# 1 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Standards of Performance for Nitric Acid Plants for Which Construction, Reconstruction,

or Modification Commenced After September 30, 2011

(40 CFR part 60, subpart Ga )

August 201 1

P art A of the Supporting Statement

1. Identification of the Information Collection

(a) Title and Number of the Information Collection

.

“ Recordkeeping and Reporting Requirements f or Nitric Acid Plants for Which

Construction, Reconstruction, or Modification Commenced After September 30, 2011 (40 CFR

Part 60, Subpart Ga )

. ” The EPA ICR tracking number is 2445.01

.

(b) Short Characterization

.

The New Source Performance Standards (NSPS) for nitric acid plants (40 CFR part 60,

subpart G) were proposed on August 17, 1971, and promulgated on June 14, 1974

. This

information collection is for a new subpart Ga, which will apply to nitric acid producti on units

which commence construction, modification

, or reconstruction after the date of proposal

. Nitrogen oxide (NO X 

# ) is the pollutant regulated under this subpart

. The standards limit nitrogen

oxides, expressed as nitrogen dioxide ( NO 2 

# ), in excess of 0. 5 0 lb per ton of acid produced

. This

information is being collected to assure compliance with 40 CFR part 60, subpart Ga

.

In general, all NSPS standards require initial notifications, performance tests, and

periodic reports

. Owners or operators are also r equired 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 ess ential in determining compliance, and are required of all sources subject to NSPS

.

Any owner or operator subject to the provisions of this part shall maintain a file of these

measurements, and retain the file for at least two years following the date of such measurements,

maintenance reports, and records

. All reports are sent to the delegated state or local authority

. In

the event that there is no such delegated authority, the reports are sent directly to the United

States Environmental Protection Agency (EPA) regional office.

Potential respondents are owners or operators of new nitric acid production units

. I t is

estimated that an additional 4 newly constructed nitric acid production units will become subject

to the regulation in the next three years

. Plants can have more than one nitric acid production unit

onsite

.

# 2 2. Need for and Use of the Collection

(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 s tationary sources that reflect:

. . . application of the best system of emission reduction which

( taking into account the cost of achieving such reduction and any

non

- air q uality health and environmental impact and energy

requirements) the Administrator determines has been adequately

demonstrated

. Section 111(a)(l).

The Agency refers to this ch arge as selecting the best demonstrated technology (BDT)

. Section

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

eight years.

In addition, section 114(a) states that the Administrator may require any owne r or

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

w hen 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, NO X 

# emissio ns from nitric acid p lants cause or

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

welfare

. Therefore, the NSPS w ill be promulgated for this source category at 40 CFR part 60,

subpart Ga

.

(b) Use /Users of the Data

.

The control of emissions of NO X 

# from nitric acid plants not only requires the installation

of properly designed equipment, but also the operation and maintenance of that equipment

. Emissions of NO X 

# from nitric acid p lants are the result of operatio n of the affected plants

.

The standards are achieved by the reduction of pollutant emissions using control

technology

. The notifications required in the applicable regulations are used to inform the

Agency or delegated authority when a source becomes sub ject to the requirements of the

# 3 regulations

. The reviewing authority may then inspect the source to check if the pollution control

devices are properly installed and operated and the regulations are being met.

For our analysis of these standards , we assum e sources will rely on the reduction of NO X 

# by using Selective Catalytic Reduction (SCR)

. The required notifications are used to inform the

Agency or delegated authority when a source becomes subject to the standard

. The reviewing

authority may then inspect the source to check if the pollution control devices are properly

installed and operated and the standard is being met

. Performance test reports are needed as these

are the Agency’s record of a source’s initial capability to comply with the emissio n standard, and

note the operating conditions under which compliance was achieved

. The periodic reports are

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

compliance determinations

. The information generated by the monitoring, recordkeeping

, and

reporting requirements described in this ICR is used by the Agency to ensure that plants affected

by the NSPS continue to operate the control equipment used to achieve compliance with the

NSPS

. Adequate monitoring, recordkee ping, and reporting are necessary to ensure compliance

with these standards, as required by the Clean Air Act

. The information collected from

recordkeeping and reporting requirements is also used for targeting inspections, and is of

sufficient quality to b e used as evidence in court.

