0 0 gReporting Subtotal2002010$18,900$174,10054. Recordkeeping RequirementsA. Read InstructionsInc. in 3AB. Implements ActivitiesNAC. Develop Record SystemNAD. Record information1. Records of Hg testing3$01361821$1,701$00b2. Records of TF testing3$01392731$2,552$00c,j3. Records of BLDS alarm5$01531521$1,418$00hE. Personnel TrainingInc. in 3BF. Time for AuditsNARecordkeeping Subtotal6063$5,671$00TOTAL2602613$24,571$174,1005Total Hours Labor Non-Labor TotalSummary of Respondent Burden 299 $24,571 $174,100 $198,671Initial Capital and Startup$0Annualized Capital/Start-up and O & M$174,100Footnotes:(a) Facilities must read Subparts AA and BB, firstyear only. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.(b) Facilities are not subject to annual Hg testingthe first or second years, costs are provided in year 3.(d) Facilities must follow performance evaluation criteria (calibrations) for control devices. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.(h) Records of BLDS alarms must be kept, we assumeeach fabric filter will warrant 5 hours of documenting for this requirement.(j) There are 6 phosphate rock calciners that are subject to TF testing starting in year 1.Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid andPhosphate Fertilizers NESHAP - Year 3(c) There are 3 oxidation reactor emission points that are currently not tested, but are applicable asnoted in the subpart AA clarifications. These emissions points will conduct total fluoride tests starting in year(e) Includes additional data submitted for Hg and TF tests, for oxidation reactor and phosphate rock calciners. The facilities' emission points that currently conduct TF tests are not considered, as theymustalready report their data. Submitted test reports include: one test report for calciner TF testing inyear 1; 4 test reports in year 2 for calciner and oxidation reactor TF testing; and 5 test reports inyear 3 forcalciner and oxidation reactor TF testing plus calciner Hg testing.(g) Includes preparation of gypsum dewatering stackand cooling pond management plan for the 12 phosphoric acid facilities, year one only. Assumed that each facility would already be employing one of thecontrol measures, so additional costs to implementa control measure were not estimated.(i) Facilities that use fabric filters must installa bag leak detection system (BLDS).(f) Includes development of CPMS performance evaluations/calibration for scrubbers, year one only. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.YearTechnicalHoursClericalHoursManagementHoursTotalLaborHours Labor CostsNon-Labor(AnnualizedCapital/Startup andO&M) Costs Total Costs1 1,236 124 62 1,421 $116,805 $157,300 $274,1052 260 26 13 299 $24,571 $174,100 $198,6713 260 26 13 299 $24,571 $174,100 $198,671Total 1,756 176 88 2,019 $165,947 $505,500 $671,447Average 585 59 29 673 $55,316 $168,500 $223,816YearNumber ofResponsesReportingHoursRecordkeepingHoursTotalHoursHours perResponse1 37 1,363 59 1,421 382 5 230 69 299 603 5 230 69 299 60Total 47 1,823 197 2,019 43Average 16 608 66 673 43Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and ReportingRequirements for the Phosphoric Acid and PhosphateFertilizers NESHAP

# ATTACHMENT 2

TABLES 5, 6, 7, and 8

Tables 5 - 7: Annual Designated Administrato r Burden and Cost of Recordkeeping and

