SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Nitric Acid Plants for which Construction, Reconstruction or Modification 

Commenced after October 14, 2011 (40 CFR Part 60, Subpart Ga) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Nitric Acid Plants for which Construction, Reconstruction or Modification 

Commenced after October 14, 2011 (40 CFR Part 60, Subpart Ga) (Renewal), 

EPA ICR Number 2445.03, OMB Control Number 2060-0674.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Nitric Acid Plants for which 

Construction, Reconstruction or Modification Commenced after October 14, 2011 (40 CFR Part 

60, Subpart Ga) were proposed on October 14, 2011, and promulgated on August 14, 2012. 

These regulations apply to new nitric acid production units (NAPUs) that produce weak nitric 

acid by either the pressure or atmospheric pressure process. Nitrogen oxide (NOX) is the 

pollutant regulated under this subpart. These standards limit nitrogen oxides, expressed as 

nitrogen dioxide (NO2), to 0.50 lb per ton of 100 percent nitric acid produced. This information 

is being collected to assure compliance with 40 CFR Part 60, Subpart Ga.

In general, all NSPS standards require initial notification reports, 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 system 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 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 U.S.

Environmental Protection Agency (EPA) regional office.

Potential respondents are owners or operators of nitric acid production units constructed, 

modified, or reconstructed after October 14, 2011. The “burden” to the “Affected Public” may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Nitric Acid Plants for 

which Construction, Reconstruction or Modification Commenced after October 14, 2011 (40 

CFR Part 60, Subpart Ga) (Renewal). The “burden” to the Federal Government is attributed 

entirely to work performed by either Federal employees or government contractors and can be 

found below in Table 2: Average Annual EPA Burden and Cost – NSPS for Nitric Acid Plants 

for which Construction, Reconstruction or Modification Commenced after October 14, 2011 (40 

CFR Part 60, Subpart Ga) (Renewal). 
2

During rule development, we estimated that 5 newly-constructed nitric acid production 

units and 1 modified unit will become subject to the regulation in the five-year period after the 

rule effective date (1.2 new sources per year). Over the next three years, we estimate that 6 units

per year will be subject to these standards, and 1.2 additional units per year will become subject 

to these standards. Plants can have more than one nitric acid production unit onsite.

The Office of Management and Budget OMB approved the currently-active Information 

Collection Requirements (ICR) without any “Terms of Clearance”.

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 system 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 demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years.

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 equipment, and use 

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, NOX emissions from nitric acid plants cause or 
3

contribute to air pollution that may reasonably be anticipated to endanger public health or 

welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60,

Subpart Ga.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards ensure compliance with 

the applicable regulations which were 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. For our analysis of these standards, we assume 

sources will rely on the reduction of NOX by using Selective Catalytic Reduction (SCR).

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, leaks are being detected and repaired, and the standards are being met. 

The performance test may also be observed.

The required noncompliance and malfunction reports are used to determine 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

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

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 ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. One comment was received on the 

burden published in the Federal Register, and it is addressed in section 3(c) below.

3(c) Consultations
4

The 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 Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s 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. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with these standards as they were being developed and these

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted both The Fertilizer Institute (TFI), 

at (202) 515-2701, and the American Chemistry Council, at (202) 249-7000. The EPA did not 

receive any comments from the consultations.

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. The EPA 

received one comment in response to the first Federal Register notice, but the comment did not 

contain any substantive recommendations and did not result in changes to this ICR. 

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 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 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 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 
5

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are nitric acid plants. 

The United States Standard Industrial Classification (SIC) code for the respondents affected by 

the standards is SIC 2873, Nitrogenous Fertilizers, which corresponds to the North American 

Industry Classification System (NAICS) code 325311 for Nitrogenous Fertilizer Manufacturing. 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Nitric 

Acid Plants for which Construction, Reconstruction or Modification Commenced after October 

14, 2011 (40 CFR Part 60, Subpart Ga).

A source must make the following reports:

Notifications

Notification of construction or modification application 60.6(a)

Notification of construction/reconstruction 60.7(a)(1)

Initial notifications 60.7(a)(3)

Notification of actual startup. 60.7(a)(3)

Physical or operational change. 60.7(a)(4)

Notification of demonstration of continuous monitoring system 60.7(a)(5)

Reports

Initial and subsequent performance test results. 60.8(a), 60.77a(a)

Compliance status. 60.7(a)(7)

A report of noncompliance, including the time period, NOX emission 

rates, reasons for noncompliance with the emission standard and a 

description of corrective actions taken.

60.77a(b)

A report summarizing times when the pollutant concentration or 

volumetric flow rate exceeds the high value of the monitoring 

60.77a(c)
6

Reports

equipment.

Report of any modifications to CERMS which could affect the ability of 

the CERMS to comply with applicable performance specifications.

60.77a(d)

Initial performance test. 60.8(d), 60.73a(e)

Compliance status. 60.7(a)(7)

A source must keep the following records:

Recordkeeping

For the NOX emissions rate, results of the performance evaluations of 

the CEMs.