3

. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication

.

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

appropriate EPA region al office

. Otherwise, the information is sent directly to the delegated state

or local agency

. If a s tate or local agency has adopted their own similar standards to implement

the Federal standards, a copy of the report submitted to the s tate or local agency can be sent to

the Administrator in lieu of the report required by the Federal standards

. Therefore, no

duplication exists.

(b) Public Notice Required Prior to ICR Submission to OMB

.

This section is not applicable because this is a rule related ICR.

(c ) Consu ltations

.

During development of the proposed revisions , EPA held meetings and conference calls

with representatives of The Fertilizer Institute ( TFI )

. We estimate that approximately 4 nitric

acid production units will be constructed, modified, or reconstr ucted, or expanded over the next

3 year s

.

(d) Effects of Less Frequent Collection

.

Less frequent information collection would decrease the margin of assurance that plants

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

# 4 frequently, the likelihood of detecting poor operati on and maintenance of control equipment and

noncompliance would decrease.

(e) General Guidelines

.

None of these reporting or recordkeeping requirements violate any of the regulations

established by the Office of Management and Budget (OMB) at 5 CFR 1320 .5.

(f) Confidentiality

.

Some respondents may consider production rate or concentration data to be confidential

. A ny such information submitted to the Agency for which a claim of confidentiality is made will

be safeguarded according to the Agency polici es 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).

(g) Sensitive Questions

.

None of the reporting or recordkeeping requirements contain sensitive questions.

4

. The Respondents and the Information Requested

(a) Respondents/ NAICS Codes

.

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

. The North American Industry Classification System ( NAICS ) code for respondents affected by

the standards is 325311, Nitrogenous Fertilizer Manufacturing.

(b) Informati on Requested

.

( i) Data Items , Including Recordkeeping Requirements

. All data in this ICR that is

recorded and/or reported is required by NSPS for Nitric Acid Plants for Which Construction,

Reconstruction, or Modification Commenced After February 2011 (40 CFR part 60, subpart Ga ).

A source must make the following reports:

Reports for 40 CFR part 60, subpart Ga

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 a ctual startup

. 60.7(a)(3)

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

# 5 Reports for 40 CFR part 60, subpart Ga

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

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

Initial performance test. 60.8(d) , 60.7 3 a( f )

Compliance status. 60.7(a)(7)

Malfunction report

. 60.7(b), 60.77a( f )

NO X 

# emission rates that are not in compliance with the emission

standard. 60.77a(b)(2)

A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart Ga

M alfunctions and periods where the continuous monitoring system is

inoperative. 60.7 6a ( f )

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

Records o f ongoing monitoring

. 60.7(f)

Record daily production and nitric acid concentration. 60. 76a ( b ) ( 2 )

Records of noncompliance with the emission standard and description

of corrective action. 60. 76a ( c ) and ( d )

Electronic Reporting

Currently, sources are using monitoring equipment that provides automated parameter

data, e.g., continuous emissions monitoring

. Although personnel at the affected facility must

evaluate the data, this type of monitoring equipment has significantly reduced the burden

associated with monitoring and recordkeeping

. In addition, some regulatory agencies are setting

up electronic reporting systems to allow sources to report electronically which is reducing the

reporting burden

. However, electronic reporting syst ems are still not widely used by the

regulatory agencies

. It is estimated that approximately 10 percent of the respondents will use

electronic reporting.

(ii) Respondent Activities

. The respondent activities required by subpart Ga are listed

in the following tables.

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate Continuous Emission Rate Monitoring System s

(C E R MS)

, which include NO X 

# and gas f low rate m onitors

.

# 6 Respondent Activities

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

(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 reports, including performance test reports and reports documenting NO X 

# emission

rates that are not in compliance the standard in subpart Ga

. Review notifications, including construction/reconstruction commencement, actual startup,

and performance test.

Review performance test results.

(b) Collection Methodology and Management

.

