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 ICR Number 1057.12, OMB Control Number 2060-0041

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Sulfuric Acid Plants (40 CFR Part 60, 

Subpart H), were proposed on August 17, 1971, promulgated 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 apply 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 (H2SO4) by the contact process by burning

elemental sulfur, alkylation 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 (SO2) 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 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.

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 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 regional office.

Approximately 53 sources are currently subject 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 by the sulfuric acid industry (the “Affected Public”). None of the facilities in the United 

States are owned by 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). The 
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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 Collection Request (ICR), we addressed the Office 

of Management and Budget (OMB) “Terms of Clearance (TOC)” on the active ICR. The TOC are 

as follows:

This collection of information is approved for 3 years. Before 

resubmission of this ICR, the Agency should update wage estimates, 

continuing to refer to most recently available data from Bureau of 

Labor Statistics. In addition, the agency should verify the number 

of respondent entities.

EPA has addressed each 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/Authority for the Collection

The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 

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

four years. 

In addition, section 114(a) states that the Administrator may require any owner 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 

when direct monitoring of emissions is impractical; (F) submit 
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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, SO2 emissions from sulfuric acid plants cause or 

contribute to air pollution that may reasonably be 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. In addition, 

the collected information is 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. 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 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 ensure that the pollution control devices are properly 

installed 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 problems 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-duplication

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

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

or local agency. If a state or local agency has adopted their 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, 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 ICR was published in 

the Federal Register (76 FR 26900) on May 9, 2011. No comments were received on the burden 

published in the Federal Register.
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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 (OTIS) 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 Agency’s internal industry experts.

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

comment on the burden associated with the standard as it was being developed. In developing this 

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 policy to respond after a thorough review of comments received since the last ICR 

renewal as well as those submitted in response to the first Federal Register notice.

3(d) Effects of Less Frequent Collection

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

are continuing to meet the standards. Requirements for information gathering and recordkeeping 

are useful techniques to ensure that good operation and maintenance practices are applied and 

emission limitations are met. If the information required by these standards was collected less 

frequently, the proper operation and maintenance of control equipment and the possibility of 

detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR 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. EPA believes that the five-year records retention requirement is consistent with the part 

70 permit program and the five-year statute of limitations on which the permit program is based. 

The retention of records for five years 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 beyond the five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will 
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be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B -

Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, 

March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

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 (SIC) code for the respondents affected by the 

standards is SIC 2819 which corresponds to the North American Industry 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 by NSPS for Sulfuric Acid 

Plants (40 CFR Part 60, Subpart H) (Renewal).

A source must make the following reports:

Notifications

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

Notification of actual startup 60.7(a)(3)

Notification of physical or operational change 60.7(a)(4)

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

Initial performance test results 60.8(a)

Initial performance test 60.8(d)

Reference Test Method 9 60.11(b)

Reports

Semiannual report of excess emissions 60.7(c)

A source must keep the following records:
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Recordkeeping 

Maintain records of startup, shutdown, or malfunction period where 

the continuous monitoring system 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 

systems to transmit data electronically. However, electronic reporting systems are not widely 

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 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of 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.

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 system). Although personnel at the source 

still need to evaluate the data, this type of monitoring equipment has significantly reduced the 

burden associated with monitoring and recordkeeping.

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management
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5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, 

and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online tracking Information system (OTIS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operational. Performance 

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. Data 

and records maintained by the respondents are tabulated and published for use in compliance and 

enforcement programs. The semiannual reports are used for problem identification, as a check on 

source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS 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. EPA uses OTIS for tracking air pollution compliance and enforcement by local and state 

regulatory agencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can 

edit, store, retrieve, and analyze the data.

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

years.

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 types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, the 

overall burden will be reduced.

5(d) Collection Schedule
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The specific frequency for each information collection activity within 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 Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

concept of burden under the Paperwork Reduction Act. 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 previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR 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 110 percent to account for the 

benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

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

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs, such as photocopying and postage.
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(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 ICR are $238,500. This is the 

total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry 

over the next three years of the ICR is estimated to be $238,500.

6(c) Estimating Agency Burden and Cost

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

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

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

emissions; and the publication and distribution of collected information.

