SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal) 1. Identification of the Information Collection 1(a) Title of the Information Collection NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal) , EPA I CR Number 1078.09, OMB Number 2060

- 0111 1(b) Short Characterization/Abstract The New Source Performance Standards (NSPS) for Phosphate Rock Plants ( 40 CFR 60, subpart NN ) were proposed on September 21, 1979, and pr omulgated on April 16, 1982. These regulations apply

to the following new facilities at phosphate rock plants with capacities greater than 4 tons per hour: dryers, calciners, grinders, and ground rock handling and storage facilities, except those faciliti es producing or preparing phosphate rock solely for consumption in elemental phosphorus production. New facilities include those that commenced construction, modification or reconstruction after the date of proposal. This information is being collected t o assure compliance with 40 CFR part 60, subpart NN.
Ingeneral, all NSPS standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining complian ce, and are required of all sources subject to NSPS. Any owner or operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority . In the event that there is no such delegated authority , the reports are sent directly to the United States Environmental Protection Agency (EPA) regional office.
Bas ed on our consultations with industry representatives, there is an average of one affected facility

at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three years, an average of 13 facilities per year will be subject to the standard, and it is estimated that one additional source will become subject to the standard in the next three years. There are approximately

13 phosphate rock plants in the United States, which are all2

publ icly owned and operated by

the P hosphate R ock industry . None of the 13 plants in the United States are owned by either state, local, tribal, or the Federal government. They are all owned and operated solely by privately owned for

- profit businesses. The burden to the “Affected Public” may

be found below in Table 1: Annual Respondent Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal) . The burden to the Federal government is attributed entirely to work performed by

Feder al employees or government contractors; this burden may be found below in Table 2: Annual Agency Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal)

. The active (previous) I CR had the following Terms of Clearance (TOC): “As part of its submission, EPA should verify that the wage rates referenced in Sections 6(b) and 6(c) of the supporting statement have been updated to current values and properly loaded to include overhead, consistent with current EPA and OMB guideline s.” The EPA has addressed these terms of clearance for this I CR by using the most recent labor rates in Sections 6(b) and 6(c).
2. Need for and Use of the Collection 2(a) Need/Authority for the Collection The EPA is charged under section 111 of th e Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality

health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrate d technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years. Inaddition, section 114(a) states that the Administrator may require any

owner or operator subject to any

requirem ent 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 metho ds, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control3 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.
Inthe Administrator's judgment, particulate matter (PM) emissions from phosphate ro ck plants cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart NN. 2(b) Practical Utility/Users of the Data The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’s initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. Durin g the performance test, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and that the standard is being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance proc edures and for compliance determinations.
3. Non
- duplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 60, subpart NN. 3(a) Non
- duplication If the subject standards have n ot 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 . I f 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 duplication4

exists. 3(b) Public Notice Required Prior to ICR Submi ssion to OMB An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (75 FR 30812) on June 2, 2010. No comments were received on the burden published in the Federal Register

. 3(c) Consultations Th e Agency

has consulted industry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Air Facility Sy stem (AFS) which is operated and maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Approximately

13 respondents will be subject to the standard over the three year period covered by this I CR.
In dustry trade associations and other interested partie s were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously

reviewed to determine the minimum information needed for compliance purposes. Itis our policy

to respond after a thorough review of comments received since the last IC R renewal as well as those submitted in response to the f irst Federal Register notice. In this case, no comments were received. 3(d) Effects of Less Frequent Collection Less frequent inform ation collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applie d and emission limitations are met. I f 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 Gu idelines These reporting or recordkeeping requirements do not violate any of the regulations promulgated by

OMB under 5 CFR part 1320, section 1320.5. 3(f) Confidentiality Any information submitted to the Agency for which a claim of confidentiality is made5

will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI ) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). 3(g) Sensitive Questions The reporting or recordkeeping requirements in the standard do not include sensitive questions. 4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes The respondents to the recordkeeping and reporting requirements are phosphate rock plants. The United States Standard Industrial Classification (SI C) code for the respondents affected by

the standards is SI C code 1475, which corresponds to the No rth American Industry Classification Sy stem (NAI CS) code 212393 for phosphate rock plants.