Following notification of startup, the reviewing authority might 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 responden ts are tabulated and published

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 t he reports is entered into the AIRS Facility Subsystem ( AFS )

which is operated and maintained by EPA ’ s Office of Compliance

. AFS is EPA’s database for

the collection, maintenance, and retrieval of compliance and annual emission inventory data for

over 1 25 ,000 industrial and government

- owned facilities

. EPA uses the AFS for tracking air

pollution complianc e and enforcement by local and s tate regulatory agencies, EPA region al

offices, and EPA headquarter s

. EPA and its delegated Authorities can edit, store, r etrieve

, and

analyze the data.

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

years.

# 7 (c) Small Entity Flexibility

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

businesse s)

. 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, t he 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 la rger business can use economies of scale to

reduce their burden, the overall burden will be reduced.

(d) Collection Schedule

.

The specific frequency for each information collection activity within this request is

shown in Table s 1a through 1c : Respondent Burden of Reporting and Recordkeeping

Requirements, NSPS for Nitric Acid Plants (40 CFR P art 60, S ubpart Ga ) for the first three years

of the information collection

.

6

. Estimating the Burden and Cost of the Collection

Table s 1 a

- 1c : Respondent Burden of Reporting and Recordkeeping Requirements, NSPS

for Nitric Acid Plants (40 CF R part 60, subpart Ga ) document s the computation of individual

burdens for the recordkeeping and reporting requirements applicable to the industry for the

subp art included in this ICR for each of the first 3 years

. Table 1 d contains a summary of the

respondent burden costs and hours detailed in Table s 1a through 1c

.

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 ; r esponses to this information

collection are mandatory.

The Agency may not conduct or sponsor, and a person is not req uired to respond to, a

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

(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 968 hours per year ( 3 Year Average Hours from

Table 1 d )

. These hours are based on Agency studies and background documents from the

develop ment of the regulation, Agency knowledge

, and experience with the NSPS program, and

any comments received.

# 8 (b) Estimating Respondent Costs

.

( i) Estimating Labor Costs

. Labor rates and associated costs are based on Bureau of

Labor Sta tistics (BLS) data

. Technical, management, and clerical average hourly rates for private

industry workers were taken from the United States Department of Labor, Bureau of Labor

Statistics, September 2010 , “Table 2

. Civilian Workers, by occupational and industry group,”

available at http://www.bls.gov/news.release/ecec.t02.htm

. Wages for occupational groups are

used as the basis for the labor rates with a tota l compensation of $4 6

. 8 2 per hour for technical,

$ 49

. 14 per hour for managerial, and $2 3

. 41 per hour for clerical

. These rates represent salaries

plus fringe benefits and do not include the cost of overhead

. An overhead rate of 1 10 percent is

used to accou nt for these costs

. The fully

- burdened hourly wage rates used to represent

respondent labor costs are: technical at $ 98.32 , management at $ 103.19 , and clerical at $4 9.16

.

(i i) Estimating Capital and Operation s and Maintenance (O&M) Costs

. The capital

costs associated with the information collection requirements will include the costs to conduct

performance tests , startup costs for CE R MS, and purchase file cabinets for keeping records

. The

rule will require an initial performance test for each new nitri c acid plant

. The annual operation

and maintenance costs are the ongoing costs to maintain the monitors and other costs such as

photocopying and postage.

The annual average capital/startup costs for CE R MS that will be used to control NO

x 

# emissions is $ 1 36 ,07 0 (costs derived from EPA Model ) with an annual operations and

maintenance costs of $ 2 3

, 488

.

The total respondent costs have been calculated as the addition of the capital/startup

costs, and the annual operation and maintenance costs

. The average an nual cost for

capital/startup and operation and maintenance costs to industry over the next three years of the

I CR are estimated to be $ 159

, 558

. T he continuous monitoring costs that are included in this

section consist only of those capital/startup and O&M costs that a source incurs as a result of the

standard

. Some continuous monitoring costs may not be included in this section

. For instance, if

a particular industry typically utilizes a control device that must have a continuous monitor (e.g.,

temperature , pressure drop, etc.) to function properly, and the record ing of additional

measurements beyond the minimum are required by the standard, then there is no capital/startup

or O&M cost, but there is a labor cost to record the additional readings

. Such a cos t would not

appear in this section, but in the industry burden Section 6(d) below.

