**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 
**NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal)** 
**1. Identification of the Information Collection 1(a) Title of the Information Collection**  NSPS for Sulfuric Acid Plants (40 CFR Part 63, Subpart H) (Renewal) EPA I CR Number 1057.1 2 , OMB Control Number 2060

- 0041 **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Sulfuric A cid Plants (40 CFR P art 60, S ubpart H), were proposed on August 17, 1971 , pro mulgated on December 23, 1971, and amended on : June 14, 1974 (39 FR 20794); October 6, 1975 (40 FR 46258); May 25, 1983 (48 FR 23611); September 29, 1983 (48 FR 4700); October 20, 1983 (48 FR 48669); February 14, 1989 (54 FR 6666) ; and October 17, 2000 (65 FR 61753). These regulations appl y to any sulfuric acid facility commencing construction, modification , or reconstruction after the date of proposal. A sulfuric acid plant is any facility producing sulfuric acid (H 2 SO 4 ) by the contact process by

burning elemental sulfur, alkyl ation acid, hydrogen sulfide, organic sulfides and mercaptans, or acid sludge. A sulfuric acid plant does not include facilities where conversion to sulfuric acid is used primarily as a means of preventing emissions to the atmosphere of sulfur dioxide (SO 2 ) or other sulfur compounds. In general, all NSPS standards require initial notifications, performance tests, and periodic reports. Owners or operators are also required to maintain records of the occurrence and duration of any s tartup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance and are required of all affected facilities. Any owner or operator subject to the provisions of this part will maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance report s , 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 regional office. Approximately 53 sources are currentl y s ubject to the regulation, and it is estimated that no additional respondents per year will become subject to the regulation in the next three years. There are approximately 53 sulfuric acid plants in the United States, which are owned and operated b y the sulfuric acid industry (the “Affected Public”). None of the facilities in the United States are owned b y state, local, tribal or the Federal government; all are privately, owned for

- profit businesses. The burden to the “Affected Public” is listed in Table 1: Annual Industry Burden and Cost

– NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H ) (Renewal). The2

Federal government burden associated with the review of reports submitted by the respondent is shown in Table 2: Average Annual EPA Burden

– NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H ) (Renewal). In the development of the Information C ollection Request (ICR) , we addressed the Office of Management and Budget (OMB) “Terms of Clearance (TOC)” on the active IC R. The TOC are as follows : This colle ction of information is approved fo r 3 years. Before

resubmission of this ICR, the Agenc y s hould update wage estimates, continuing to refer to most recentl y available data from Bureau of Labor Statistics. In addition, the agency should verify the number of respondent entities. EPA has addressed ea ch item of concern in the TOC. The updated labor rates and the number of respondents have been thoroughly checked , and all estimates have been updated.
**2. Need for and Use of the Collection 2(a) Need/Author**  **ity for the Collection** The EPA is charged under s ection 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and environmental impact and energy requirements) the Administrator 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 Admini strator may require any o wner 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 variab les or other indirect data when direct monitoring of emissions is impractical; (F) submit3 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, SO 2 emissions from sulfuric acid plants cause or contribute to air pollution that may reasonabl y b e anticipated to endanger public health or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart H

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. Inaddition, the collected informatio n is used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility’s i nitial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notificatio ns 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 ensure that the pollution control devices are properl y in stalled and operated , that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, to identify prob lems at the facility , and to verify operation/maintenance procedures and compliance.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 60, subpart H. **3(a) Non**
**- dupl**  **ication** If the subject standards have not been delegated, the information is sent directly 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 h as adopted their own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this IC R was published in the Federal Register (7 6 FR 26900 ) on May 9 , 20 11 . No comments were received on the burden published in the Fede ral Register

.4

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

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agenc y’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment o n the burden associated with the stan dard as it was being developed. In dev eloping this ICR, we contacted the United States Census Bureau, General Chemical at (973) 515

- 0900, and Sulfuric Acid Today

at (985) 893

- 8692. It is our polic y t o respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assur ance 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 likely

. **3(e) General Guidelines** These reporting or recordkeeping requirem ents do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with the part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars allows the EPA to establish the compliance history of a source, any pattern of non

- compliance, and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending b eyond the five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any i nformation submitted to the Agency for which a claim of confidentiality i s made will5

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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** The reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are sulfuric acid plants. The United States Standard Industrial Classification (SI C) code for the respondents affected by the standards is SI C 2819 which corresponds to the North American Ind ustry Classification System (NAICS) 325188 for Inorganic Chemical Manufacturing. **4(b) Information Requested** None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. **(i) Data Items**  In this ICR, all the data that is recorded or reported is required b y NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal)