40 CFR Part 60, Subpart NN SIC Codes NAICS Codes Phosphate Rock 1475 212393 4(b) Information Requested None of these reporting or recordkeeping requirements v iolate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. (i) Data Items
Inthis I CR, all the data that is recorded or reported is required by the NSPS for Phosphate Rock Plants (40 CFR part 60, subpart NN).
A source must make the following reports:
Notifications Notification of construction or reconstruction 60.7(a)(1) Notification of actual startup 60.7(a)(3) Notification of phy sical or operational change which may increase the emission rate 60.7(a)(4) Notification o f demonstration of continuous monitoring sy stem 60.7(a)(5) Notification of initial performance test 60.8(d) Report on initial performance test 60.8(a) Semiannual report on excess emissions 60.7(c) A source must keep the following records:6
Recordkeep ing Maintain records of startups, shutdowns, malfunctions, periods where the continuous monitoring sy stem is inoperative 60.7(b) Maintain all records for two years 60.7(f) Electronic Reporting Some of the respondents are using monitoring equipment th at automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

a gencies in cooperation with the respondents, continue to create reporting sy stems to transmit data electronically . However, electronic reporting sy stems are still not widely

used. At this time, it is estimated that approximately 10 percent of the respond ents use electronic reporting.

(ii) Respondent Activities

Respondent Activities Read instructions. In stall, calibrate, maintain, and operate continuous monitoring sy stem (CMS) for opacity , or for pressure drop and liquid supply pressure for wet scrubb er. Perform initial performance test, Reference Methods 5, and 9, and repeat performance tests if necessary
. Write the notification and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acqui ring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously

applicable instructions and requirements. Train personnel to be able to respond to a coll ection of information. Transmit, or otherwise disclose the information. Currently , sources are using monitoring equipment that provides parameter data in an automated way

(e.g., continuous parameter monitoring sy stem). Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping.7

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management 5(a) Agency Activities EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information. Agency Activities Review notifications and reports, including performance test reports, a nd excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, analy

ze, and maintain data in the Air Facility Sy stem (AFS). 5(b) Collection Methodology and Management Following notification of startup, the reviewin g authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency

to discern a source’s initial capability to comply with the emission standard and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the AFS which is operated and maintained by

the EPA Office of Compliance. AFS is the EPA database for the collection, mai ntenance, 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 h eadquarters. EPA and its delegated Authorities can edit, store, retrieve and analy ze the data. The records required by

this regulation must be retained by the owner/operator for two ye ars. 5(c) Small Entity Flexibility The majority

of the respondent s are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses,) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them fur ther for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.8

5(d) Collection Schedule The specific frequency

for each information collection activity within this re quest is shown in below Table 1: Annual Respondent Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal)

. 6. Estimating the Burden and Cost of the Collection Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reductio n Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. 6(a) Estimating Respondent Burden The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 1,602 labor hours. The re cordkeeping hours shown below in Table 1 are 1,338. The reporting requirement hours shown below in Table 1 are 264. These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience w ith the NSPS program, the previously approved I CR, and any

comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the following labor rates: Managerial $116.05 ($55.26 + 110%) Technical $97.21 ($46.29 + 110% ) Clerical $48.87 ($23.27 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2010, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry

. (ii) Estimating Capital/Startup and Operation and Maintenance Costs The ty pe of industry

costs associated with the informatio n collection activities in the subject standard is both labor costs, which are addressed elsewhere in this I CR, and the costs9

associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation and Maintenan ce (O&M) Costs (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/ Startup Cost, (B × C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E × F) Continuous Opacity Monitor $37,000 0.33 $12,210 $8,400 13.33 $111,972
The total capital/startup costs for this I CR are $12,210. Th is is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $111,972. This is the total of column G. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with analy sis of the reported information. The EPA 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 I CR is estimated to be $6,298. This cost is based on the average hourly labor rate as follows: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) Technical $46.2 1 (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), 2010 General Schedule, which excludes locality

rates of pay . The rates have been increased by 60 percent to acco unt for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Annual Agency Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal)

. 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our research for this I CR, on average over the next three years, approximately 13 existing respondents will be subject to the standard. It is estimated that an additional one10

respondents per year w ill become subject. The overall average number of respondents, as shown in the table below, is 13 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered by

this I CR. Number of Respondents Respondents That Submit Reports Respondents That Do Not Submit Any Reports Year (A) Number of New Respondents a (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D)

