SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION 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, subpart BB) RTR and Standards of Performance for Phosphate 

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

1(b) Short Characterization/Abstract 

This supporting statement addresses information collection activities that will be imposed 

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

from Phosphoric Acid Manufacturing and Phosphate Fertilizer Production, 40 CFR part 63, 

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

information collection activities imposed by amendments to the Standards of Performance for the 

Phosphate Fertilizer Industry, 40 CFR part 60, subparts 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 acid manufacturing and phosphate fertilizer production 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 Institute. 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 the residual risk review for the NESHAP and 

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

finalized rules in 2015. This information collection 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, completing performance evaluations, 

developing a gypsum dewatering stack and cooling pond management plant, and monitoring, 

recordkeeping, and reporting 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 Administrator" 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 the plans developed to implement the Phosphoric 

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

source phosphoric acid manufacturing and phosphate fertilizer production 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 impose more stringent requirements, it is assumed for this burden 

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

NESHAP. 

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

production facilities (12 facilities produce phosphoric acid and 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 attributed entirely to work performed by federal 

employees or government contractors; this burden 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 sources 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 subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

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

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

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

and (G) provide such other information as the Administrator may 

reasonably require. 

In the Administrator's judgment, HAP emissions from phosphoric acid manufacturing 
and phosphate fertilizer production facilities cause or contribute to air pollution that may 

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

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

2(b) Practical Utility/Users of the Data

The information will be used by Designated Administrators' enforcement personnel to 

ensure that the requirements are being implemented and are complied 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 that the Phosphoric Acid and Phosphate Fertilizer 

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

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

parameters established during performance tests are not exceeded. 

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

identify phosphoric acid manufacturing 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 facilities maintain would indicate to the Designated 

Administrator whether the personnel 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 reporting will be required under 40 CFR part 63, 

subparts AA and BB.

3(a) Nonduplication

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 prior to ICR submission to OMB

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

published for the Phosphoric Acid Manufacturing and Phosphate Fertilizer Production RTR and 

Standards of Performance for Phosphate Processing. 

3(c) Consultations

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

in this Information Collection Request during the comment period for the proposed rulemaking. 
In addition, industry representatives including The Fertilizer Institute, and all member 

companies, provided information concerning the Phosphoric Acid and Phosphate Fertilizer 

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

 

3(d) Effects of Less Frequent Data Collection

The Phosphoric Acid and Phosphate Fertilizer NESHAP requires initial and periodic 

testing, continuous operating parameter monitoring, performance evaluations, a notification of 

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

the period that will provide an adequate margin of assurance that affected 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 used 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 achieved. Less frequent monitoring would not ensure 

continuous compliance. 

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. 

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

40 CFR part 63, subpart A, "General Provisions for National Emission Standards for Hazardous 

Air Pollutants for Source Categories," owners or operators of facilities are 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 which a claim of confidentiality is made will 

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

Confidentiality of Business Information (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 recordkeeping 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 recordkeeping and reporting requirements are owners or operators 

of new or existing major source phosphoric acid 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 present a summary of the recordkeeping and 

reporting requirements of this regulation. 

(ii) Respondent Activities

The respondent activities required by the standards 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 monitoring, preparation of a monitoring plan with 

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

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

and the associated burden estimate are only for rule 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 for 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 details 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 control measures is already in place or will be 
implemented for their existing gypsum dewatering stacks or cooling ponds. 

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

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

phosphate rock calciners and for total F at oxidation reactors. During the initial performance test 

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

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

Owners or operators of phosphoric acid manufacturing and phosphate fertilizer 

production facilities are required to keep records of certain parameters 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 -- AGENCY 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 visits 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 enforcement 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 entered 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 compliance data for approximately 125,000 industrial 

and government-owned facilities. EPA uses the AFS 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 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 Fertilizer NESHAP does not contain any provisions 

reserved exclusively for the benefit of small entities; however, there are provisions that reduce 

the impact on all regulated entities, which would 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 calciners, development of a monitoring plan with 

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

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

status (including performance tests 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 recordkeeping and reporting requirements applicable to the industry for 

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

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

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

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

present a summary of the agency burden. 