. A source must make the following reports:
**Notifications** Notification of construction/reconstruction 6 0.7(a)(1) Notification of actual startup 60.7(a)(3) Notification of phys ical or operational change 60.7(a)(4) Notification of continuous monitoring sy stem (CMS) demonstration 60.7(a)(5) Initial performance test results 60.8(a) Initial performance tes t 60.8(d) Reference Test Method 9 60.11(b) **Reports** Semiannual report of excess emissions 60.7(c) A source must keep the following records:6
**Recordkeeping** Maintain records of startup, shutdown, or malfunction period where the continuous monitoring s ys tem is inoperative 60.7(b) Maintain records for two years 60.7(f) Maintain annual performance test, as required 60.7(f) Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are not widel y used. At this time, it is estimated that approximately 20 percent of the respondents use electronic reporting. **Respondent Activities** Read instructions. Perform initial performance test, Reference Method 9 test, and repeat performance test if necessary
. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing , acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. D evelop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond t o a collection of information. Transmit, or otherwise disclose the information. Currently , sources are using monitoring equipment that provides parameter data in an automated way (e.g., continuous parameter monitoring s ys tem). Although personnel at th e source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Manage**  **ment**7

**5(a) Agency Activities**
EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary
. Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online tracking Information s ys tem ( OTI S )

. **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y i nstalled and operational

. P erformance test reports are used by

the Agency

to discern a source’s initial capability to comply

with the emission standard, and to note the operating conditions under which compliance was achieved. D ata and records maintained by the respondents are tabulated and published for use in c ompliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. E PA uses OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory

a gencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can edit, store, retrieve , and analyze the data. The records required b y this regulation must be retained by the owner o r operator for two ye ars. **5(c) Small Entity Flexibility** The majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. T o the ex tent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** 8

The specific frequency

f or each information collection activity w ithin this request is shown in Table 1: Annual Industry Burden for NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal). **6. Estimating the Burden and Cost of the Co llection**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed t o be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 8,594 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NSPS program, the previ ously approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $119.36 ($56.84 + 110%) Technical $99.18 ($47.23 + 110%) Clerical $49.35 ($23.50 + 110 %) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2011, "Table 2. Civilian Workers, by Occupational and Industry group." The rates are from column 1, "Total Compensation." The rates have been increased by 1 10 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 s ubject 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.9
**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation and Maintenance (O&M) Costs**  (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)

CMS $120,000 0 $0 $4 ,500 53 $ 238,500 Total $0 $238,500
The total capital/startup costs for this ICR are $0

. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 238,500 . This is the total of column G.
The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the I CR is estimated to be $ 238,500

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

are those costs associated w ith 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 $ 21,974

. This cost is based on the average hourl y labor rate as follows: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) Technical $4 6.21 (GS

- 12, Step 1, $28.88 + 60%) Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%)
These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality

rates of pay . The rates have been increased by 60 percent to a ccount for the benefit packages available to government emplo ye es
. Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden, NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal)

. **6(d) Estimating the Responden t Universe and Total Burden and Costs**  Based on our research for this ICR, on average over the next three years, approximately 5 310

existing respondents will be subject to the standard. It is estimated that no additional respondent per year will become sub

ject to the standard . The overall average number of respondents, as shown in the table below, is 53 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

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 0 53 0 0 53 2 0 53 0 0 53 3 0 53 0 0 53 Average 0 53 0 0 53

1 New respondent s include sources with constructed, reconstructed , and modified affected facilities. To avoid double

- counting respondents , column D is subtracted. As shown above, the averag e Number of Respondents over the three

- ye ar period of this ICR is 53

. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

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

Total Annual Responses E=(BxC)+D

Notification of construction or modification 0 1 0 0 Notification of actual startup 0 1 0 0 Notification of physical or ope rational change 0 1 0 0 Notification of demonstration of CMS 0 1 0 0 Notification of initial performance test 0 1 0 0 Semiannual report of excess emissions 53 2 0 106 Total 106 The number of Total Annual Responses is 106

. The total annual labor c osts are $ 822,650 . Details regarding these estimates may be found in Table 1: Annual Industry Burden and Cost

– NSPS for Sulfuric Acid Plant s (40 CFR Part 60, Subpart H) ( Renewal).11

**6(e) Bottom Line Burden Hours 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 8,594 . Details regarding these estimates may be f ound in Table 1 : Annual Respondent Burden and Cost: NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 81 hour s per response. The total annual capital/startup and operation and maintenance ( O&M ) costs to the regulated entity are $ 237,500

.

**(ii) The Agency Tally** The average annual Agency burden and cost over the next three years is estimated to be 488 labor hour s at a cost of $ 21,974 . See Table 2 : Annual Agency Burden and Cost: NSPS for Sulfuric Acid Plants (40 CFR Part 63, Subpart H) (Renewal)

. **6(f) Reasons for Change in Burden** The adjustment decrease in burden from the most recentl y approved ICR is due to a more accurate estimate of existing and anticipated new sources. After consulting the Offi ce of Air Quality Planning and S tandards (OAQPS) and trade associations, our data indicates that there are approximately fifty- three sources subject to the rule, as compared with the active I CR that shows one hundred and three sources. There are no new facilities expected to be constructed over the next three years of this ICR. The decline in the number of sources is partially due to: 1) plant closures, as the cost to retrofit aging facilities increased due to the down turn in the economy; 2) corporate mergers; and 3) foreign competition. Therefore, there is a net decrease in the burden to industry

