**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 b y either the pressure or atmospheric pressure process

. Nitrogen oxide (NO X) is the pollutant regulated under this subpart. The se standards limit nitrogen oxides, expressed as nitrogen dioxide (NO 2 ), to 0.50 lb per ton of 100 percent nitric acid produced. This information is being collected to assure compliance with 40 CFR P art 60, Subpart Ga

. 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 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 directl y 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 F ederal 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

- ye ar period after the rule effective date (1.2 new sources per ye ar). Over the next three ye ars , we estimate that 6 units per year will be subject to the se standard s , and 1.2 additional units per year will become subject to the se standard s
. Plants can have more than one nitric acid production unit onsite. The Office of Management and Budget OMB approved the currentl y- active In formation Collection Requirements ( IC R) 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), a s 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 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 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 mo nitoring 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 reasonabl y require. In the Administrator's judgment, NO X emissions from nitric acid plants cause or3

contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NSPS were p romulgated 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 the se standard s 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. Continuous emission monitors are used to ensure compliance with the standard at all times. For our anal ys is of these standards, we assume sources will rel y on the reduction of NO X by using Selective Catal ytic 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 dev ices are properl y installed and operated, leaks are being detected and repaired , and the standard s are being met. The performance test may also be observed. The required noncompliance and malfunction reports are used to determine periods of excess emissi ons, 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 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 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 I CR was published in the Federal Register ( 79 FR 30117 ) on May 27, 2014

. One comment w as 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 the se standard s as they were being developed and the se standard s 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 co mments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. 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 I CR. **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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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 sensitive5

question s. **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 Unite d States Standard Industrial Classification ( SIC ) code for the respondents affected b y the standards is SI C 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 b y 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:

**Notification s**  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 s ys tem 60.7(a)(5)
**Reports** Initial and subsequent performance test results. 60.8(a), 60.77 a (a) Compliance status. 60.7(a)(7) A report of noncompliance, including the time period, NO X emission rates , reasons for non compliance 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 NO X 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 NO X 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 C ontinuous Emissions Rate M onitoring S ys tems (CERMS), which include NO X 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, anal yz e, and maintain data in Integrated Compliance Information System (ICI S) 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 properl y installed and operated. Performance test reports are used b y 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 published8

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.
In formation contained in the reports is reported b y state and local governments in the IC IS Air database which is operated and maintained by EPA's Off

ice of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated a

uthorities can edit, store, retrieve and anal yz e 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**  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 n eeded 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 f

requency 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 IC R. 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 record

keeping and reporting requirement s is estimated to be 1,3 70 ( Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of9

the regulation, Agency

knowledge and experien ce 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 $ 5 1

. 79 ($2 4

. 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 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 are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. Th e 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 c abinet 1 $43 6 $258 **TOTAL (Rounded)**  **$18 9**  **, 000**  **$5 9**  **, 000** 

1 In cluded 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 $ 18 9 , 000 . This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this ICR are $ 5 9 , 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 IC R is estimated to be $24 8 , 000

. These are the costs of recordkeeping. **6(c) Estimating Agency Burden and Cost** The only cos ts 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 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 $ 2,32 0

. This cost 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

. Th e rates have been increased b y 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 I CR, on average over the next three ye ars, approximately 4.8 existing respondents will be subject to the standard. It is estimated that an additional 1.2 respondents per ye ar 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 ye ars covered b y this ICR.11 **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 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

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 6

. The total number of annual responses per ye ar 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 $13 8 ,0 00

. 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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 1,3 70 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 ty

pical 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 ty pical duties13

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 17 0 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $24 8 , 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 $2,32 0 . 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 ty

pical 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 ty pical 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 incre ase 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 ye ar will become subject to the rule. We assume the industry will continue to grow linearl y 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 17 0 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 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 ways 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 15.14

To comment on the Agency's need for thi s 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

- O ECA

- 201 4

- 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 i s (202) 566

- 17 52

. Also, you can send comments to the Office of In form ation 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

- 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/ Respondent

Yr (C)

Hours/ Respondent

Yr (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 o perational c hange 2 1 2 1.2 2.4 0.12 0.24 $277.55 New Sources

- Notification of d emo nstration of CERMS 2 1 2 1.2 2.4 0.12 0.24 $277.5516

New Sources

- Notification of initial p erformance test 2 1 2 1.2 2.4 0.12 0.24 $277.55 New Sources

- Report of p erformance 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**  **74 9**  **$7 5**  **, 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 c ollection 0.125 330 41.25 6 247.5 12.375 24.75 $28,622.26 Records of s tartups, s hutdowns, 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 (** **R ounded)**  **1,3 70**  **$13 8**  **,0 00**  Capital and O&M $24 8 , 000 **TOTAL COSTS $38**  **6 ,**  **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 Revie w Test Results 8 1 8 1.2 9.6 0.48 0.10 $481 Revie w NOX noncompliance reports 8 1 8 0.36 2.88 0.144 0.03 $144 **Total Annual Hours (Rounded)**  50 $2,32 0 Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.