**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for**  **Sulfuric Acid Plants (40 CFR Part**  **60 , Subpart**  **H ) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NSPS for Sulfuric Acid Plants (40 CFR Part 60 , Subpart H ) (Renewal), EPA I CR Number 1057.13 , OMB Control Number 2060

- 0041

. **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Sulfuric Acid Plants were : propo sed on August 17, 1971 ; promulgated on December 23, 1971 ; and amended on: June 14, 1974 (39 FR 20794); October 6, 1975 (40 FR 46258); July 25, 1977 (42 FR 37936); May 25, 1983 (48 FR 23611); September 29, 1983 (48 FR 4700); October 20, 1983 (48 FR 48669); February 14, 1989 (54 FR 6666); October 17, 2000 (65 FR 61753); January 9, 2012 (77 FR 1130); and February 27, 2014 (79 FR 11250) . These regulations apply to existing facilities and new facilities

. New facilities include those that commenced con struction, modification or reconstruction after the date of proposal. A sulfuric acid plant is any facility producing sulfuric acid (H 2 SO 4 ) by the contact process b y burning elemental sulfur, alkyl ation acid, h ydrogen sulfide, organic sulfides and mercapt ans, or acid sludge. A sulfuric acid plant does not include facilities where conversion to sulfuric acid is used primarily as a means of preventing emissions to the atmosphere of sulfur dioxide (SO 2 ) or other sulfur compounds. This information is being c ollected to assure compliance with 40 CFR Part 60, Subpart H

. In general, all NSPS standards require initial notification report s, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maint ain 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 compliance, and are required of all affected facilities subject to NSPS

. Any owner/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 me asurements, 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 53 respondents per ye ar will be subject to the standard s , and it is estimated that no additional respondents per ye ar will become subject to the standard s
. The Office of Management and Budget (OMB) approved the currentl y active I CR without any

Terms of Clearance.2

There are approximately

53 sulfuric acid plants in the United States, which are owned and operated b y the S ulfuric A cid industry (the “Affected Public”). None of the facilities in the Unit ed States are owned by either state, local, tribal or the Federal government; all are privatel yowned , for

- profit businesses. The “burden ” to the Affected Public may be found below in Table 1 : Annual Respondent Burden and Cost

– NSPS for Sulfuric Acid Pl ants (40 CFR Part 60 , Subpart H ) (Renewal)

. T he Federal Government “ burden ” is attributed entirely to work performed b y either F ederal employees or government contractor s and may be found below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Sul furic Acid Plants (40 CFR Part 60 , Subpart H ) (Renewal).
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 111 of the 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 determine s has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four ye ars. In addition, 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 equip ment, 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 Admin istrator may reasonabl y require. In the Administrator's judgment, SO 2 emissions from sulfuric acid plants cause or3

contribute to air pollution that may reasonably

be anticipated to endanger either public health and/ or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart H

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which w ere 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 s . Continuous emission monitors are used to ensure compliance with the standard s at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in pla ce of a continuous emission monitor

. The notifications required in the se standard s 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 properl y installed and operated , leaks are being detected and repaired , and that the standard are being met. The performance test may also be observed. The required semiannual reports are used to determin e periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping an d reporting are r equired under 40 CFR Part 60, Subpart H

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y 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, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 79 FR 30117 ) on May 27, 2014 . No comments were received on the burden published in the Fede ral Register

.4

**3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, mainten ance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this I CR, we contacted Chemtrade Logistics , at (416) 496

- 5856, and Souther n States Chemical , at (910) 762

- 5054. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were recei ved. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniq ues 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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 made 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 3 6902, 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**
T he reporting or recordkeeping requirements in the standard do not include sensitive5

questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are sulfuric acid plants

. The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards is SI C 2819 , which corresponds to the North American Industry Classification Sy stem (NA IC S ) code 325188 for Inorganic Chemical Manufacturing

. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal)

. A source must make the following reports:

**Notification s**  Notification of construction/reconstruction 60.7(a)(1) Notification of actual startup 60.7(a)(3) Notification of ph ys ical or operational change 60.7(a)(4) Notification of continuous monitoring sy stem (CMS) demonstration 60.7(a)(5) Initial performance test results 60.8(a) Initial performance test 60.8(d) Reference Test Method 9 60.11(b)
**Reports** Semiannual report of excess emissions 60.7(c) A source must keep the following records: **Recordkeeping** Maintain records of startup, shutdown, or malfunction period where the continuous monitoring s ys tem is inoperative 60.7(b) Maintain records for two years 60.7(f)6 **Recordkeeping** Maintain annual performance test, as required 60.7(f) Electronic Reporting Some of the respondents are using monitoring equipment that 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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 2 0 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Perform initial performance test, Reference Method 9 test, and repeat performance tests if necessary
. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, 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 in formation. Adjust the existing way s to comply with an y previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.7

Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. **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, analysis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s init ial capability to compl y with the emission standard. 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 OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retriev al of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for two ye ars. **5(c) Small Entity Flexibility**8

The majority

of the respondents 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 further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

for each information coll ection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

– NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (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 Reduction 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 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 requirement s is estimated to be 13,409 hours ( Total Labor Hours from Table 1). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NSPS program, the previously

approved ICR, and any comments received.

**6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 8

. 0 2 ($ 60.98 + 110%) Technical $ 10 1

. 05 ($4 8

. 12 + 110%)9 Clerical $ 5 1

. 37 ($2 4

. 46 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 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 information collection activities in the subject standard(s) are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject t o 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 Maintenance (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 X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O &M (G)

Total O&M, (E X F)

CMS $120,000 0 $0 $4,500 53 $238,500 Total $0 $238,500 The total capital/startup costs for this I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR are $ 238,500

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry

over the next three years of the IC R is estimated to be $ 238,500

. These are recordkeeping costs

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.10

The average annual Agency cost during the three years of the ICR is estimated to be $ 22,192

. This cos t is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (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 ye ars, approximately 53 existing respondents will be subject to the standard. It is estimated that n o additional respondents per ye ar will become subject. The overall average number of re spondents, as shown in the table below, is 53 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 53 0 0 53
2 0 53 0 0 53 3 0 53 0 0 53 Average 0 53 0 0 53 1 New respondents include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the11

average Number of Respondents over the three ye ar period of this ICR is 53

. The total number of annual responses per ye ar 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=(BxC)+D Notification of construction or mo dification 0 1 N/A 0 Notification of actual startup 0 1 N/A 0 Notification of physical or operational change 0 1 N/A 0 Notification of demonstration of CMS 0 1 N/A 0 Notification of initial performance test 0 1 N/A 0 Semiannual report of excess emissions 53 2 N/A 106 Total 106 The number of Total Annual Responses is 106

. The total annual labor costs are $1,312,776

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (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 , respect ively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 13,409 hours

. Details regarding these estimates may be found in Table 1 : Annual Respondent Burden and Cost

– NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of12

information is estimated to average 12 7 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $238,500

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 488 labor hours at a cost of $22,192 . See below Table 2: Average Annual EPA Burden and Cost

– NSPS for Sulfuric Acid Plants (40 CFR Part 63, Subpart H) (Renewal). **6(f) Reasons for Change in Burden** The re is an increase in respondent burden in this ICR as compared to the previous I CR. This is not due to any

program changes ; rather, it is due to the correction of a mathematical error. We assume that 0.25 hours per occurrence over 350 occurrences per year is required to enter records of operating parameters

. The previous I CR calculated 8 hours per respondent for this burden item (instead of 87.5 hours per respondent) , which grossly underestimated recordkeeping burden. This correction changes the total respondent burden from 8,594 hours to 13,409 hours and the estimated burden cost from $ 822,650 to $1,312,776. There is also an increase in the estimated Agency

costs due to the use of more updated labor rates. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 127 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instruction s; 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 compl y 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 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 accuracy 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 IC R under Docket ID Number EPA

- HQ

- OECA

- 201 4

- 0035 . An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft13

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 sy stem , select “search,” then key in the docket ID number identifie d 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 holiday s. The telephone number for the Reading Room is (202) 566

