**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR Part 63, Subparts AA and BB) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the**  **Information Collection** NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR Part 63, Subparts AA and BB) (Renewal), EPA ICR Number 1790.06 , O MB Control Number 2060

- 0361 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production were proposed on December 27, 1996 , promulgated on June 10, 1999 , and amended on both June 12, 2002 , and April 20, 2006 . These standards appl y to either owners or operators of new and existing phosphoric acid manufacturing and phosphate fertilizers production facilities that are major sources . The rule applies to component processes at these facilities and to any new, mo dif

ied, or reconstructed sources. Component processes include the following facilities: wet process phosphoric acid plants, super

- phosphoric acid plants, purified phosphoric acid plants, phosphate rock dryers, phosphate rock calciners, diammonium and mono ammonium phosphate plants, and granular tripl e superphosphate (GTSP) plants. Since man y of the facilities affected b y the standards also are subject to new source performance standards (NSPS), the standards include an exemption f

rom the NSPS for those sources. The exemption eliminates a duplication of information collection requirements

. New facilities include those that commenced construction, modification, or reconstruction after the date of proposal. This information is being collected to assure comp liance with 40 CFR part 63, subparts AA and BB. In general , all NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining complia nce, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurement s, maintenance reports, and records. All reports are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office

. Based on our consultations with industry representatives during a previous renewal, there is an average of one affected facilities at each plant site and that each plant site has only one2

respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an average of 12 respondents per ye ar will be subject to the standard , and no additional respondents will become subject to the standard s annually

. The Office of Management and Budget (OMB) approved the currentl y active I CR without any

“ Terms of Clearance ”. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Productio n (40 CFR Part 63, Subparts AA and BB) (Renewal)

. The burden to the “Federal Government” is attributed entirely to work performed by

F ederal emplo ye es or government contractors; this burden may be found below in Table 2: Average Annual EPA Burden and Cost

- NESHAP for Phosphoric Acid Manufacturing and P hosphate Fertilizers Production (40 CFR Part 63, S ubparts AA and BB) (Renewal)

. **2. Need for and Use of the Collection**  **2(a) Need/Authority for the Collection** The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction

. Inaddition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep re cords on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and ( G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, hazardous air pollutants (HAPs) emissions from phosphoric acid manufacturing and phosphate fertilizers production plants cause or contribute to air pollution that may

reasonably

be ant icipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this sourc e category at 40 CFR part 63, s ubparts AA and BB

.3

**2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard s ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in ord er to determine an affected facility ’ s initial capability to comp ly

with the emission standards. Continuous emission monitors are used to ensure compliance with the standards at all times. During the performance test 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 standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control de vices are p roperl y installed and operated, leaks are being detected and repaired and the standards is being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify prob lems at the facility , verify operation/maintenance procedures and for compliance determinations.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are re quired under 40 CFR part 63 , subparts AA and BB

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a 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, dup lication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (77 FR 63813) on October 17, 2012 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency

has consulted i ndustry

experts and internal data sources to project4

the number of affected facilities and industry growth over the next three years. The primary source of information as reported b y 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 EPA’ s Office of Compliance. OTIS is EPA ’ s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Approximately 12 respondents will be subject to the standard over the three ye ar period covered by this ICR.
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 and the standard has been previously

reviewed to determine the minimum information needed for compliance purposes. In developing this I CR, we contacted : 1) the Fertilizer Institute at , (202) 962

- 0490 ; and 2) the PCS Phosphate Company , at (847) 849

- 4322. 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 f irst Federal Register n otice. In this case, no comments were received

. **3(d) Effects of Less Frequent Collec**  **tion** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements 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. EPA believes that the five

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

- ye ar statute o f limitations on which the permit program is based. T he retention of records for five years allow s EPA to establish the compliance history of a source , an y 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 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 informatio n submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2,5

subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, Sept ember 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**
T he 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 phosphoric acid manufacturing and phosphate fertilizers production facilities . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards is SI C 2874 , which corresponds to the North American Industry Classification S ys tem (NAI CS ) code 325312 for Phosphatic Fertilizer Manufacturing