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 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 sources 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, and operating and maintenance (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 Department of Labor, Bureau of Labor Statistics, 

May 2013, “National Industry-Specific 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 available to those employed by private industry. 

 

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

The capital costs associated with the finalized Phosphoric Acid 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 performance 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 for 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 analysis of the reported 

information. The 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 

$17,300. 

This cost is based on the average 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 Personnel Management (OPM), 2013 General Schedule, 

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

overhead and fringe benefit costs. Details on the 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 referred to as the respondent universe. Based on 

research, 13 existing facilities will 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 monitoring that each unit will most likely 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 hours are 2,019. Furthermore, the annual public reporting and 

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

response. The total annual labor costs are $166,000 or $55,000 per year. Details regarding these 

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

The total annual capital/startup and O&M costs to the regulated entity are $505,500. The 

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

Costs. 
(ii) The Designated Administrator Tally 

The average annual burden over the first three 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 rules to the final rules due to changes in the 

rule requirements. This decrease in burden is due to the fact that facilities are not subject to 

Method 320 testing for hydrogen fluoride and defluorination units and 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; 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 currently valid OMB control number. The OMB 

Control Numbers for EPA regulations are listed in 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, 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.regulations.gov/ which may be used to obtain a copy of the draft 

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

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

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

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

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

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

Number EPA-HQ-OAR-2012-0522 in any correspondence. 
PART B OF THE SUPPORTING STATEMENT 

This section is not applicable because statistical methods are 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 Burden and Cost of Recordkeeping and 

Reporting Requirements for the Phosphoric Acid and Phosphate Fertilizer 

NESHAP
Burden Item

(A)

Respondent 

Hours per 

Occurrence 

(Technical 

hours)

(B) 

Non-Labor 

Costs Per 

Occurrence

(C) 

Number of 

Occurrences 

Per 

Respondent 

Per Year

(D)

Technical 

Hours per 

Respondent 

Per Year

 (A X D)

(E)

Number of 

Respondents 

Per Year

(F)

Technical 

Hours per 

Year

(D X E)

(G) 

Clerical 

Hours per 

Year

(F X 0.1)

(H)

Management 

Hours per 

Year

(F X .05)

(I)

Total Labor 

Costs Per 

Year

L

1. Applications NA2. Surveys and Studies NA3. Reporting Requirements

A. Read Rule 20 $0 1 20 23 460 46 23 $43,471 B. Required Activities

1. Mercury testing - Calciners 10 $8,000 1 10 6 60 6 3 $5,670 2. TF testing

a. Oxidation Reactors 10 $5,600 1 10 0 0 0 0 $0 a. Calciners 10 $5,600 1 10 6 60 6 3 $5,670 

3. Performance evaluation 0 $2,000 1 0 23 0 0 0 $0 4. BLDS 

a. Capital cost 0 $25,200 1 0 3 0 0 0 $0 b. Annual cost 0 $9,900 1 0 3 0 0 0 $0 

C. Create Information Inc. in 3BD. Gather Information Inc. in 3EE. Report Preparation

1. Performance test report 10 $0 1 10 2 20 2 1 $1,890 2. Develop monitoring plan 15 $0 1 15 23 345 35 17 $32,603 3. Prepare gypsum stack management plan 20 $0 1 20 12 240 24 12 $22,681 

Reporting Subtotal 1185 119 59 $111,985 4. Recordkeeping Requirements

A. Read Instructions Inc. in 3AB. Implements Activities NAC. Develop Record System NAD. Record information

1. Records of Hg testing 3 $0 1 3 6 18 2 1 $1,701 2. Records of TF testing 3 $0 1 3 6 18 2 1 $1,701 3. Records of BLDS alarm 5 $0 1 5 3 15 2 1 $1,418 

E. Personnel Training Inc. in 3BF. Time for Audits NA

Recordkeeping Subtotal 51 5 3 $4,820 TOTAL 1236 124 62 $116,805 

Total Hours Labor Non-Labor 

Summary of Respondent Burden 1,421 $116,805 $157,300 Initial Capital and Startup $119,071Annualized Capital/Start-up and O & M $276,371