It is assumed that the 4 newly constructed nitric acid plants will not be located at existing

facilities

. It is anticipated that new units will use CE R MS for compliance with the proposed new

NO

x 

# limit

. Initial CE R MS testing is usually conducted by an installation contractor such that the

cost of the emissions testing is a capital cost

. T esting costs are $1 5,019 for each NO

x 

# CEMS and

$ 6,229 for a flow meter (assumes one flow meter per stack)

. The 4 new sources in this sec tor

result in a total capital cost of approximately $ 76,496 for CE R MS testing over the next three

years.

# 9 (iii) Annualizing Capital Costs

. The annualized capital costs include the costs for one

year ( 1.2 units ) for NO X 

# CEMS, flow meters, and file cabinets

. The annualized capital costs for

equipment associated with NO X 

# CEMS and flow meters were calculated using a 7 percent

interest rate and a 10 year life (i.e., CRF of 0.1424)

. The annuali zed capital cost for file cabinets

was calculated using a 7 percent interest rate and a 15

- year life (i.e., CRF of 0.1098)

. The total

annualized capital costs total $ 42

, 776

. T he CEMS Monitoring Costs Spreadsheet can be found in

the docket (See Section 6(g) for docket information).

(c ) Estimating Agency Burden and Cost

.

Table s 2a

- 2c : Burden and Cost to the Agency

— NSPS for Nitric Acid Plants document s

the costs of this NSPS revision to the Agency for the first 3 years of the information collection

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

. Publication and distribution of the information are part of the AFS program

. Examination of

records to be maintained by the respondents will occur as part of th e periodic inspection of

sources, which is part of EPA ’ s overall compliance and enforcement program. Table 2 d contains

a summary of the agency burden cost s and hours detailed in Table s 2a

- 2c

. The average annual

Agency cost during the three years of the ICR is estimated to be $ 3

, 206

.

The Agency labor rates are from the Office of Personnel Management (OPM) 2008

General Schedule which excludes locality rates of pay

. These rates can be obtained from Salary

Table 20 1 1

- GS, available on the OPM website at http://www.opm.gov/oca/11tables/html/gs_h.asp

. The government employee labor rates are $ 1 5.63 per hour for clerical (GS

- 6, Step 3), $ 28.88 for

technical (GS

- 12, Step 1), and $ 38.92 for m anagerial (G S

- 13, Step 5)

. These rates were increased

by 60 percent to include fringe benefits and overhead

. The fully

- burdened wage rates used to

represent Agency labor costs are: clerical at $ 2 5.01 , technical at $ 46.21 , and managerial at $ 62.27

.

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

.

It is estimated that 4 newly constructed nitric acid production units will become subject to

the proposed regulation in the next three years. Nitric acid production was estimated for 2006

(TSD for Greenhouse Gas Reporting Rule), using the production growth of 6.5% from 2006 to

2007 (ICIS) and the predicted production growth rate of 3% for 2007 through 2016 (ICIS)

. In the

period from 2010 through 2016, the growth was approximately 1.6 million tons of nitric acid

. Assuming 350 days per year, this equals approximately 4,586 tpd of nitric acid production

. Using the model plants, the estimate of 4,586 tpd equals 2 production trains that produce 300

tpd, and 4 production trains that produce 1,000 tpd over the five year period after promulgation.

The total annual number of responses for the monitoring, recordkeeping, and reporting

requirements in subpart Ga is 2 2 for the 4 newly constructed nitric acid units

.

The total annu al labor costs are $ 91

, 808

. Details upon which this estimate is based appear

in Table 1a

.

# 10 (e ) Bottom Line Burden Hours and Cost Tables

.

The bottom line burden hours and cost tables for both the Agency and the respondents are

attached

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

information is estimated to average 44.8 hours per response.

(f) Reasons for Change in Burden

.

There is no change in burden because this is a new Information Collection.

(g) Burden Statement

.