60.76a(a)

Daily production rate of nitric acid. 60.76a(b)(2)

30 operating day average NOX emissions rate values 60.76a(b)(3)

Times of noncompliance with the emissions standards and when 

pollutant concentrations or flow rates exceed the full span of the 

monitoring equipment.

60.76a(c)

Reasons for periods of noncompliance and description of corrective 

actions taken.

60.76a(d)

Records of modifications to CEMS which could affect the ability of 

the CEMS to comply with performance specifications.

60.76a(e)

The occurrence and duration of malfunctions of operation or of the

pollution control and monitoring equipment. Description of actions 

taken to minimize emissions during periods of malfunction and 

correction actions to restore normal operation.

60.76a(f)

Records are required to be retained for two (2) years. 60.7(f)

Records of ongoing monitoring. 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 recordkeeping at 

a plant site. 
7

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements. 

Install, calibrate, maintain, and operate Continuous Emissions Rate Monitoring Systems 

(CERMS), which include NOX concentration and gas flow rate monitors

Write the notifications and reports listed above.

Enter information required to be recorded above.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Train personnel on CERMS operation and maintenance.

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.

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO. 

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 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. Data and records maintained by the respondents are tabulated and published 
8

for use in compliance and enforcement programs. The reports of noncompliance are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two

years.

5(c) Small Entity Flexibility

Most, if not all, of the anticipated new sources will be large entities (e.g., large 

businesses). However, the impact on potential small entities (i.e., small business) was taken into 

consideration during the development of the regulation. Due to technical considerations 

involving the process operation and the types of control equipment employed, the recordkeeping 

and reporting requirements are the same for both small and large entities. The agency considers 

these requirements the minimum needed to ensure compliance and, therefore, cannot reduce 

them further for small entities. To the extent that larger business 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 collection activity within this request is 

shown below in Table 1: Annual Respondent Burden and Cost – NSPS for Nitric Acid Plants for 

which Construction, Reconstruction or Modification Commenced after October 14, 2011 (40 

CFR Part 60, Subpart Ga) (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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

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 1,370 (Total Labor Hours from Table 1). 

These hours are based on Agency studies and background documents from the development of 
9

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 ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “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 type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

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 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)

NOX CERMS and 

flow meter $136,174 1.2 $163,409 $9,787 6 $58,720

Initial CERMS 

testing $15,019 1.2 $18,023

Initial flow meter 

testing $6,229 1.2 $7,475

File cabinet 1$43 6 $258

TOTAL

(Rounded) $189,000 $59,000

1

Included as O&M because the cost is annualized using a 7 percent interest rate and a 15-year life (i.e., CRF of 0.1098). 

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 
10

The total capital/startup costs for this ICR are $189,000. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $59,000. 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 ICR is estimated to be $248,000. These are the costs 

of recordkeeping. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$2,320. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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 Nitric Acid 

Plants for which Construction, Reconstruction or Modification Commenced after October 14, 

2011 (40 CFR Part 60, Subpart Ga) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

4.8 existing respondents will be subject to the standard. It is estimated that an additional 1.2 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 6 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
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Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

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 1.2 3.6 0 0 4.8

2 1.2 4.8 0 0 6

3 1.2 6 0 0 7.2

Average 1.2 4.8 0 0 6

1

New respondents include sources with constructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 6. 

The total number of annual responses per year is calculated using the following table: 
12

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 / 

reconstruction

1.2 1 0 1.2

Notification of actual startup 1.2 1 0 1.2

Notification of physical or 

operational change

1.2 1 0 1.2

Notification of CERMS 

demonstration

1.2 1 0 1.2

Notification of initial 

performance test

1.2 1 0 1.2

Report of performance test 1.2 1 0 1.2

NOx noncompliance report 0.6 1 0 0.6

Total 7.8

The number of Total Annual Responses is 8 (rounded). 

The total annual labor costs are $138,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Nitric Acid Plants for 

which Construction, Reconstruction or Modification Commenced after October 14, 2011 (40 

CFR Part 60, Subpart Ga) (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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 1,370 hours, at a cost of $138,000 (rounded). 

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

and Cost – NSPS for Nitric Acid Plants for which Construction, Reconstruction or 

Modification Commenced after October 14, 2011 (40 CFR Part 60, Subpart Ga) (Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties 
13

of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection 

of information is estimated to average 170 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $248,000. 

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 50

labor hours at a cost of $2,320. See Table 2: Average Annual EPA Burden and Cost – NSPS for 

Nitric Acid Plants for which Construction, Reconstruction or Modification Commenced after 

October 14, 2011 (40 CFR Part 60, Subpart Ga) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent and Agency burden due to an increase 

in the estimated number of sources. Our research during the rule development indicated an 

average of 1.2 new sources per year will become subject to the rule. We assume the industry

will continue to grow linearly at this rate. This also results in an increase in annual O&M costs. 