. **4(b) Information Requested (i)**  **Data Items**
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR Part 63, Subparts AA and BB). A source must make the following reports:
**Notifications** Notification and application of construction/reconstruction 63.5(d) Notification of initial startup 63.09(b), 63.607, and 63.627 Notification of initial performance test 63.7(b), 63.9(e), 63.607, and 63.627 Extension of compliance 63.607, 63.627, and 63.9(c) Special compliance requirements 63.607, 63.627, and 63.9(d) Waiver of performance testing 63.607, 63.627, and 63.7(h) Notification of compliance status 63.607, 63.627, and 63.9(h)6 **Reports** Initial performance test report 63.607(a)(1), 63.627(a)(1), and 63.10(d) Semiannual report 63.10(e) and 63.607(c)(2) Quarterl y report 63.10(e) and 63.607(c)(2) Annual report 63.10(e) and 63.607(c)(1) A source must keep the following records: **Recordkeeping** Performance test report 63.607(b)(1), 63.627(b)(1), and 63.10(b) Excess emissions report. 63.607(b)(2), 63.627(b)(2), and 63.10(b) Summary report 63.607(b)(3), 63.627(b)(3), and 63.10(b) Reports and notifications 63.10(b) Records retained for 5 ye ars 63.10(b)(1)
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 still not widely used. At this time, it is estimated that approximately 2 0 percent of the respondents use electronic reporting.

**(ii) Respondent Activi ties** 

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate devices for HAPs. Perform initial performance test, Reference Methods 5 and 13 test, and repeat performance tests if necessary

. Perform annual performance test. Write the notifications and reports listed above.7 **Respondent Activities** 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. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with an y 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 and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem )

. Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduce d the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following activities in connection with the acquisition, 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, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (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 installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to8

comply with the emission standard and 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.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA ’ s Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement by

local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A 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 d evelopment of the regulatio n. 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 requ irements 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. The exact number of small ent ities affected b y this rule could not be determined based on a review of available documents related to the rule, including the full text of the Final Rule (60 FR 62930). A ccording to both the Final Rule and the Wood Manufacturing Operations (NESHAP Impl ementation Document (EPA

- 456/R

- 97

- 005, updated March 2004), additional mechanisms for exempting smaller sources from the standards were put in place. The Implementation Document states: “In order to lessen the burden on ... small sources ... the EPA include d material usage and emission limits in the NESHAP

. Facilities below these limits are designated b y rule as area sources and are therefore not subject to the NESHAP.” **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown in below Table 1: Annual Respondent Burden and Cost

– NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR Part 63, Subparts AA and BB) (Renewal).9

**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 each of the subpart s included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver 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 requirement s is estimated to be 1, 76 5 ( Total Labor Hours from Table 1 below ). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program , the previousl y approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and O peration and Maintenance Costs**  The ty pe of industry

costs associated with the information collection activities in the subject standards are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital/startup costs are one ti me costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs such as photocopying and postage.10 **(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)
Tem perature mo nitoring device $2,700 0 $0 $886 12 $10,632
The total capital/startup costs for this I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 10,632

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $10,632. These are the costs of recordkeeping

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

are those costs associated with anal ys is of the reported information. EPA’ s overall compliance and enforcement program includes activities such as the examination of records maintained b y 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 i s estimated to be $ 55 , 017

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees
. Details upon which this estim ate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR Part 63, Subparts AA and BB) (Renewal).11

**6(d) Estimating the Respondent Universe and Total Burden and Costs**  Based on our research for this I CR, on average over the next three ye ars, approximately 12 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject

. The overall av erage number of respondents, as shown in the table below, is 12 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 Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 12 0 0 12
2 0 12 0 0 12
3 0 12 0 0 12 Average 0 12 0 0 12 1 New respondent include sources with constructed, reconstructed and modified affected facilities. Column D is subtracted t o avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 12. The total number of annual responses per ye ar is calculated using the following table:12 **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

Notification of construction/reconstruction 0 0 0 0 Notification of i nitial p erformance t est 0 0 0 0 Notification of compliance status 0 0 0 0 Annual p erformance t est report 12 1 0 12 Quarterly reports of excess emissions 1

. 2 4 0 4.8 Semiannual r eport of no excess emissions 10.8 2 N/A 2 1.6 Startup/Shutdown/Malfunction Report 1 1 N/A 1 Total 39.4
The number of Total Annual Responses is 39

