SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)
1. Identification of the Information Collection 1(a) Title of the Information Collection NSPS for Ammonium Sul fate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal) EPA I CR Number 1066.06, OMB Control Number 2060

- 0032 1(b) Short Characterization/Abstract The New Source Performance Standards (NSPS) for Ammonium Sulfate Manufacturing Plants were propose d on February 4, 1980, and promulgated on November 12, 1980. These standards apply

to each ammonium sulfate dryer within an ammonium sulfate manufacturing plant in the caprolactam by

- product, sy nthetic, and coke oven by

- products sectors of the ammonium su lfate manufacturing industry for which construction, modification or reconstruction commenced after the date of the proposal. Owners or operators of the affected facilities described must make the following one - time

- only

reports: notification of the date of construction or reconstruction; notification of the anticipated and actual dates of startup; notification of any phy sical or operational change to an existing facility

which may

increase the regulated pollutant emission rate; and the notification of th e date of the initial performance test. 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 . These notifications, reports and records are required, in general, of all sources subject to NSPS. Recordkeeping requirements specific to the ammonium sulfate industry provides information on the amount of ammonium sulfate processed and the operation of the emission control device. Owners or ope rators of affected facilities are required to install, calibrate, maintain, and operate a flow monitoring device which can be used to determine the mass

- flow of ammonium sulfate feed material to the process, and which has an accuracy of plus or minus 5 per cent across its operating range. However, if the plant uses weight scales of the same accuracy to directly

measure production rates of ammonium sulfate, the use of flow monitoring devices is not required. Owners or operators of all affected facilities wi ll install, calibrate, maintain, and operate a monitoring device which continuously measures and permanently records the total pressure drop across the emission control sy stem. Therefore, the recordkeeping requirements for ammonium sulfate plants consist of the occurrence and duration of all startups and malfunctions as described, the initial performance test results, amount of ammonium sulfate feed material, and the pressure drop across the emission2

control sy stem. Records of startups, shutdowns and malf unctions will be noted as they occur. Records of the performance test should include information necessary to determine the conditions of the performance test, and performance test measurements (including pressure drop across the emission control sy stem) and results. The continuous monitoring sy stem (CMS) will record pressure drop across the scrubbers continuously and automatically

. The reporting requirements for this industry include the initial notifications listed and the initial performance test resu lts. 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 Environmental Protection Agency (EPA) regional office. Notifications are used to inform the Agency or delegated authority

when a source becomes subject to the standard. The reviewing authority may then inspect the source to ensure that the pollution control devices are properly installed and operated, and the standard is being met. Performance test records are needed as these are the Agency

records of a source's initial capability to comply

with the emission standard. Owners or operators of the affected facilities described are required to adhere to reporting requirements specific to this rule , e.g., provide information on the operation of emissions control devices. Semiannual excess emissions and monitoring sy stems reports are required to be submitted by

the respondents. Any owner or operator subject to the provisions of this part will maint ain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. These records and reports are essential in determining compliance and are required of all sources subje ct to NSPS. Based on the pre

- existing number of applicable sources, approximately two sources are currently subject to the regulations. Due to the static nature of the industry , it is estimated that no additional sources will become subject to the standa rd over the next three years. This information is based on discussions with EPA personnel knowledgeable about the ammonium sulfate industry . The industry is dominated by

facilities that have been operating prior to the proposed date of the rule (February 4, 1980), and there has been a long

- term static or declining market for the product both domestically and globally . The average annual cost to industry over the next three years of this Information Collection Request (I CR) is estimated to be $23,183.
Th e Office of Management and Budget (OMB) approved the current Information Collection Request (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, NSPS for Ammonium Sul fate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal) . The burden to the “Federal Government” is attributed entirely to work performed by

Federal employees or government contractors; this burden may be found below in Table 2: Average Annual EPA Burden , NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)

.3

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 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 adequately demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the B est D emonstrated T echnology (BDT). Section 111 als o requires that the Administrator review and, if appropriate, revise such standards every four years. Inthe Administrator's judgment, particulate emissions from the ammonium sulfate manufacturing industry

causes or contribute to air pollution that may re asonably

be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart PP. 2(b) Practical Utility/Users of the Data The control of emissions of particulate from ammonium su lfate facilities requires the installation of properly

designed equipment and the operation and maintenance of that equipment. Emissions of particulate from ammonium sulfate facilities are the result of the operation of the affected facilities. The subje ct standards are achieved by the reduction of particulate emissions using control technology and leak detection and repair (LDAR) procedures. The notifications required in the applicable regulations are used to inform the Agency or delegated authority

whe n 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 t hat the regulations are being met. Performance test reports are needed as these are the Agency records of a source’s initial capability to comply

with the emission standards, and serve as a record of the operating conditions under which compliance was ach ieved. The information generated by the monitoring, recordkeeping and reporting requirement described in this I CR is used by the Agency

to ensure that facilities which are affected by NSPS continue to operate the control equipment in compliance with the r egulation. Adequate monitoring, recordkeeping and reporting are necessary to ensure compliance with the applicable regulations, as required by the Clean Air Act. In addition, the information collected from recordkeeping and reporting requirements is used for targeting inspections, and is of sufficient quality to be used as evidence in court.4