Reporting Requirements for the Phosphoric Acid and Phosphate Fertilizer

NESHAP - Year 1-3

Table 8: Summary of Annual Designated Administrator Burden and Cost of

Recordkeeping and Reporting Requirements for the Phosphoric Acid and

Phosphate Fertilizer NESHAP(A) (B) (C) (D) (E) (F)Number ofOccurrencesPer YearEPA HoursPerOccurrenceTech HoursPer Year(C=A x B)ManagementHours PerYear(D = C x 0.05)ClericalHours PerYear(E = C x 0.1)EPA CostPer Year1. Applications2. Read and Understand Rule Requirements 10 20 200 10 20 $10,364 a3. Required ActivitiesA.2 16 32 2 3 $1,658 bB. Excess emissions -- Enforcement Activities 1 24 24 1 2$1,244 cC. Create InformationD. Gather InformationE. Report Reviews1.Review performance test report2 5 10 1 1 $518 d2.Review monitoring plan23 10 230 12 23 $11,9193.Review gypsum stack and cooling pond managementplan12 8 96 5 10 $4,975F. Prepare annual summary report1 10 10 1 1 $518 e4. Travel expenses: (1 person * 30 hours per year/ 8 hours per day * $75 per diem) + ($600 per roundtrip) = $881 per trip $1,763TOTAL602 30 60 $32,960Footnotes:a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 respondents).b Assumes EPA personnel attend 20 percent of the stack tests; only considers facilities with new emission points.c Assume 10 percent of the facilities will exceed emissions; only considers facilities with new emission points.d Estimate based on only the hours to review new requirements.e Estimate based on only the hours to add additionalinformation.Observe stack tests FootnotesTable 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirementsfor the PhosphoricAcid and Phosphate Fertilizers NESHAP - Year 1Burden Itemnot applicablenot applicablenot applicable(A) (B) (C) (D) (E) (F)Number ofOccurrencesPer YearEPA HoursPerOccurrenceTech HoursPer Year(C=A x B)ManagementHours PerYear(D = C x 0.05)ClericalHours PerYear(E = C x 0.1)EPA CostPer Year1. Applications2. Read and Understand Rule Requirements 0 20 0 0 0 $0 a3. Required ActivitiesA.3 16 48 2 5 $2,487 bB. Excess emissions -- Enforcement Activities 2 24 48 2 5$2,487 cC. Create InformationD. Gather InformationE. Report Reviews1.Review performance test report5 5 25 1 3 $1,296 d2.Review monitoring plan0 10 0 0 0 $03.Review gypsum stack and cooling pond managementplan0 8 0 0 0 $0F. Prepare annual summary report1 10 10 1 1 $518 e4. Travel expenses: (1 person * 30 hours per year/ 8 hours per day * $75 per diem) + ($600 per roundtrip) = $881 per trip $2,644TOTAL131 7 13 $9,432Footnotes:a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 respondents).b Assumes EPA personnel attend 20 percent of the stack tests; only considers facilities with new emission points.c Assume 10 percent of the facilities will exceed emissions; only considers facilities with new emission points.d Estimate based on only the hours to review new requirements.e Estimate based on only the hours to add additionalinformation.Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirementsfor the PhosphoricAcid and Phosphate Fertilizers NESHAP - Year 2 FootnotesBurden Itemnot applicableObserve stack testsnot applicablenot applicable(A) (B) (C) (D) (E) (F)Number ofOccurrencesPer YearEPA HoursPerOccurrenceTech HoursPer Year(C=A x B)ManagementHours PerYear(D = C x 0.05)ClericalHours PerYear(E = C x 0.1)EPA CostPer Year1. Applications2. Read and Understand Rule Requirements 0 20 0 0 0 $0 a3. Required ActivitiesA.3 16 48 2 5 $2,487 bB. Excess emissions -- Enforcement Activities 2 24 48 2 5$2,487 cC. Create InformationD. Gather InformationE. Report Reviews1.Review performance test report5 5 25 1 3 $1,296 d2.Review monitoring plan0 10 0 0 0 $03.Review gypsum stack and cooling pond managementplan0 8 0 0 0 $0F. Prepare annual summary report1 10 10 1 1 $518 e4. Travel expenses: (1 person * 30 hours per year/ 8 hours per day * $75 per diem) + ($600 per roundtrip) = $881 per trip $2,644TOTAL131 7 13 $9,432Footnotes:a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 respondents).b Assumes EPA personnel attend 20 percent of the stack tests; only considers facilities with new emission points.c Assume 10 percent of the facilities will exceed emissions; only considers facilities with new emission points.d Estimate based on only the hours to review new requirements.e Estimate based on only the hours to add additionalinformation.Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirementsfor the PhosphoricAcid and Phosphate Fertilizers NESHAP - Year 3 FootnotesBurden Itemnot applicableObserve stack testsnot applicablenot applicableYearTechnicalHours Management Hours Clerical Hours Total Hours LaborCostsNon-LaborCosts Total Costs1 602 30 60 692 $32,960 $0 $32,9602 131 7 13 151 $9,432 $0 $9,4323 131 7 13 151 $9,432 $0 $9,432Total 864 43 86 994 $51,825 $0 $51,825Average 288 14 29 331 $17,275 $0 $17,275Table 8 - Summary of Annual Designated Administrator Burden and Cost of Recordkeeping andReporting Requirements for the Phosphoric Acid andPhosphate Fertilizers NESHAP