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

is estimated to average 44.8 hours per response

. Burden means the total time, effort, or financial

resources expended by persons to generate, mainta in, 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 informa tion, 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; s earch 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’ s 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 ICR under

Docket ID Number EPA

- HQ

- OA R

- 200 7

- 0 877

. An electronic version of the public docket is

available at 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 t he public docket that are available electronically

. When in the system, select “search,” then key in Docket ID Number EPA

- HQ

- OAR

- 200 7

- 0877

. The documents are also available for public viewing at the EPA Docket Center, EPA West,

Ro om 3334

, 1301 Constitution Avenue , 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 docke t center is (202) 566

- 17 4 2

. S end comments to the Office of Information and

Regulatory Affairs, Office of Management and Budget (OMB), Attn: Desk Officer for EPA,

725 17th St., NW, Washington, DC 20503

. Please i nc lude the EPA Docket ID Number

EPA

- HQ

- OAR

- 200 7

- 0877 and OMB Control Number 2060

- NEW in any correspondence.

# 11 Part B of the Supporting Statement

This part is not applicable because statistical methods are not used in data collection

associated with the rule

.

# 12 Table 1 a

. Year 1 Respondent Burden and Cost

- NSPS for Nitric Acid Plants (40 CFR part 60, subpart Ga )

Year 1

- Respondent

(A) Hours per Occurrence (B) Occurrences/

Respondent/Year (C) Hours/

Respondent/

Year (A x B) (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 (Not Applicable)

2. SURVEY AND STUDIES (Not Applicable)

3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND

SYSTEMS (Not Applicable)

4. REPORT REQUIREMENTS

A. Read Instructions

New Sources 1 1 1 1.2 1.2 0.1 0.2 $131

B. Required Activities

New Sources

- Initial Performance Test 180 1 180 1.2 216 10.8 21.6 $23,557

New Sources

– Demonstration of CE R MS 180 1 180 1.2 216 10.8 21.6 $23,557

New Sources

- Daily monitoring (CE R MS) 0.5 330 165 1.2 198 9.9 19.8 $21,594

C. Create Information (Included in 4B)

D. Gather Existing Information (Included in 4E)

E. Wr ite Report

New Sources

- Notification of construction/reconstruction 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of actual startup 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Physical or Operational Change 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of Demonstration of CE R MS 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of Initial Performance Test 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Report of Performance Test 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Report of Noncompliance with NOX emission standard 2 1 2 0.12 0.24 0.0 0.0 $26

5. RECORDKEEPING REQUIREMENTS

A. Read Instructions (Included in 4A)

B. Pl an Activities (Included in 4B)

C. Implement Activities (Included in 4B)

D. Re cord Data ( Not Applicable)

New Sources

- Record times of noncompliance with emission standard

and document corrective actions. 0.5 1 0.5 0.12 0.1 0.0 0.0 $7

E. Time to Transmit or Disclose Information

New Sources

- Daily production and flow rates 8 1 8 1.2 9.6 0.5 1.0 $1,047

New Sources

– Data Collection 0.125 330 33 1.2 39.6 2.0 4.0 $4,319

New Sources

- Records of Startups, Shutdowns, malfunctions, etc 8 1 8 1.2 9.6 0.5 1.0 $1,047

F. Time to Train Personnel

Tra in Personnel for CE R MS maintenance 16 2 32 1.2 38.4 1.9 3.8 $4,188

G. Time for Audits (Not Applicable)

TOTAL ANNUAL LABOR BURDEN AND COST 67 5 1 7 74 3 37 74 $ 81

, 044

85 5 Hours

ANNUAL CAPITAL COSTS

Performance tests $ 76,492

File cabinets $ 940

Other capital costs of installation (ODC and labor) $136,174

Total annual capital $ 213

, 606

ANNUALIZED CAPITAL COSTS

File cabinets (15 year life, 7% interest; CRF=0.1098) $ 103

Other annualized capital costs (10 year life, 7% interest, CRF=0.1424) $ 1 9

, 185

Total annualized capital $ 1 9

, 288

TOTAL ANNUAL COSTS (O&M) $ 2 3

, 488

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $ 42

, 776

# 13 Table 1b . Year 2 Respondent Burden and Cost

- NSPS for Nitric Acid Plants (40 CFR part 60, subpart Ga)

Year 2

- Respondent

(A) Hours per Occurrence (B) Occurrences/

Respondent/Year (C) Hours/

Respondent/

Year (A x B) (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 (Not Applicable)