6(g) Burden Statement

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

is estimated to average 170 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.
14

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 ICR under 

Docket ID Number EPA-HQ-OECA-2014-0103. An electronic version of the public docket is 

available at http://www.regulations.gov/, which may be used to obtain a copy of the draft 

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

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

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

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

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

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

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

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

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

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

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

Number EPA-HQ-OECA-2014-0103 and OMB Control Number 2060-0674 in any

correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
15

Table 1: Annual Respondent Burden and Cost – NSPS for Nitric Acid Plants for which Construction, Reconstruction or 

Modification Commenced after October 14, 2011 (40 CFR Part 60, Subpart Ga) (Renewal)

Item

(A) 

Hours per 

Occurrence

(B) 

Occurrences/ 

RespondentYr

(C) 

Hours/ 

RespondentYr 

(AxB)

(D) 

Respondents/ 

Year

(E) 

Technical 

Hours/Year 

(C x D)

(F) 

Managerial 

Hours/Year 

(E x 0.05)

(G) 

Clerical 

Hours/Year 

(E x 0.10)

(F)

Cost/ Year

1. APPLICATIONS N/A

2. SURVEY AND STUDIES N/A 

3. ACQUISITION, INSTALLATION, AND 

UTILIZATION OF TECHNOLOGY AND 

SYSTEMS 

N/A

4. REPORT REQUIREMENTS

A. Familiarization with the regulatory 

requirements

All Sources 1 1 1 6 6 0.3 0.6 $693.87

B. Required Activities

New Sources - Initial Performance 

Test 180 1 180 1.2 216 10.8 21.6 $24,979.43 

New Sources – Demonstration of 

CERMS 180 1 180 1.2 216 10.8 21.6 $24,979.43 

New Sources - Daily monitoring 

(CERMS) 0.5 330 165 1.2 198 9.9 19.8 $22,897.81 

C. Create Information (Included in 4B)

D. Gather Existing Information 

(Included in 4E)

E. Write Report

New Sources - Notification of 

construction/reconstruction 2 1 2 1.2 2.4 0.12 0.24 $277.55 

New Sources - Notification of actual 

startup 2 1 2 1.2 2.4 0.12 0.24 $277.55 

New Sources - Physical or 

operational change 2 1 2 1.2 2.4 0.12 0.24 $277.55 

New Sources - Notification of 

demonstration of CERMS

2 1 2 1.2 2.4 0.12 0.24 $277.55 
16

New Sources - Notification of initial 

performance test

2 1 2 1.2 2.4 0.12 0.24 $277.55 

New Sources - Report of 

performance test 2 1 2 1.2 2.4 0.12 0.24 $277.55 

NOx Noncompliance report 2 1 2 0.6 1.2 0.06 0.12 $138.77 

Subtotal for Reporting 749 $75,355

5. RECORDKEEPING REQUIREMENTS

A. Read Instructions (Included in 4A)

B. Plan Activities (Included in 4B)

C. Implement Activities (Included in 4B)

D. Record Data ( Not Applicable)

Record of noncompliance 0.5 1 0.5 6 3 0.15 0.3 $346.94 

E. Time to Transmit or Disclose 

Information

Daily production and flow rates 8 1 8 6 48 2.4 4.8 $5,550.98 

Data collection 0.125 330 41.25 6 247.5 12.375 24.75 $28,622.26 

Records of startups, shutdowns, 

malfunctions, etc

8 1 8 6 48 2.4 4.8 $5,550.98 

F. Time to Train Personnel

Train Personnel for CERMS 

maintenance 16 2 32 6 192 9.6 19.2 $22,203.94 

G. Time for Audits (Not Applicable)

Subtotal for Recordkeeping 619 $62,275.10 

TOTAL ANNUAL LABOR BURDEN 

AND COST (Rounded) 1,370 $138,000

Capital and O&M $248,000

TOTAL COSTS $386,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 
17

Table 2: Average Annual EPA Burden and Cost – NSPS for Nitric Acid Plants for which Construction, Reconstruction or 

Modification Commenced after October 14, 2011 (40 CFR Part 60, Subpart Ga) (Renewal)

Activity

(A)

EPA Hours/ 

Occurrence

(B) 

Occurrences/ 

Plant/Year

(C)

EPA 

Hours/ 

Plant/Year 

(A x B)

(D) 

Plants/ 

Year

(E)

EPA 

Technical 

Hours/ 

Year

(C x D)

(F)

EPA 

Managerial 

Hours/Year

(G)

EPA 

Clerical 

Hours/Year

(H) 

Cost, $

Observe Initial Performance Tests 24 1 24 1.2 28.8 1.44 2.88 $1,507 

Notification of construction/reconstruction 

commencement 2 1 2 1.2 2.4 0.12 0.24 $126 

Notification of actual startup 0.5 1 0.5 1.2 0.6 0.03 0.06 $31 

Notification of performance test 0.5 1 0.5 1.2 0.6 0.03 0.06 $31 

Review Test Results 8 1 8 1.2 9.6 0.48 0.10 $481 

Review NOX noncompliance reports 8 1 8 0.36 2.88 0.144 0.03 $144 

Total Annual Hours (Rounded) 50 $2,320

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.