Footnotes:(a) Facilities must read Subparts AA and BB, first year 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 testing the 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 fer(h) Records of BLDS alarms must be kept, we assume each 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 Phosp

Phosphate Fertilizers NESHAP - Year 1

(g) Includes preparation of gypsum dewatering stack and cooling pond management plan for the 12 phosphoric acid facilities, year one only. Assumed that each facility would already control measures, so additional costs to implement a control measure were not estimated.(c) There are 3 oxidation reactor emission points that are currently not tested, but are applicable as noted in the subpart AA clarifications. These emissions points will conduct total flu

(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 coalready report their data. Submitted test reports include: one test report for calciner TF testing in year 1; 4 test reports in year 2 for calciner and oxidation reactor TF testing; and 5 test 

calciner and oxidation reactor TF testing plus calciner Hg testing.(i) Facilities that use fabric filters must install a 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 p
Burden Item

(A)

Respondent 

Hours per 

Occurrence 

(Technical 

hours)

(B) 

Non-Labor 

Costs Per 

Occurrence

(C) 

Number of 

Occurrences 

Per 

Respondent 

Per Year

(D)

Technical 

Hours per 

Respondent 

Per Year

 (A X D)

(E)

Number of 

Respondents 

Per Year

(F)

Technical 

Hours per 

Year

(D X E)

(G) 

Clerical 

Hours per 

Year

(F X 0.1)

(H)

Management 

Hours per 

Year

(F X .05)

(I)

Total Labor 

Costs Per 

Year

L

1. Applications NA2. Surveys and Studies NA3. Reporting Requirements

A. Read Rule 20 $0 1 20 0 0 0 0 $0 B. Required Activities

1. Mercury testing - Calciners 10 $8,000 1 10 6 60 6 3 $5,670 2. TF testing

a. Oxidation Reactors 10 $5,600 1 10 3 30 3 2 $2,835 a. Calciners 10 $5,600 1 10 6 60 6 3 $5,670 

3. Performance evaluation 0 $2,000 1 0 23 0 0 0 $0 4. BLDS 

a. Capital cost 0 $25,200 1 0 0 0 0 0 $0 b. Annual cost 0 $9,900 1 0 3 0 0 0 $0 

C. Create Information Inc. in 3BD. Gather Information Inc. in 3EE. Report Preparation

1. Performance test report 10 $0 1 10 5 50 5 3 $4,725 2. Develop monitoring plan 15 $0 1 15 0 0 0 0 $0 3. Prepare gypsum stack management plan 20 $0 1 20 0 0 0 0 $0 

Reporting Subtotal 200 20 10 $18,900 4. Recordkeeping Requirements

A. Read Instructions Inc. in 3AB. Implements Activities NAC. Develop Record System NAD. Record information

1. Records of Hg testing 3 $0 1 3 6 18 2 1 $1,701 2. Records of TF testing 3 $0 1 3 9 27 3 1 $2,552 3. Records of BLDS alarm 5 $0 1 5 3 15 2 1 $1,418 

E. Personnel Training Inc. in 3BF. Time for Audits NA

Recordkeeping Subtotal 60 6 3 $5,671 TOTAL 260 26 13 $24,571 

Total Hours Labor Non-Labor 

Summary of Respondent Burden 299 $24,571 $174,100 Initial Capital and Startup $0Annualized Capital/Start-up and O & M $174,100

Footnotes:(a) Facilities must read Subparts AA and BB, first year 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 testing the 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 fer(h) Records of BLDS alarms must be kept, we assume each 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 Phosp

Phosphate Fertilizers NESHAP - Year 2

(c) There are 3 oxidation reactor emission points that are currently not tested, but are applicable as noted in the subpart AA clarifications. These emissions points will conduct total flu

