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. This 

information collection request documents the additional recordkeeping and reporting 

requirements and burden imposed by the proposed rules. 

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

following promulgation of the proposed 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 proposed Phosphoric Acid and Phosphate 

Fertilizer NSPS requirements. These proposed 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 

proposed 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 $1,874,000. 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 proposed 

rulemaking published for the Phosphoric Acid Manufacturing and Phosphate Fertilizer 

Production RTR and Standards of Performance for Phosphate Processing.

3(c) Consultations

The public will be 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. 

 

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 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.

Phosphoric acid manufacturing and phosphate fertilizer production facilities must comply 

with hydrogen fluoride (HF) emission limits using Method 320. The current NESHAP required 

performance tests for total fluorides (TF) using Method 13A or 13B. The proposed Phosphoric 

Acid and Phosphate Fertilizer NESHAP translated those TF limits into HF limits and revised the 

test method, which has a higher cost per test. 

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

regulation requires an initial performance test for mercury (Hg) at phosphate rock calciners and

for HF at defluorination units, oxidation reactors, and clarifiers. 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 three years 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 performance tests 

(Hg and HF), development of a monitoring plan with performance evaluations, development of a 

gypsum dewatering stack and cooling pond management plan, and the notification of compliance 

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

facilities within the first three years. Facilities are not subject to HF limits until one year after the 

rule is finalized, therefore, the incremental HF testing costs are only included in years 2 and 3. 

Facilities are not subject to Hg limits until three years after the rule is finalized, therefore, the 

additional Hg testing costs are only included in year 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 640 hours. The average annual recordkeeping 

hours are 40 and the reporting requirement hours are 600, 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

There are no capital costs associated with the proposed Phosphoric Acid and Phosphate 

Fertilizer NESHAP 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 $43,500 $1,716,000 $572,000

The total capital/startup costs for this ICR are $43,500; column C. 

The total annualized capital/startup and O&M costs for this ICR are $1,716,000, or an 

average of $572,000 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 

$17,000.

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 

proposed emissions guidelines. 

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 57 19

The number of average annual responses is 19.

6(e) Bottom Line Burden Hours and Cost Tables

(i) The Respondent Tally 

The total annual labor hours are 1,930. Furthermore, the annual public reporting and 

recordkeeping burden for this collection of information is estimated to average 34 hours per 

response. The total annual labor costs are $159,000 or $53,000 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 $572,000. 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 326 hours at a cost of $17,000 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

There is no change in the labor hours or cost in this ICR as it is for the proposed 

Phosphoric Acid and Phosphate Fertilizer NESHAP and is considered new burden.

6(g) Burden Statement

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

is estimated to be 34 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-2002-0037 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

(J)

Total NonLabor Costs 

Per Year 

(B x C x E)

(K)

Total 

Number of 

Responses 

per Year

(C X E)