. Because there are no new sources with reporting requirements, no c apital/startup costs are incurred. The only

cost that is incurred is for the O&M of the monitoring equipment

. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 81 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acqui re, 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;12

adjust the existing way s to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not c onduct 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 A gency's need for this information, the accuracy of the provided burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docke t ID Number EPA

- HQ

- OECA

- 20 11

- 02 17

. 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 content of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search” than 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 In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., Washington, D

. C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 1927

. Also, yo u can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, D

. C

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

- HQ

- OECA

- 20 11

- 02 17 and OMB Control Number 2060

- 0041 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.**Table 1: Annual Respondent Burden an d Cost** 

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

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

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

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

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

**Techni cal**  **person**   ** hours per** **year (E=CxD)**  **(F)**

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

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

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

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions c 1 1 1 0 0 0 0 $0 B. Required activities Initial performance tests d 300 1 300 0 0 0 0 $0 Reference Method 9 test e 4 1 4 0 0 0 0 $0 Repeat of performance tests f 300 1 300 0 0 0 0 $0 C. Create information See 3B D. Gather existing information See 3B E. Write Report Application of construction or modification 2 1 2 0 0 0 0 $0 Notification of actual startup 2 1 2 0 0 0 0 $0 Notification of physical or operational change 2 1 2 0 0 0 0 $0 Notification of demonstration of CMS 2 1 2 0 0 0 0 $0 Notification of initial performance test 2 1 2 0 0 0 0 $0 Semiannual report of excess emissions g 40 2 80 5 3 4 ,240 212 424 $ 466,751.92 Subtotal for Reporting Requirements 4,876 4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities See 3A C. Implement Activities See 3A D. Develop record system N/A E. Time to enter information Records of operating parameters h 0.25 350 8 53 424 21 .2 42 .4 $ 46,675.19 Record of conversion factors/calculation i 0.05 1,050 53 53 2,809 140.45 280.9 $ 309, 223.14 F. Time to train personnel N/A G. Time for audits N/A Subtotal for Recordkeeping Requirements 3,717.95 **Subtotals :**  **Labor Burden and costs** 7,473 373.65 747.3 $ 822,650.2514

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

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

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

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

**Techni cal**  **person**   ** hours per** **year (E=CxD)**  **(F)**

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

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

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

**TOTAL LABOR BURDEN AND COST (rounded)**  8,593.95 8,594 (rounded) $ 822,650

**Assu mptions:**  a We have assumed that there are approximately 5 3 respondents, with no a dditional ne w o r reconstructed sources becoming subject to the rule over the next three years. b This ICR uses the following labor rates: $ 119.36 per hour for Executive, Administrative, and Managerial labor; $99.18 per ho ur for Technical labor, and $49 .35 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2 011, Table 2. Civilian Workers, by Occupational and Industry groups. The rates are from column 1, Total Compensation. The rat es have been increased by 110 percent to account for the benefit packages available to those employed by private industry. c We have assumed that it will take one hour for each respondent to read instructions. d We have assumed that it will take 300 hour s for each respondent to complete an initial performance test. e We have assumed that it will take four hours for each respondent to complete a reference Method 9 test. f We have assumed that it will take 300 hours to repeat performance test due to failures. g We have assumed that it will take 40 hours , twice a year , for each respondent to w rite an excess emission report. h We have assumed that each respondent will enter information on records of operating parameters 350 times per year. i We have assumed that all information is entered on a weekly basis. j We have assumed that records of conversion factors will be recorded three time s daily , at 350 days per year , for a total of 3x350=1,050 times per year.15

**Table 2: Average Annual EPA Bur den** 
**- NSPS for Sulfuric Acid Plants**  **(40 CFR Part 60, Subpart H) (Renewal)**

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

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

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

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

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

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

**Cost, $ b** 

New facility Initial performance test c 50 1 50 0 0 0 0 $0 Repeat performance test/observed d 24 1 24 0 0 0 0 $0 Revie w reports Notification of construction 2 1 2 0 0 0 0 $0 Notification of actual startup 0.5 1 0.5 0 0 0 0 $0 Notification of initial test 0.5 1.2 0.6 0 0 0 0 $0 Review test results 8 1.2 9.6 0 0 0 0 $0 Notification of C MS demonstration 0.5 1 0.5 0 0 0 0 $0 Existing facility 0.5 1 0.5 0 0 0 0 $0 Excess emission reports e 4 2 8 53 424 21.2 4 2.4 $ 21,973.58 Subtotals Labor Burden and cost 424 2 1.2 4 2.4 $ 21,973.58 **TOTAL ANNUAL BURDEN AND COST (rounded)**  4 8 7.6 48 8 (rounded) $ 21,974

**Assu mptions:**  a We have assumed that there are approximately 5 3 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS

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

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

- 6, Step 3, $15.63 1.6). These rates are from the Office of Personnel Management (OPM) A 2011 General Schedule @ which excludes locality rates of pay.
c We have assumed that it will take fifty hours for each respondent to perform the initial performance test. d We have ass umed that it will take twenty

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