. The total annual labor costs are $1 70 , 9 49

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

– NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR Part 63, Subparts AA and BB) (Renewal). **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y , and summarized below. **(i) Respondent Tally** The total annual labor hours are 1 , 76 5 at a cost of $170, 9 49

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR Part 63, S ubparts AA and BB) (Renewal). Furthermore, the annual public repo rting and recordkeeping burden for this collection of information is estimated to average 45 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $10,632

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.13 **(ii) The Agency Tally**  The average annual Agency burden and cost over next three years is estimated to be 1, 221 labor hours at a cost of $ 55 , 017 . See below T able 2: Average Annual EPA Burden and Cost

– NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR part 63, subparts AA and BB) (Renewal). **6(f) Reasons for Change in Burden** There is an increase in burden for both the respondents and the Agency due to an adjustment. This increase is not due to any program changes. The previous I CR assumed the per - respondent burden hour for each activity is inclusive of all technical, managerial, and clerical hours. This I CR assumes the per

- respondent burden hour includes technical hours only , and that managerial and clerical hours are additional 5 and 10 percent of technical hours, respectivel y. In addition, this I CR uses updated labors rates available from the Bureau of Labor Statistics to calculate burden costs

. This results in an adjustment increase in both labor hours and costs. Additionally , there is a decrease in the estimated number of responses due to a correction. The previou s ICR assumed that each respondent would have to submit annual, semiannual, and quarterl y reports, or a total of seven reports per ye ar, which is inconsistent with the assumptions used to calculate respondent reporting burden. This I CR corrects the number of responses and clarifies that quarterl y reports are onl y required if there are excess emissions. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 45 h ours per respo nse. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, ins tall, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applica ble instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. 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 I CR under EPA

- HQ

- OECA

- 2 012

- 0676. An electronic version of the public docket is available at14

http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the doc ket, and to access those documents in the public docket that are available electronicall y. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, e xcluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2012

- 0676 and OMB Control Number 2060

- 0361 in any correspondence. **Part B of the Supporting Statement** This part i s not applicable because no statistical methods were used in collecting this information.15

**Table 1: Annual Respondent Burden and Cost**

**– NESHAP for**  **Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40 CFR**  **P art**  **63, S**  **ubparts AA and BB) (Renewal).**

**Burden item (A)**  **(B) (C)**  **(D) (**  **E )**  **( F**  **) (**  **G )**  **( H** **) Technical**  **Hours per Occurrence**  **Occurrences**

**per respondent**  **per year Person** 

**h ours**  **per r**  **espondent per**  **year (C = AxB)**  **Respondents**

**per year Technical** 

**person hours per**  **y ear**  **(E = Cx D)**  **a Managerial** 

**person hours**  **per y ear**  **(F = Ex**  **0.05) a**  **Clerical**

**person hours**  **per y ear**  **(G = Ex 0.1)**  **a Total** 

**Cost per**  **year($)** 1. Applications N/A 2. Survey and Studies N/A 4. Reporting Requirements A. Read instructions 4 1 4 0 0 0 0 $0 B. Required activities Initial performance test 28 1 28 0 0 0 0 $0 Repeat initial performance test 28 0.1 2.8 0 0 0 0 $0 Startup, shutdown, malfunction plan 40 1 40 0 0 0 0 $0 Annual performance test b 28 1 28 12 336 16.8 33.6 $37,414.61 Repeat annual performance test c 28 0.2 5.6 1 5.6 0. 28 0. 56 $ 6 23. 57 C. Create information See 4B D. Gather existing information See 4B E. Write report j Notification of applicability N/A Notification of construction./ reconstruction 2 1 2 0 0 0 0 $0 Notification of actual startup N/A Notification of compliance requirements N/A Notification of performance test 2 1 2 0 0 0 0 $0 Notification of compliance status 4 1 4 0 0 0 0 $0 Report of performance test See 4B Report mo nitoring exceedances d 16 4 64 1.2 76.8 3.84 7.68 $8,551.9116