Footnotes

1. Applications NA

2. Surveys and Studies NA

3. Reporting Requirements

A. Read Rule 20 $0 1 20 23 460 46 23 $43,471 $0 0 a

B. Required Activities

1. Mercury testing 10 $6,400 1 10 0 0 0 0 $0 $0 0 b

2. Hydrogen fluoride testing c

a. Incremental 320 Cost 0 $8,000 1 0 0 0 0 0 $0 $0 0 c

b. Oxidation Reactors, 

Defluorination Units, & Clarifiers 10 $15,000 1 10 0 0 0 0 $0 $0 0 c

3. TF testing: Oxidation, Defluorination, 

& Clarifiers 10 $5,600 1 10 8 80 8 4 $7,560 $44,800 0 i

4. Performance evaluation 0 $2,000 1 0 23 0 0 0 $0 $46,000 0 d

C. Create Information Inc. in 3B

D. Gather Information Inc. in 3E

E. Report Preparation

1. Performance test report 10 $0 1 10 7 70 7 4 $6,615 $0 7 e

2. Develop monitoring plan 15 $0 1 15 23 345 35 17 $32,603 $0 23 f

3. Prepare gypsum stack management 

plan 20 $0 1 20 12 240 24 12 $22,681 $0 12 g

Reporting Subtotal 1195 120 60 $112,930 $90,800 42

4. Recordkeeping Requirements

A. Read Instructions Inc. in 3A

B. Implements Activities NA

C. Develop Record System NA

D. Record information

1. Records of Hg testing 3 $0 1 3 0 0 0 0 $0 $0 0

2. Records of HF/TF testing 3 $0 1 3 8 24 2 1 $2,268 $0 0

3. Records of Hg control device 10 $0 1 10 0 0 0 0 $0 $0 0 h

E. Personnel Training Inc. in 3B

F. Time for Audits NA

Recordkeeping Subtotal 24 2 1 $2,268 $0 0

TOTAL 1219 122 61 $115,198 $90,800 42

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 1,402 $115,198 $90,800 $205,998

Initial Capital and Startup $43,471

Annualized Capital/Start-up and O & M $134,271

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 fertilizer units.

(f) Includes development of CPMS performance evaluations/calibration for scrubbers. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.

(h) One facility will install a carbon adsorption system and must determine the carbon bed life; costs not applicable until year 3.

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid and Phosphate 

Fertilizers NESHAP - Year 1

(g) Includes preparation of gypsum stack and cooling pond management plan for the 12 phosphoric acid facilities. Assumed that each facility would already be employing one of the control measures, so additional 

costs to implement a control measure were not estimated.

(c) Facilities are not subject to annual HF testing the first year, costs are provided in years 2 and 3.

(e) Includes additional data submitted for Hg and HF tests, for emission points not currently tested. The facilities' emission points that currently conduct TF tests are not considered, as they must already report their 

data. No additional Hg and HF tests would be performed in year 1.

(i) There are 8 emission points (oxidation reactors, defluorination units, and clarifiers) that are currently not tested, but are applicable as noted in the subpart AA clarifications. These emissions points will conduct 

total fluoride tests in year 1, before transitioning to HF testing in years 2 and 3.
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

(J)

Total NonLabor Costs 

Per Year 

(B x C x E)

(K)

Total 

Number of 

Responses 

per Year

(C X E)

Footnotes

1. Applications NA

2. Surveys and Studies NA

3. Reporting Requirements

A. Read Rule 20 $0 1 20 0 0 0 0 $0 $0 0 a

B. Required Activities

1. Mercury testing 10 $6,400 1 10 0 0 0 0 $0 $0 0 b

2. Hydrogen fluoride testing c

a. Incremental 320 Cost 0 $8,000 1 0 78 0 0 0 $0 $624,000 0 c

b. Oxidation Reactors, 

Defluorination Units, & Clarifiers 10 $15,000 1 10 8 80 8 4 $7,560 $120,000 0 c

3. TF testing: Oxidation, Defluorination, 

& Clarifiers 10 $5,600 1 10 0 0 0 0 $0 $0 0 g

4. Performance evaluation 0 $2,000 1 0 23 0 0 0 $0 $46,000 0 d

C. Create Information Inc. in 3B

D. Gather Information Inc. in 3E

E. Report Preparation

1. Performance test report 10 $0 1 10 7 70 7 4 $6,615 $0 7 e

2. Develop monitoring plan 15 $0 1 15 0 0 0 0 $0 $0 0 a

3. Prepare gypsum stack management 

plan 20 $0 1 20 0 0 0 0 $0 $0 0 a

Reporting Subtotal 150 15 8 $14,175 $790,000 7

4. Recordkeeping Requirements

A. Read Instructions Inc. in 3A

B. Implements Activities NA

C. Develop Record System NA

D. Record information

1. Records of Hg testing 3 $0 1 3 0 0 0 0 $0 $0 0

2. Records of HF testing 3 $0 1 3 8 24 2 1 $2,268 $0 0

3. Records of Hg control device 10 $0 1 10 0 0 0 0 $0 $0 0 f

E. Personnel Training Inc. in 3B

F. Time for Audits NA

Recordkeeping Subtotal 24 2 1 $2,268 $0 0

TOTAL 174 17 9 $16,443 $790,000 7

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 200 $16,443 $790,000 $806,443

Initial Capital and Startup $0

Annualized Capital/Start-up and O & M $790,000

Footnotes:

(a) Only applicable to first year.

(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 fertilizer units.

