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, s ubpart 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 Fe rtilizer Production , 40 CFR part 63

, subpart s 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, 4 0 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, subpart s AA and BB (6 4 FR 31358

, June 10, 1999 ). On June 13, 2002 EPA amended subpart AA to revise PM emissions limits for existing ph osphate 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 res idual risk review for the NESHAP and technology review s for both the NESHAP and NSPS , EPA issued proposed rule s in 201 4

. This information collection request documents the additional recordkeeping and reporting requirements and burden imposed by the propose d rule s

. 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, recordkeepin g, 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 a re 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 Fertiliz er 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 $ 1,8 74 ,000

. The burden t o 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 H AP 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 m anner 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 1 14(a)(3); and (G) provide such other information as the Administrator may reasonably require.

In the Administrator's judgment, HAP emissions from phosphoric acid manufacturingand phosphate fertilizer production facilities cause or contribute to air pollution that may reasonably be anticipated to enda nger 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/U sers 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 a nd Phosphate Fertilizer NESHAP being complied with; and (4 ) ensure, on a continuous basis, that the operating parameters established during performance test s are not exceeded.

In addition, records and reports are necessary to enable the Designated Adminis trator to identify p hosphoric a cid manufacturing and p hosphate f ertilizer 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 proc esses 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 6 3

, subparts AA and BB

.

3 ( a ) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the
ap propriate EPA regional office. Otherwise, the information is sent directly to the de legated state or local agency. If a state or local agency has adopted its own similar standards to implement t he 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 requ ired 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 ) Cons ultations

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 proposedrulemaking. In addition, i ndustry representatives including The Fertilize r 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
test ing

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

c ompliance s tatus , and summary r eports

. The frequency of these activities was chose n 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 con trol devices are operating properly. This information assures EPA and the public that the reductions envisioned by the r egulations 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 facilit ies 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 ne w 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) Code s 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 A ctivities

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, a nd 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 parame ter requirements. This includes discussion of CPM S and CEMS requirements, if applicable. The monitoring plan also includes procedures for performance evaluations which must be performed annually , at a minimum

. Phosphoric acid f acilities must prepare a g ypsum dewatering stack and cooling pond management plan which provides additional details on their active gypsum dewatering stack s and ponds . As part of this plan, phosphoric acid facilities must provide documentation which shows at least one of the fugiti ve emission control measures is already in place or will beimplemented for their existing gypsum dewatering stack s or cooling ponds

. Phosphoric acid manufacturing and phosphate fertilizer production facilities must comply with hydrogen fluoride ( HF ) emis sion 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 mon itor 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 perf ormance 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 sec tion 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 compli ance 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 c ontained 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 industri al 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 an alyze 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; h owever, there are provisions that reduce the impact on all regulated entities, which wou ld 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 a n i nitial

n otification

. W e also anticipate the one

- time and annual activities, including performance tests ( Hg and HF), development of a monitoring plan with performance evaluations, deve lopment of a gypsum dewatering stack and cooling pond management plan, and the notification of compliance
status (including performance test s results and operating parameter values) will occur for faciliti es 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, ther efore, 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 report ing 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 unde r the Paperwork Reduction Act. Where a ppropriate, specific tasks and major ass umptions 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 a gency 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 informa tion 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 201 3

, “ 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 re 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 beco mes 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 cos ts 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 P roduction F acilities 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 a gency 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 a gency cost during the three years of the ICR is estimated to be $ 1 7
, 0 00

. 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%) Cle rical $25.01 (GS

- 6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 201 3 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 refer red to as the respondent universe. Based on research, 13 existing facilities wi ll be subject to the standard. No new re spondents will become subject. Industry burden is calculated based on the number of facilities in each subcategory and the anticipated co ntrols 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 P roduction F acilities 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 theseestimates 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 Desi gnated Administrator Tally

The average annual burden over the first three years for the Designated Administrator would be 326 hours at a cost of $ 1 7 ,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 o r 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 mainta ining 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; complet e 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 vali d OMB contro l number. The OMB Control N umbers for EPA regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the a gency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing responde nt 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 s ystem , select “search,” then key in the docket ID numbe r 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 telephonenum ber for the do cket 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, At tention: Desk Officer for EPA. Please include the EP A Docket ID Number EPA

- HQ

- OAR

- 2002

- 0 037 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 Recordkeepin g and Reporting Requirements for the Phosphoric Acid and Phosphate Fertilizer NESHAPBurden 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 NESHAPATTACHMENT 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 Reporti ng 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 Footnotes

Burden Item 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 Footnotes

Burden Item not applicable

Observe stack tests

not applicable not applicableYear 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