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

$21,974.

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (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 account for the 

benefit packages available to government employees. 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 Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately 53 
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existing respondents will be subject to the standard. It is estimated that no additional respondent 

per year will become subject 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 

years covered by 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 respondents include sources with constructed, reconstructed, and modified affected facilities.

To avoid double-counting respondents, column D is subtracted. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 53.

The total number of annual responses per year 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 operational 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 costs are $822,650. Details regarding these estimates may be found 

in Table 1: Annual Industry Burden and Cost – NSPS for Sulfuric Acid Plants (40 CFR Part 60, 

Subpart H) (Renewal).
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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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 8,594. Details regarding these estimates may be found in 

Table 1: Annual Respondent Burden and Cost: NSPS for Sulfuric Acid Plants (40 CFR Part 60, 

Subpart H) (Renewal). 

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

information is estimated to average 81 hours 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 hours 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 recently approved ICR is due to a more 

accurate estimate of existing and anticipated new sources. After consulting the Office of Air 

Quality Planning and Standards (OAQPS) and trade associations, our data indicates that there are 

approximately fifty-three sources subject to the rule, as compared with the active ICR 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 capital/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, acquire, 

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

information, processing and maintaining information, and disclosing and providing information; 
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adjust the existing ways to comply with any previously applicable instructions and requirements; 

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

and review the collection of information; and transmit or otherwise disclose the information.

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

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

Numbers for EPA’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-OECA-2011-0217. 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 

system, 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 

Information 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 holidays. 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, 

you 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-2011-0217 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 and 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)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

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 c1 1 1 0 0 0 0 $0

 B. Required activities

 Initial performance tests d300 1 300 0 0 0 0 $0

 Reference Method 9 test e4 1 4 0 0 0 0 $0

 Repeat of performance tests f300 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 g40 2 80 53 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 h0.25 350 8 53 424 21.2 42.4 $46,675.19

 Record of conversion factors/calculation i0.05 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 $822,650.25
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Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

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

Assumptions:

 a We have assumed that there are approximately 53 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three 

years.

 b

 This ICR uses the following labor rates: $119.36 per hour for Executive, Administrative, and Managerial labor; $99.18 per hour 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 2011, Table 2. Civilian Workers, by 

Occupational and Industry groups. The rates are from column 1, Total Compensation. The rates have been increased by 110 percent to account for the benefit 

packages available to those employed by private industry.

c

 We have assumed that it will take one hour for each respondent to read instructions.

d

 We have assumed that it will take 300 hours for each respondent to complete an initial performance test.

e

 We have assumed that it will take four hours for each respondent to complete a reference Method 9 test.

f

 We have 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 write an excess emission report.

h We have assumed that each respondent will enter information on records of operating parameters 350 times per year.

i 

 We have assumed that all information is entered on a weekly basis.

j 

 We have assumed that records of conversion factors will be recorded three times daily, at 350 days per year, for a total of 3x350=1,050 times per year.
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Table 2: Average Annual EPA Burden - NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrence

s per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

New facility

 Initial performance test c50 1 50 0 0 0 0 $0

 Repeat performance test/observed d24 1 24 0 0 0 0 $0

Review reports

 Notification of construction 2 1 2 0 0 0 0 $0

 Notification of actual startup 0.5 1 0.5 0 0 0 0 $0

 Notification of initial test 0.5 1.2 0.6 0 0 0 0 $0

 Review test results 8 1.2 9.6 0 0 0 0 $0

 Notification of CMS demonstration 0.5 1 0.5 0 0 0 0 $0

 Existing facility 0.5 1 0.5 0 0 0 0 $0

 Excess emission reports e4 2 8 53 424 21.2 42.4 $21,973.58

Subtotals Labor Burden and cost 424 21.2 42.4 $21,973.58

TOTAL ANNUAL BURDEN AND COST 

(rounded)

487.6

488 (rounded)

$21,974

Assumptions:

 a

 We have assumed that there are approximately 53 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next

 three years. 

b

 This 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) A2011 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 assumed that it will take twenty-four hours for each respondent to repeat the performance test due to failure.

e

 We have assumed that it will take four hours, twice per year, for each respondent to review the excess emission reports.