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

- 1927

. 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

- 20 1 4

- 0035 and OMB Control Number 2060

- 0041 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.14

**Table 1: Annual Respondent Burden and Cost**

**– N**  **SPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H ) (Renewal)** 

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions c 1 1 1 0 0 0 0 $0 B. Required activities Initial performance tests d 300 1 300 0 0 0 0 $0 Reference Method 9 test e 4 1 4 0 0 0 0 $0 Repeat of performance tests f 300 1 300 0 0 0 0 $0 C. Create information See 3B D. Gather existing information See 3B E. Write Report Application of construction or modification 2 1 2 0 0 0 0 $0 Notification of actual startup 2 1 2 0 0 0 0 $0 Notification of physical or operational change 2 1 2 0 0 0 0 $0 Notification of demonstration of CMS 2 1 2 0 0 0 0 $0 Notification of initial performance test 2 1 2 0 0 0 0 $0 Semiannual report of excess emissions g 40 2 80 53 4,240 212 424 $477,373.12 **Subtotal for Reporting Requirements 4,876**  **$477,373** 4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities See 3A C. Implement Activities See 3A D. Develop record system N/A E. Time to enter information Records of operating parameters h 0.25 350 87.5 53 4637.5 231.88 463.75 $522,126.85 Record of conversion factors/calculation i 0.05 1,050 52.5 53 2,782.5 139.13 278.25 $313,276.11 F. Time to train personnel N/A G. Time for audits N/A15

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

**Subtotal for Recordkeeping Requirements 8,533**  **$835,403 TOTAL LABOR BURDEN AND COST (rounded)**  **13,409 $1,312,776**  **Assu mptions:**  a We have assumed that there are approximately 53 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. b This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, Table 2. Civilian Workers, by Occupational and Industry groups. 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. c We have assumed that it will take one hour for each respon dent to read instructions. d We have assumed that it will take 300 hours for each respondent to complete an initial performance test. e We have assumed that it will take four hours for each respondent to complete a reference Method 9 test. f We have ass umed that it will take 300 hours to repeat performance test due to failures. g We have assumed that it will take 40 hours, twice a year, for each respondent to w rite an excess emission report. h We have assumed that each respondent will enter information on records of operating parameters 350 times per year. i We have assumed that all information is entered on a weekly basis. j We have assumed that records of conversion factors will be recorded three times daily, at 350 days per year, for a total of 3 x350=1,050 times per year.16

**Table 2: Average Annual EPA Burden and Cost**

**– N**  **SPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H ) (Renewal)** 

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrence**  **s per plant per year**  **(C)**

**EPA person**  **** **hours per**  **plant per year**  **(C=AxB) (D)** 

**Plants per**  **year a**  **(E) Technical**  **person**   ** hours per** **year (E=CxD)**  **(F)**

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

New facility Initial performance test c 50 1 50 0 0 0 0 $0 Repeat performance test/observed d 24 1 24 0 0 0 0 $0 Revie w reports Notification of construction 2 1 2 0 0 0 0 $0 Notification of actual startup 0.5 1 0.5 0 0 0 0 $0 Notification of initial test 0.5 1.2 0.6 0 0 0 0 $0 Review test results 8 1.2 9.6 0 0 0 0 $0 Notification of CMS demonstration 0.5 1 0.5 0 0 0 0 $0 Existing facility 0.5 1 0.5 0 0 0 0 $0 Excess emission reports e 4 2 8 53 424 21.2 42.4 $ 22 , 192.16 **TOTAL ANNUAL BURDEN AND COST (rounded) 488**  **$2 2,192** 
**Assu mptions:**  a We have assumed that there are approximately 53 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. b This ICR uses the following rates: $62.90 for Managerial (GS

- 13, Step 5, $39.31 + 60%), $46.67 for Technical (GS

- 12, Step 1, $29.17 + 60%) and $25.25 Clerical (GS

- 6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM) 2014 Gen eral Schedule which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed that it will take fifty hours for each respondent to perform the initial performance test. d We have assumed that it will take twenty

- four hours for each respondent to repeat the performance test due to failure.
e We have assumed that it wi ll take four hours, twice per year, for each respondent to review the excess emission reports.