(f) One facility will install a carbon adsorption system and must determine the carbon bed life; costs not applicable until year 3.

(g) Facilities will perform HF tests instead of TF tests from year 2 forward.

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid and Phosphate 

Fertilizers NESHAP - Year 2

(c) Must perform annual HF testing. For 78 emission points, the incremental cost for using Method 320 versus 13B are included ($8,000). There are 8 emission points (oxidation reactors, defluorination units, and 

clarifiers) that are currently not tested, but are applicable as noted in the subpart AA clarifications (they would incur the full Method 320 cost of $15,000).

(e) Includes additional data submitted for Hg and HF, for emission points not currently tested. The facilities' emission points that currently conduct TF tests are not considered, as they must already report their data. 

Only facilities that perform HF tests are included in year 2 costs.
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

(J)

Total NonLabor Costs 

Per Year 

(B x C x E)

(K)

Total 

Number of 

Responses 

per Year

(C X E)

Footnotes

1. Applications NA

2. Surveys and Studies NA

3. Reporting Requirements

A. Read Rule 20 $0 1 20 0 0 0 0 $0 $0 0 a

B. Required Activities

1. Mercury testing 10 $6,400 1 10 7 70 7 4 $6,615 $44,800 0 b

2. Hydrogen fluoride testing c

a. Incremental 320 Cost 0 $8,000 1 0 78 0 0 0 $0 $624,000 0 c

b. Oxidation Reactors, 

Defluorination Units, & Clarifiers 10 $15,000 1 10 8 80 8 4 $7,560 $120,000 0 c

3. TF testing: Oxidation, Defluorination, 

& Clarifiers 10 $5,600 1 10 0 0 0 0 $0 $0 0 g

4. Performance evaluation 0 $2,000 1 0 23 0 0 0 $0 $46,000 0 d

C. Create Information Inc. in 3B

D. Gather Information Inc. in 3E

E. Report Preparation

1. Performance test report 10 $0 1 10 8 80 8 4 $7,560 $0 8 e

2. Develop monitoring plan 15 $0 1 15 0 0 0 0 $0 $0 0 a

3. Prepare gypsum stack management 

plan 20 $0 1 20 0 0 0 0 $0 $0 0 a

Reporting Subtotal 230 23 12 $21,735 $834,800 8

4. Recordkeeping Requirements

A. Read Instructions Inc. in 3A

B. Implements Activities NA

C. Develop Record System NA

D. Record information

1. Records of Hg testing 3 $0 1 3 7 21 2 1 $1,985 $0 0

2. Records of HF testing 3 $0 1 3 8 24 2 1 $2,268 $0 0

3. Records of Hg control device 10 $0 1 10 1 10 1 1 $945 $0 0 f

E. Personnel Training Inc. in 3B

F. Time for Audits NA

Recordkeeping Subtotal 55 6 3 $5,198 $0 0

TOTAL 285 29 14 $26,933 $834,800 8

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 328 $26,933 $834,800 $861,733

Initial Capital and Startup $0

Annualized Capital/Start-up and O & M $834,800

Footnotes:

(a) Only applicable to first year.

(b) Must perform annual Hg testing, plus semi-annual testing on one representative carbon adsorber system (there are six phosphate rock calciners).

(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.

(f) One facility will install a carbon adsorption system and must determine the carbon bed life.

(g) Facilities will perform HF tests instead of TF tests from year 2 forward.

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid and Phosphate 

Fertilizers NESHAP - Year 3

(c) Must perform annual HF testing. For 78 emission points, the incremental cost for using Method 320 versus 13B are included ($8,000). There are 8 emission points (oxidation reactors, defluorination units, and 

clarifiers) that are currently not tested, but are applicable as noted in the subpart AA clarifications (they would incur the full Method 320 cost of $15,000).