Report of no excess emissions e 8 2 16 10.8 172.8 8.64 17.28 $19,241.80 Startup/ shutdown/ malfunction report f 8 1 8 1 8 0.4 0.8 $890.82 **Subtotal for Reporting 68**  **9 $66,**  **7 22.**  **71** 5. Recordkeeping Requirements A. Read instructions 4 1 4 0 0 0 0 $0 B. Plan activities See 5E C. Implement activities See 5E D. Develop record system See 5E E. Time to enter information Records of operating parameters b 1.5 g 52 h 78 12 936 46.8 93.6 $104,226.41 F. Time to train personnel i N/A G. Time to comply with applicable requirements See 4B H. Time for audits N/A **Subtotal for Recordkeeping**  **1,076 $104,226.41**  **TOTAL ANNUAL BURDEN and COST**  **(rounded) 1,76**  **5 $170,**  **9 49**  Assumptions:
a This ICR assume s that managerial hours are 5 percent of t echnical h ours, and clerical hours are 10 percent of t echnical hours. This ICR uses a labor rate of $121.44 for managerial hours, $100.23 for technical hours, and $50.51 for clerical hours

. b We have a ssume d that the average of respondents that will be subject to the rule will be twelve. There will be no additional new sources per year that will become subject to the rule over the three

- year period of this ICR.
c We have assumed that 7 percent of respondents (12x7%= 0.84/ rounded to 1) will fail the initial performance test and must repeat it. d We have a ssume d that 10 percent of respondents will report exceedances. Respondents are required to report quarterly.
e We have a ssume d that 90 percent of existing respondents report no excess emissions semiannually. f We have a ssume d that 1 of 12 sources will have to submit a startup, shutdown, or malfunction report. g We have a ssume d that it will take 1.5 hours per respondent to enter information. h We have a ssume d that information is entered one

- time per week for 52 weeks per year. i There are no hours for training personnel sinc e no tr aining is required by the rule and hours have been allotted under 5A for reading and understanding the recordkeeping/reporting requirements.17

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertil**  **izers Production (40 CFR**  **P art**  **63, S**  **ubparts AA and BB) (Renewal)**

**Burden Item (A)**  **(B) (C)**  **(D) (E)**  **(F) (G)**  **(H)**

**Person hours per**  **Occurrence No. of** 

**occurrences per**  **respondent per**  **year P**  **erson**

**hour s**  **per respondent**  **per year**  **(C=AxB) Respondents** 

**per year Technical** 

**person hours per**  **year (E =**  **Cx D)**  **Managerial**

**person hours per**  **year (F =**  **Ex 0.05)**  **Clerical**

**person hours per**  **year (G =**  **Ex 0.1)**  **Total**

**Cost per**  **year a**  Initial performance test 40 1 40 0 0 0 0 $0 Repeat initial performance test Retesting preparation 8 1 8 0 0 0 0 $0 Retesting 40 1 40 0 0 0 0 $0 Excess e missions e nforcement a ctivities N/A Report r eview Notification of applicability 2 1 2 0 0 0 0 $0 Notification of construction./reconstruction N/A Notification of anticipated startup N/A Notification of actual startup N/A Notification of special compliance requirements N/A Notification of initial performance test 2 1 2 0 0 0 0 $0 Notification of compliance status 2 1 2 0 0 0 0 $0 Annual performance test 40 1 40 12 480 24 48 $24,875.76 Repeat annual performance test 40 1 40 0.84 33.6 1.68 3.36 $1,741.30 Excess emissions report 20 4 80 1.2 96 4.8 9.6 $4,975.15 No excess emissions report 20 2 40 10.8 432 21.6 43.2 $22,388.18 Waiver application N/A 0 0 0 $0 Startup, shutdown, malfunction report 20 1 20 1 20 1 2 $1,036.49 **TOTAL ANNUAL BURDEN**  **AND COST (rounded)**  **1,221 $55,01**  **7**

**Assu mptions:** 18

a The cost is based on rates from the Office of Personnel Management (OPM) “ 20 12 General Schedule ” which excludes locality rates of pay. b We have a ssume d that the average of respondents that will be subject to the rule will be 12. There will be no additional new sources per year that will become subject to the rule over the three

- year period of this ICR.
c We have assumed that 7 percent of respondents will fail the initial performance test and must repeat it. d We have a ssume d that 10 percent of respondent will report exceedances. Respondents are required to report quarterly.
e We have a ssume d that 90 percent of existing respondents report no excess emissions semiannually. f We have a ssume d that 1 of 12 sources will have to submit startup, shutdown, or malfunction report.