Number of Existing Respo ndents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)
1 0.33 13 0 0 13.33 2 0.33 13 0 0 13.33 3 0.33 13 0 0 13.33 Average 0.33 13 0 0 13.33 Assumptions:
a New respondents include sources with constructed, reconstructed and modifi ed affected facilities. In this standard, existing respondents submit initial notifications. Column D is subtracted to avoid double

- counting respondents. As shown above, the average Number of Respondents over the three

- ye ar period of this I CR is 13.33 or 13, when rounded. The total number of annual responses per year is calculated using the following table: Total Annual Responses (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Responses E=(B×C)+D

Notification of construction or mo dification 0.33 1 N/A 0.33 Notification of actual startup 0.33 1 N/A 0.33 Notification of physical or operational change which may incre ase the emission rate 0.33 1 N/A 0.33

Notification of demonstration of CMS 0.33 1 N/A 0.33 Notification of initial performance tests 0.33 1 N/A 0.33 Report of initial performance test 0.33 1 N/A 0.33 Semiannual report on excess emissions 13.33 2 N/A 26 .66 TOTAL (rounded) 29 N/A

– Not Applicable The total Number of Respondents is 13.11

The number of Total Annual Responses is 29. This is the number in column E of the Respondent Universe and Number of Responses per year in table above. The total annual labor costs are $150,354. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal)

. 6(e) Bottom Line Burden Hours and Cost Tables The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 (below), respectively , and summarized below. (i) Respondent Tally The total annual labor hours are 1,602 labor hours. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) ( Renewal ). Furthermore, the annual public reporting and recordkeeping burden for this collection of inf ormation is estimated to average 55 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $124,182. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Cos ts. (ii) The Agency Tally The average annual Agency burden and cost over next three years is estimated to be 140 labor hours at a cost of $6,298. See below Table 2 : Annual Agency Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) ( Renewal ). 6(f) Reasons for Change in Burden There is no change in the labor hours, or in the capital/startup and operation and maintenance costs in this I CR compared to the previous I CR. This is due to two considerations: 1) the regulations have not changed over the past three years and are not anticipated to change over the next three years; and 2) the growth rate for the industry is very low, negative, or non

existent. The increase in labor cost to Respondents and the Agency is due to labor r ate adjustments to reflect the most recent available estimates. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 55 hours per response. Burden means the total time, effort, or financial12

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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s 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 r equired to respond to, a collection of information unless it display s a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency 's need for this information, the ac curacy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket I D Number EPA

- HQ

- OECA

- 2010

- 0362. An el ectronic 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 acce ss those documents in the public docket that are available electronically . When in the sy stem, select “search,” then key in the docket I D number identified in this document. The documents are also available for public viewing at the Enforcement and Compl iance 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 h oliday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center is (202) 566

- 1752. Also, you can send comments to the Office of In formation 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

- OECA

- 2010

- 0362 and OMB Control Number 2060

- 0111 in any correspondence. Part B of the Supporting Statement This part is not applicab le because no statistical methods were used in collecting this information.13

Table 1. Annual Respondent Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal)

Reporting/Recordkeeping Requirements Person

hours per occurre nce No. of

occurrences per respondent per year Person

hours per respondent per year (C = A×B) Respondents

per year a Technical

person hours per year (E = C×D) Management

person - hours per year (E×0.05) Clerical

person hours per year (E×0.1) Total

Hours/ Year (H = E + F + G) Cost b ($)

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirem ents A. Read instructions 1 1 1.00 0.3 0.33 0.02 0.03 0.38 $35.61 B. Required activities Initial emissions tests 32 1 32.00 0.3 10.56 0.53 1 .06 12.14 $1,139.42 Report performance test c 32 1 32.00 0.1 2.24 0.11 0.22 2.58 $241.69 C. Create Information See 3B D. Gather existing information See 3B E. Write report Notification of construction/ reconstruction 2 1 2.00 0.3 0.66 0.03 0.0 7 0.76 $71.21 Notification of actual startup 2 1 2.00 0.3 0.66 0.03 0.07 0.76 $71.21 Notification of physical or operational change which may increase the emission rate d 2 1 2.00 0 0.00 0.00 0.00 0.00 $0.00