(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 coalready report their data. Submitted test reports include: one test report for calciner TF testing in year 1; 4 test reports in year 2 for calciner and oxidation reactor TF testing; and 5 test 

calciner and oxidation reactor TF testing plus calciner Hg testing.(g) Includes preparation of gypsum dewatering stack and cooling pond management plan for the 12 phosphoric acid facilities, year one only. Assumed that each facility would already 

control measures, so additional costs to implement a control measure were not estimated.(i) Facilities that use fabric filters must install a 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 p
Burden Item

(A)

Respondent 

Hours per 

Occurrence 

(Technical 

hours)

(B) 

Non-Labor 

Costs Per 

Occurrence

(C) 

Number of 

Occurrences 

Per 

Respondent 

Per Year

(D)

Technical 

Hours per 

Respondent 

Per Year

 (A X D)

(E)

Number of 

Respondents 

Per Year

(F)

Technical 

Hours per 

Year

(D X E)

(G) 

Clerical 

Hours per 

Year

(F X 0.1)

(H)

Management 

Hours per 

Year

(F X .05)

(I)

Total Labor 

Costs Per 

Year

L

1. Applications NA2. Surveys and Studies NA3. Reporting Requirements

A. Read Rule 20 $0 1 20 0 0 0 0 $0 B. Required Activities

1. Mercury testing - Calciners 10 $8,000 1 10 6 60 6 3 $5,670 2. TF testing

a. Oxidation Reactors 10 $5,600 1 10 3 30 3 2 $2,835 a. Calciners 10 $5,600 1 10 6 60 6 3 $5,670 

3. Performance evaluation 0 $2,000 1 0 23 0 0 0 $0 4. BLDS 

a. Capital cost 0 $25,200 1 0 0 0 0 0 $0 b. Annual cost 0 $9,900 1 0 3 0 0 0 $0 

C. Create Information Inc. in 3BD. Gather Information Inc. in 3EE. Report Preparation

1. Performance test report 10 $0 1 10 5 50 5 3 $4,725 2. Develop monitoring plan 15 $0 1 15 0 0 0 0 $0 3. Prepare gypsum stack management plan 20 $0 1 20 0 0 0 0 $0 

Reporting Subtotal 200 20 10 $18,900 4. Recordkeeping Requirements

A. Read Instructions Inc. in 3AB. Implements Activities NAC. Develop Record System NAD. Record information

1. Records of Hg testing 3 $0 1 3 6 18 2 1 $1,701 2. Records of TF testing 3 $0 1 3 9 27 3 1 $2,552 3. Records of BLDS alarm 5 $0 1 5 3 15 2 1 $1,418 

E. Personnel Training Inc. in 3BF. Time for Audits NA

Recordkeeping Subtotal 60 6 3 $5,671 TOTAL 260 26 13 $24,571 

Total Hours Labor Non-Labor 

Summary of Respondent Burden 299 $24,571 $174,100 Initial Capital and Startup $0Annualized Capital/Start-up and O & M $174,100

Footnotes:(a) Facilities must read Subparts AA and BB, first year 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 testing the 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 fer(h) Records of BLDS alarms must be kept, we assume each 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 Phosp

Phosphate Fertilizers NESHAP - Year 3

(c) There are 3 oxidation reactor emission points that are currently not tested, but are applicable as noted in the subpart AA clarifications. These emissions points will conduct total flu

(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 coalready report their data. Submitted test reports include: one test report for calciner TF testing in year 1; 4 test reports in year 2 for calciner and oxidation reactor TF testing; and 5 test 

calciner and oxidation reactor TF testing plus calciner Hg testing.(g) Includes preparation of gypsum dewatering stack and cooling pond management plan for the 12 phosphoric acid facilities, year one only. Assumed that each facility would already 

control measures, so additional costs to implement a control measure were not estimated.(i) Facilities that use fabric filters must install a 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 p
Year

Technical 

Hours

Clerical 

Hours

Management 

Hours

Total 

Labor 

Hours Labor Costs

Non-Labor 

(Annualized 

Capital/Startup and 

O&M) Costs 

1 1,236 124 62 1,421 $116,805 $157,300 2 260 26 13 299 $24,571 $174,100 3 260 26 13 299 $24,571 $174,100 