2. SURVEY AND STUDIES (Not Applicable)

3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND

SYSTEMS (Not Applicable)

4. REPORT REQUIREMENTS

A. Read Instructions

New Sources 1 1 1 2.4 2.4 0.1 0.2 $ 262

B. Required Activities

New Sources

- Initial Performance Test 180 1 180 1.2 216 10.8 21.6 $23,557

New Sources

– Demonstration of CE R MS 180 1 180 1.2 216 10.8 21.6 $23,557

New Sources

- Daily monitoring (CE R MS) 0.5 330 165 1.2 198 9.9 19.8 $21,594

C. Create Information (Included in 4B)

D. Gather Existing Information (Included in 4E)

E. Wr ite Report

New Sources

- Notification of construction/reconstruction 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of actual startup 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Physical or Operational Change 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of Demonstration of CE R MS 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of Initial Performance Test 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Report of Performance Test 2 1 2 1.2 2.4 0.1 0.2 $262

New sources

- Report of Noncompliance with NOX emission standard 2 1 2 0.24 0.5 0.0 0.0 $52

5. RECORDKEEPING REQUIREMENTS

A. Read Instructions (Included in 4A)

B. Pl an Activities (Included in 4B)

C. Implement Activities (Included in 4B)

D. Record Data ( Not Applicable)

Record of noncompliance 0.5 1 0.5 0.24 0.1 0.0 0.0 $13

E. Time to Transmit or Disclose Information

New Sources

- Daily production and flow rates 8 1 8 2.4 1 9. 2 1 1. 9 $ 2 ,0 94

New Sources

– Data Collection 0.125 330 33 2.4 79.2 4 7.9 $ 8

, 638

New Sources

- Records of Startups, Shutdowns, malfunctions, etc 8 1 8 2.4 1 9. 2 1 1. 9 $ 2 ,0 94

New Sources

-

F. Time to Train Personnel

Train Personnel for CE R MS maintenance 16 2 32 2.4 76.8 3.8 7.7 $ 8

, 376

G. Time for Audits (Not Applicable)

TOTAL ANNUAL LABOR BURDEN AND COST 675 23 842 42 8 4 $ 91

, 808

968 Hours

ANNUAL CAPITAL COSTS

Performance tests $ 76

, 492

File cabinets $ 940

Other capital costs of installation (ODC and labor) $136,174

Total annual capital $ 213,606

ANNUALIZED CAPITAL COSTS

File cabinets (15 year life, 7% interest; CRF=0.1098) $ 103

Other annualized capital costs (10 year life, 7% interest, CRF=0.1424) $ 1 9

, 185

Total annualized capital $ 1 9

, 288

TOTAL ANNUAL COSTS (O&M) $ 2 3

, 488

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $ 42

, 776

# 14 Table 1c . Year 3 Respondent Burden and Cost

- NSPS for Nitric Acid Plants (40 CFR part 60, subpart Ga)

Year 3

- Respondent

(A) Hours per Occurrence (B) Occurrences/

Respondent/Year (C) Hours/

Respondent/

Year (A x B) (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 (Not Applicable)

2. SURVEY AND STUDIES (Not Applicable)

3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND

SYSTEMS (Not Applicable)

4. REPORT REQUIREMENTS

A. Read Instructions

New Sources 1 1 1 3.6 3.6 0. 2 0. 4 $ 393

B. Required Activities

New Sources

- Initial Performance Test 180 1 180 1.2 216 10.8 21.6 $23,557

New Sources

– Demonstration of CE R MS 180 1 180 1.2 216 10.8 21.6 $23,557

New Sources

- Daily monitoring (CE R MS) 0.5 330 165 1.2 198 9.9 19.8 $21,594

C. Create Information (Included in 4B)

D. Gather Existing Information (Included in 4E)

E. Wr ite Report

New Sources

- Notification of construction/reconstruction 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of actual startup 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of Demonstration of CE R MS 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Notification of Initial Performance Test 2 1 2 1.2 2.4 0.1 0.2 $262