3. Non
- duplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 60, subpart PP. 3(a) No n - 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 . I f a state or local agency has a dopted their own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agencies 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 I CR was published in the Federal Register on July 30, 2009 (74 FR 38004). No comments were received on the burden published in the Federal Register

. 3(c) Consultations For this information collection, a previous I CR renewal was used to obtain burden estimates since this I CR renewal was processed under the “Expedited Approach (renew without change)” option. Per this guidance , all data and assumptions from the previous I CR renewal were used as the basis for estimating the hourly and cost burdens associated with this renewal. The I CR renewal for the year 2003 used several different resources to obtain the most recent data av ailable for ammonium sulfate manufacturing plants. The most recent I CR and preparer of the I CR were referenced. The most recent data available (October 30, 2003) on the Air Facility

Sy stem (AFS) database, which is maintained by the Office of Compliance, was accessed. The Office of Compliance Sector Notebook “ Profile of the Inorganic Chemical Industry ”, information from the United States Census Bureau internet website, as well as other web sites covering ammonium sulfate manufacturing were reviewed. The EPA Office of Air Quality Planning and Standards, Information Transfer and Program Integration Division was consulted. In addition, multiple consultations with industry were conducted: the American Agricultural Economics Association (AAEA), Kay Snopek, (5 15) 233

- 3202; American Chemical Society , Hank Whalen, (202) 872

- 8724; Costal Chemical, Ms. Barbara Cabot, (307) 637

- 2700; Agrium, Mr. Robert Williams, (559) 627

- 5553; Florida Department of Environmental Protection (FCEP), Ms. Cindy

Phillips, (850) 921

- 9534 ; and BP Chemicals, Incorporated, Mr. Kevin Sprague, (419) 226

- 1200.5

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 a useful technique to ensure that good operation and maintenance practices are applied and emission limitations are met. I f the information required by these standards was collected less frequently , the l ikelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease. 3(e) General Guidelines None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR Part 13 20, Section 1320.5. 3(f) Confidentiality Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality of B usiness 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 None of the reporting or recordkeeping requirements contain sensitive questions. 4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes The respondents to the recordkeeping and reporting requirements are ammonium sulfate manufacturing facilities. The United States Standard Indu strial Classification (SI C) code for the respondents affected by

the standards is 2873 which corresponds to the North American In dustry Classification Sy stem (NAI CS) code 325311 for ammonium sulfate manufacturing facilities. 4(b) Information Requested
N one 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 All data in this I CR that is recorded and/or reported is required by NSPS for Ammonium Sulfate Manu facturing Plants (40 CFR part 60, subpart PP).6

A source must make the following reports:

Notification Reports Standard Citation by Section Notification of construction or modification 60.7(a)(1) Notification of initial startup 60.7(a)(3) Notification of initial performance test 60.8(d)

Periodic Reports Standard Citation by Section Semiannual report 60.7(c) A source must make the following reports: Recordkeeping In itial performance test results 60.8(a) Startup, shutdowns, and malfunctions 60.8( c) Control device operating parameters (continuous) 60.423 Records should be retained for two years 60.7(f) Electronic Reporting Currently , sources are using monitoring equipment that provides parameter data in an automated way , e.g., a pressure drop and volumetric flow rate. Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. In addition, some regulatory agencies are setting up electronic reporting sy stems to allow sources to report electronically which is reducing the reporting burden. However, electronic reporting sy stems are still not widely used by the regulatory

agencies. It is estimated that approximately 10 perce nt of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities Read instructions. In stall, calibrate, maintain, and operate control devices for particulate matter (PM). Perform initial performance test, Reference Methods 9 and 5, and repeat performance tests if necessary
. Write the notifications and reports listed above. Enter information required to be recorded above.7 Respondent Activities Submit the required reports developing, acquiring, installing, and utilizing technology and sy ste ms 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. Adjust the existing way s to comply with any previously

appli cable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. 5. The Information Collected: Agency Activities, Collection Methodology, and Information Manage ment 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, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, analy

ze, and maintain data in the Air Facility Sy stem (AFS). 5(b) Coll ection Methodology and Management Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, 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 e nforcement programs.
In formation contained in the reports is entered into the AFS which is operated and maintained by

the EPA Office of Compliance. AFS is the EPA database for the collection, maintenance, and retrieval of compliance and annual emission i nventory data for more than 100,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegate d Authorities can edit, store, retrieve and analy ze the data. The records required by this regulation must be retained by the owner or operator for two ye ars.8