Notification of CMS demonstration e 2 1 2.00 0.3 0.66 0.03 0.07 0.76 $71.21 Notification of initial performance test 2 1 2.00 0.3 0.66 0.03 0.07 0.76 $71.21 Report of initial performance test 2 1 2.00 0.3 0.66 0.03 0.07 0.76 $71.21 Semiannual report on excess emissions f 8 2 16.00 13.3 213.28 10. 66 21.33 245.27 $23,012.81 Reporting Subtotal 264 $24,786 4. Recordkeeping requirem ents A. Read instructions See 3E B. Plan activities See 3E C. Implement activities See 3E D. Develop record system See 3E E. Time to enter informatio n Record operating parameters g 0.3 350 87.50 13.3 1,163.75 58.19 116.38 1,338.31 $125,568.04 F. Time to transmit or disclose information N/A14

Reporting/Recordkeeping Requirements Person

hours per occurre nce No. of

occurrences per respondent per year Person

hours per respondent per year (C = A×B) Respondents

per year a Technical

person hours per year (E = C×D) Management

person - hours per year (E×0.05) Clerical

person hours per year (E×0.1) Total

Hours/ Year (H = E + F + G) Cost b ($)

G. Train personnel N/A H. Audits N/A Recordkeeping Subtotal 1,338 $125,568 TOTAL ANNUAL BURDEN AND COST 1,602 $150,354 N/A

– Not Applicable. Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 13.33. It is estimated that one new source will become subject to the rule over the three

- year period of this ICR. b This ICR uses the following labor rates: $116.05 per hour for Executive, Administrative, and Managerial labor; $97.21 per hour for Technical labor, and $48.87 per hour for Clerical labor. These rates are from th e United States Department of Labor, Bureau of Labor Statistics, December 2003, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 p ercent to account fo r the benefit packages available to those employed by private industry.
c We have assumed that 20 percent of initial performance test will be repeated due to failure. d We have assumed that no facility will be engaged in physical or operational changes.
e We have assumed that it will take each respondent 2 hours each to write CMS notification report. f We have assumed that each respondent will take 8 hours, two times per year, to write semiannual report on excess emissions. g We have assumed that each respondent w ill take 15 minutes per day to record operating parameters information.15

Table 2. Annual Agency Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal) (A) (B) (C) (D) (E) (F) (G) (H) (I) Activity EPA person hours per occurrence No. of

occurrences per plant per year EPA

person hours per plant per year (C = A×B) Plants per

year a Technical

person hours per year (E = C×D) Management

person - hours per year (E×0.05) Clerical

person hours per year (E×0.1) Tota l

Hours/ Year (H = E + F + G) Cost b ($)

Initial performance tests New or modified facility 24 1 24.00 0.33 7.92 0.40 0.79 9.11 $410.45 Repeat performance test New or modified facility c 24 1 24.00 0.07 1.68 0.08 0.17 1.93 $87.07 Report Review New or mo dified facility Notification of construction/reconstruction 2 1 2.00 0.33 0.66 0.03 0.07 0.76 $34.20 Notification of actual startup 2 1 2.00 0.33 0.66 0.03 0.07 0.76 $34.20 Notification of physical or operational change which may increase the emi ssion rate d 2 1 2.00 0 0.00 0.00 0.00 0.00 $0.00

Notification of CEMS demonstration e 2 1 2.00 0.33 0.66 0.03 0.07 0.76 $34.20 Notification of initial performance test 2 1 2.00 0.33 0.66 0.03 0.07 0.76 $34.20 Report on initial performance test 8 1 8 .00 0.33 2.64 0.13 0.26 3.04 $136.82 Semiannual report on excess emissions f 4 2 8.00 13.33 106.64 5.33 10.66 122.64 $5,526.56 Report Review Subtotal 129 $5,800 TOTAL ANNUAL BURDEN 140 $6,298 Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 13.33. It is estimated that one new sour ce w ill become subject to the rule over the three

- year period of this ICR. b The cost is based on the follow ing labor rate w hich i ncorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $62.27 (GS

- 13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS

- 12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS

- 6, Step 3, $15. 63 x 1.6). These rates are from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality rates of pay.
c We have assumed that 20 percent of initial performance test will be repeated due to failure. d We have assumed that no facility will be engaged in physical or operational changes.
e We have assumed that it will take each respondent 2 hours each to review CMS notification report. f We have assumed that each respondent will take 8 hours two times per year to review semi annual report on excess emissions.