New Sources

- Report of Performance Test 2 1 2 1.2 2.4 0.1 0.2 $262

New sources

- 2 1 2 0.36 0.7 0.0 0.1 $79

5. RECORDKEEPING REQUIREMENTS

A. Read Instructions (Included in 4A)

B. Pl an Activities (Included in 4B)

C. Implement Activities (Included in 4B)

D. Re cord Data ( Not Applicable)

Record of noncompliance 0.5 1 0.5 0.36 0.2 0.0 0.0 $20

E. Time to Transmit or Disclose Information

New Sources

- Daily production and flow rates 8 1 8 3.6 28.8 1.4 2.9 $ 3,141

New Sources

– Data Collection 0.125 330 33 3.6 118.8 5.9 11.9 $ 12,956

New Sources

- Records of Startups, Shutdowns, malfunctions, etc 8 1 8 3.6 28.8 1.4 2.9 $ 3,141

New Sources

-

F. Time to Train Personnel

Train Personnel for CE R MS maintenance 16 2 32 3.6 115.2 5.8 11.5 $ 12

, 564

G. Time for Audits (Not Applicable)

TOTAL ANNUAL LABOR BURDEN AND COST 67 5 30 941 4 7 9 4 $ 102,572

1,082 Hours

ANNUAL CAPITAL COSTS

Performance tests $ 76

, 492

File cabinets $ 940

Other capital costs of installation (ODC and labor) $136,174

Total annual capital $213,606

ANNUALIZED CAPITAL COSTS

File cabinets (15 year life, 7% interest; CRF=0.1098) $ 103

Other annualized capital costs (10 year life, 7% interest, CRF=0.1424) $ 1 9

, 185

Total annualized capital $ 1 9

, 288

TOTAL ANNUAL COSTS (O&M) $ 2 3

, 488

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $ 42

, 776

# 15 Table 1 d

. Summary of Respondent Burden and Cost

- NSPS for Nitric Acid Plants (40 CFR part 60, subpart Ga )

Year Total Annual Labor

Burden (hours) Total Annual Costs

1 855 $81,044

2 968 $91,808

3 1,082 $102,572

Total 2,904 $275,424

3

- Year Average 968 $91,808

# 16 Table 2 a

. Year 1 Burden and Cost to the Agency

— NSPS for Nitric Acid Plants

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 2 8.8 1 .44 0.2 88 $ 1,4 28

Notification of construction/reconstruction commencement 2 1 2 1.2 2.4 0. 12 0. 24 $ 119

Notification of actual startup 0.5 1 0.5 1.2 0.6 0. 03 0.0 6 $ 30

Notification of performance test 0.5 1 0.5 1.2 0.6 0. 03 0.06 $ 30

Review Test Results 8 1 8 1.2 9.6 0.48 0.096 $476

Review NOX noncompliance reports 8 1 8 0.12 0.96 0.048 0.0096 $ 48

Total Annual Hours 43 2 0. 43 $ 2

, 130

46 hours

Travel Expenses $ 1,028

$ 3

, 158



# Table 2b. Year 2 Burden and Cost to the Agency

— NSPS for Nitric Acid Plants

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 0.288 $ 1,428

Notification of construction/reconstruction commencement 2 1 2 1.2 2.4 0.12 0.24 $ 119

Notification of actual startup 0.5 1 0.5 1.2 0.6 0.03 0.06 $ 30

Notification of performance test 0.5 1 0.5 1.2 0.6 0.03 0.06 $ 30

Review Test Results 8 1 8 1.2 9.6 0.48 0.096 $476

Review NOX noncompliance reports 8 1 8 0.24 1.92 0.096 0.0192 $ 95

Total Annual Hours 44 2.2 0.4 $ 2

, 177

47 hours

Travel Expenses $ 1,028

$ 3,2 06



# Table 2c. Year 3 Burden and Cost to the Agency

— NSPS for Nitric Acid Plants

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 0.288 $ 1,428

Notification of construction/reconstruction commencement 2 1 2 1.2 2.4 0.12 0.24 $ 119

Notification of actual startup 0.5 1 0.5 1.2 0.6 0.03 0.06 $ 30

Notification of performance test 0.5 1 0.5 1.2 0.6 0.03 0.06 $ 30

Review Test Results 8 1 8 1.2 9.6 0.48 0.096 $476

Review NOX noncompliance reports 8 1 8 0.36 2.88 0.144 0.0288 $ 143

Total Annual Hours 45 2.2 0.4 $ 2

, 225

48 hours

Travel Expenses $ 1,028

$ 3,2 53

a Assume agency personnel visit 1 .2 new plant each year.