Total 1,756 176 88 2,019 $165,947 $505,500 

Average 585 59 29 673 $55,316 $168,500 

Year

Number of 

Responses

Reporting 

Hours

Recordkeeping 

Hours

Total 

Hours

Hours per 

Response

1 37 1,363 59 1,421 382 5 230 69 299 603 5 230 69 299 60

Total 47 1,823 197 2,019 43

Average 16 608 66 673 43

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Re

Requirements for the Phosphoric Acid and Phosphate Fertilizers NESHAP
ATTACHMENT 2 

 TABLES 5, 6, 7, and 8 

Tables 5 - 7: Annual Designated Administrator 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) 

Number of 

Occurrences 

Per Year

EPA Hours 

Per 

Occurrence

Tech Hours 

Per Year

(C=A x B)

Management 

Hours Per 

Year

(D = C x 0.05)

1. Applications2. Read and Understand Rule Requirements 10 20 200 10 3. Required Activities

A. 2 16 32 2 B. Excess emissions -- Enforcement Activities 1 24 24 1 

C. Create InformationD. Gather Information

E. Report Reviews

1. Review performance test report 2 5 10 1 2. Review monitoring plan 23 10 230 12 3. Review gypsum stack and cooling pond management 

plan 12 8 96 5 

F. Prepare annual summary report 1 10 10 1 

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $881 

TOTAL 602 30 

Footnotes:

a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 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 additional information.

Observe stack tests

Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requiremen

Acid and Phosphate Fertilizers NESHAP - Year 1 

Burden Item

not applicable

not applicablenot applicable
(A) (B) (C) (D) 

Number of 

Occurrences 

Per Year

EPA Hours 

Per 

Occurrence

Tech Hours 

Per Year

(C=A x B)

Management 

Hours Per 

Year

(D = C x 0.05)

1. Applications2. Read and Understand Rule Requirements 0 20 0 0 3. Required Activities

A. 3 16 48 2 B. Excess emissions -- Enforcement Activities 2 24 48 2 

C. Create InformationD. Gather Information

E. Report Reviews

1. Review performance test report 5 5 25 1 2. Review monitoring plan 0 10 0 0 3. Review gypsum stack and cooling pond management 

plan 0 8 0 0 

F. Prepare annual summary report 1 10 10 1 

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $881 

TOTAL 131 7 

Footnotes:

a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 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 additional information.

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requiremen

Acid and Phosphate Fertilizers NESHAP - Year 2

Burden Item

not applicable

Observe stack tests

not applicablenot applicable
(A) (B) (C) (D) 

Number of 

Occurrences 

Per Year

EPA Hours 

Per 

Occurrence

Tech Hours 

Per Year

(C=A x B)

Management 

Hours Per 

Year

(D = C x 0.05)

1. Applications2. Read and Understand Rule Requirements 0 20 0 0 3. Required Activities

A. 3 16 48 2 B. Excess emissions -- Enforcement Activities 2 24 48 2 

C. Create InformationD. Gather Information

E. Report Reviews

1. Review performance test report 5 5 25 1 2. Review monitoring plan 0 10 0 0 3. Review gypsum stack and cooling pond management 

plan 0 8 0 0 

F. Prepare annual summary report 1 10 10 1 

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $881 

TOTAL 131 7 

Footnotes:

a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 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 additional information.

Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requiremen

Acid and Phosphate Fertilizers NESHAP - Year 3

Burden Item

not applicable

Observe stack tests

not applicablenot applicable
Year

Technical 

Hours Management Hours Clerical Hours Total Hours Labor Costs

Non-Labor 

Costs 

1 602 30 60 692 $32,960 $0 2 131 7 13 151 $9,432 $0 3 131 7 13 151 $9,432 $0 

Total 864 43 86 994 $51,825 $0 

Average 288 14 29 331 $17,275 $0 

Table 8 - Summary of Annual Designated Administrator Burden and Cost of Recordkee

Reporting Requirements for the Phosphoric Acid and Phosphate Fertilizers NES