(e) Includes additional data submitted for Hg and HF, for emission points not currently tested. The facilities' emission points that currently conduct TF tests are not considered, as they must already report their data.
Year

Technical 

Hours

Clerical 

Hours

Management 

Hours

Total 

Labor 

Hours Labor Costs

Non-Labor 

(Annualized 

Capital/Startup and 

O&M) Costs Total Costs

1 1,219 122 61 1,402 $115,198 $90,800 $205,998

2 174 17 9 200 $16,443 $790,000 $806,443

3 285 29 14 328 $26,933 $834,800 $861,733

Total 1,678 168 84 1,930 $158,574 $1,715,600 $1,874,174

Average 559 56 28 643 $52,858 $571,867 $624,725

Year

Number of 

Responses

Reporting 

Hours

Recordkeeping 

Hours

Total 

Hours

Hours per 

Response

1 42 1,374 28 1,402 33

2 7 173 28 200 29

3 8 265 63 328 41

Total 57 1,811 118 1,930 34

Average 19 604 39 643 34

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

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) (E) (F)

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)

Clerical 

Hours Per 

Year

(E = C x 0.1)

EPA Cost 

Per Year

1. Applications

2. Read and Understand Rule Requirements 10 20 200 10 20 $10,364 a

3. Required Activities

A. 2 16 32 2 3 $1,658 b

B. Excess emissions -- Enforcement Activities 1 24 24 1 2 $1,244 c

C. Create Information

D. Gather Information

E. Report Reviews

1. Review performance test report 7 5 35 2 4 $1,814 d

2. Review monitoring plan 23 10 230 12 23 $11,919

3. Review gypsum stack and cooling pond management 

plan

12 8 96 5 10 $4,975

F. Prepare annual summary report 1 10 10 1 1 $518 e

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $881 per trip $1,763

TOTAL 627 31 63 $34,255

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 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 additional information.

Observe stack tests

Footnotes

Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric 

Acid and Phosphate Fertilizers NESHAP - Year 1 

Burden Item

not applicable

not applicable

not applicable
(A) (B) (C) (D) (E) (F)

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)

Clerical 

Hours Per 

Year

(E = C x 0.1)

EPA Cost 

Per Year

1. Applications

2. Read and Understand Rule Requirements 0 20 0 0 0 $0 a

3. Required Activities

A. 2 16 32 2 3 $1,658 b

B. Excess emissions -- Enforcement Activities 1 24 24 1 2 $1,244 c

C. Create Information

D. Gather Information

E. Report Reviews

1. Review performance test report 7 5 35 2 4 $1,814 d

2. Review monitoring plan 0 7 0 0 0 $0

3. Review gypsum stack and cooling pond management 

plan

0 5 0 0 0 $0

F. Prepare annual summary report 1 10 10 1 1 $518 e

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $881 per trip $1,763

TOTAL 101 5 10 $6,997

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 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 additional information.

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric 

Acid and Phosphate Fertilizers NESHAP - Year 2 

Burden Item

Footnotes

not applicable

Observe stack tests

not applicable

not applicable
(A) (B) (C) (D) (E) (F)

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)

Clerical 

Hours Per 

Year

(E = C x 0.1)

EPA Cost 

Per Year

1. Applications

2. Read and Understand Rule Requirements 0 20 0 0 0 $0 a

3. Required Activities

A. 3 16 48 2 5 $2,487 b

B. Excess emissions -- Enforcement Activities 1 24 24 1 2 $1,244 c

C. Create Information

D. Gather Information

E. Report Reviews

1. Review performance test report 8 5 40 2 4 $2,073 d

2. Review monitoring plan 0 7 0 0 0 $0

3. Review gypsum stack and cooling pond management 

plan

0 5 0 0 0 $0

F. Prepare annual summary report 1 10 10 1 1 $518 e

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $881 per trip $2,644

TOTAL 122 6 12 $8,966

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 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 additional information.

Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric 

Acid and Phosphate Fertilizers NESHAP - Year 3

Burden Item

Footnotes

not applicable

Observe stack tests

not applicable

not applicable
Year

Technical 

Hours Management Hours Clerical Hours Total Hours Labor Costs

Non-Labor 

Costs Total Costs

1 627 31 63 721 $34,255 $0 $34,255

2 101 5 10 116 $6,997 $0 $6,997

3 122 6 12 140 $8,966 $0 $8,966

Total 850 43 85 978 $50,218 $0 $50,218

Average 283 14 28 326 $16,739 $0 $16,739

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

Reporting Requirements for the Phosphoric Acid and Phosphate Fertilizers NESHAP