Travel Expenses = (1 person x 1 .2 plant/year x 3 days/plant x $ 117 per diem) + ($ 608 round trip/plant x 1 plant /year) = $ 1,028 /year

# 17 Table 2 d

. Summary of Burden and Cost to the Agency

— NSPS for Nitric Acid Plants

Year Total Annual Labor

Burden (Hours) Total Annual Costs

1 4 6 $ 3, 158

2 47 $3,2 06

3 47 $3,2 53

Total 1 39 $9,6 17

3

- Year Average 4 6 $3,2 06

## Summary of CEMS

Analyzers BEFORE AFTER

CO 0 0

SO2 0 0

NOX 0 0

HCl 0 0

Mercury (and CO2/O2) 0 0

CO2 0 0

O2 0 0

THC 0 0

Monitors

OPACITY 0 0

FLOW 0 1

PM (beta gauge) 0 0

PM (light scattering; insitu) 0 0

PM (light scattering; extractive) 0 0

Bag leak detector

Number of fabric filters to be monitored= 0 0

Number of sensors= 0 0

Summary of Costs

First Costs Labor Test ODCs Total

Planning 528 0 0 528

Select Equipment 1,709 0 293 2,002

Support Facilities 0 0 900 900

Purchase CEMS Hardware 0 0 19,080 19,080

Install and Check CEMS 1,037 0 690 1,727

Performance Specification Tests 77 440 0 517

QA/QC Plan 2,306 7,650 692 10,647

5,656 8,090 21,655 35,401

Annual Costs

Day-to-Day Activities 691 0 0 691

Annual RATA 0 0 0 0

PM Monitor RCA 0 0 0 0

PM Monitor RRA 0 0 0 0

Cylinder Gas Audits (ACA/SVA for PM) 0 0 0 0

Recordkeeping and Reporting 5,448 0 40 5,488

Annual QA & O&M Review and Update 1,409 0 1,180 2,589

Capital Recovery 805 1,152 3,084 5,041

Total w/o capital recovery 7,548 0 1,220 8,768

Total with capital recovery 8,354 1,152 4,304 13,810

## Summary of CEMS

Analyzers BEFORE AFTER

CO 0 0

SO2 0 0

NOX 0 1

HCl 0 0

Mercury (and CO2/O2) 0 0

CO2 0 0

O2 0 0

THC 0 0

Monitors

OPACITY 0 0

FLOW 0 0

PM (beta gauge) 0 0

PM (light scattering; insitu) 0 0

PM (light scattering; extractive) 0 0

Bag leak detector

Number of fabric filters to be monitored= 0 0

Number of sensors= 0 0

Summary of Costs

First Costs Labor Test ODCs Total

Planning 1,910 0 284 2,194

Select Equipment 10,941 0 3,067 14,008

Support Facilities 0 0 18,865 18,865

Purchase CEMS Hardware 0 0 62,794 62,794

Install and Check CEMS 4,343 0 11,979 16,322

Performance Specification Tests 2,129 7,526 503 10,157

QA/QC Plan 2,570 11,981 692 15,244

21,894 19,507 98,183 139,584

Annual Costs

Day-to-Day Activities 5,532 0 1,000 6,532

Annual RATA 885 7,156 0 8,041

PM Monitor RCA 0 0 0 0

PM Monitor RRA 0 0 0 0

Cylinder Gas Audits (ACA/SVA for PM) 1,284 0 1,069 2,353

Recordkeeping and Reporting 1,253 0 160 1,413

Annual QA & O&M Review and Update 2,074 0 1,324 3,398

Capital Recovery 3,118 2,778 13,981 19,877

Total w/o capital recovery 11,029 7,156 3,553 21,738

Total with capital recovery 14,147 9,934 17,534 41,615