5(c) Small Entity Flexibility Currently the number of employees at a ty pical ammonium sulfate plant exceeds the criterion for small business. 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 requirements to be the minimum needed to ensure compliance and, therefore, cannot reduce them fur ther 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 The specific frequency

for each information collection activity within this re quest is shown below in Table 1: Annual Respondent Burden and Cost, NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)

. 6. Estimating the Burden and Cost of the Collection Table 1 documents the computation of individua l 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 to be consistent with the concept of burdens under the Pa perwork Reduction Act. Where 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 display s 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 247 (Total L abor 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 IC R, and any

comments received. 6(b) Estima ting Respondent Costs (i) Estimating Labor Costs
This I CR uses the following labor rates: Managerial $114.77 ($54.65 + 110%) Technical $97.59 ($46.47 + 110%) Clerical $48.26 ($22.98 + 110%)9

These rates are from the U

. S

. Department of Labor, Bure au of Labor Statistics, March 2009, “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 only costs to the regulated industry resulting from information collection activities required by

the subject standard are labor costs. There are no cap ital/startup or operation and maintenance costs.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs The only ty pes of industry

cost associated with the information collection activity in the regulations are labor costs. There are no capita l/startup or operation and maintenance 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)

N/A N/A N/A N/A N/A N/A N/A The total capital/startup costs for this I CR are zero. This is the total of column D in the above table. The devices used to r ecord operating parameters must be installed and maintained by the respondents in order to operate the processing plant efficiently . Therefore, the total operation and maintenance (O&M) costs for this I CR are zero. This is the total of column G. The t otal respondent costs have been calculated as the addition of the capital/startup costs, and the annual operation and maintenance costs. The average annual cost for capital/startup and operation and maintenance cost to industry over the next three years o f the IC R is estimated to be zero. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with analy sis of the reported information. The EPA compliance and enforcement program includes activities such as the ex amination 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 I CR is estimated to be10

$3,010 (rounded). This cost is based on the average hourly labor rate as follows: Managerial $61.36 (GS

- 13, Step 5, $38.35 + 60%) Technical $45.52 (GS

- 12, Step 1, $28.45 + 60%) Clerical $24.64 (GS

- 6, Step 3, $15.40 + 60%)
These rates are from the Office of P ersonnel Management (OPM), 2009 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 be low in Table 2: Average Annual EPA Burden , NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)

. 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our research for this I CR, approximately four ex isting sources are currently subject to the standard. It is estimated that no additional sources will become subject to the regulation in the next three years. Number of respondents is calculated using the following table which addresses the three ye ars covered by

this I CR. Number of Respondents Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records but Do No t Submit Reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 2 0 0 2 2 0 2 0 0 2 3 0 2 0 0 2 Average 0 2 0 0 2 To avoid double

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

- ye ar period of this I CR is two. The total number of annual responses per year is calculated using the following table: Total Annual Responses (A) Number of New Respondents (B)

Number of Reports for New Respondents (C)

Number of Existing Respondents (D)

Number of Reports for Existing Respondents (F)

Number of Existing Respondents That Keep Records but Do Not Submit Reports (E) Total Annual Responses E=(AxB)+(CxD)+F

0 0 2 2 0 411

The number of Total Annual Responses is 4. The total annual labor costs are $23,183 (rounded). Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost, NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renew al)

. Note that the total annual capital and O&M costs to the regulated entity are zero. These costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. 6(e) Bottom Line Burden Hours and Cost Tables The bottom line burden hours and cost tables for both the Agency and the respondents are attached in Tables 1 and 2 , respectively . The annual public reporting and recordkeeping burden for this collection of information are estimated to average 62 hours per response. 6(f) Reasons for Change in Burden There is an apparent increase of one hour in the total labor hours for this I CR. Total labor hours for this I CR is 247 rather than 246 in the previous I CR, because the previous I CR did not round labor hours up to the nearest whole number. There is no change in the per

- respondent labor hours in this I CR compared to the previous I CR. This is due to two considerations. First, the regulations have not changed over the past three years and are not anticipated to change o ver the next three years. Secondly , the growth rate for the respondents is very low, negative or non

existent. Therefore, the labor hours in the previous I CR reflect the current burden to the respondents and are reiterated (with a correction for rounding ) in this I CR. There is an increase in both respondent and Agency costs resulting from labor rate increases from the year 2003 to the year 2009. This I CR uses the year 2009 labor rates because burden and cost calculations in Tables 1 and 2 of this I CR w ere expanded to include managerial and clerical labor rates, and the previous I CR only provided a technical labor rate for the year 2003. This I CR is, therefore, updated to present the most recent available labor rates for each of the three labor categori es. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 62 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate , maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifyin g information, processing and maintaining information, and 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 to a collection of infor mation; search data sources; complete and review the collection of information; and transmit or otherwise disclose12

the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it dis play s 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 metho ds for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket I D Number EPA

- HQ

- OECA

- 2009

- 0527. An electronic version of the public docket is available at http://www .regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically . When in the 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 (EP A/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 docket center is (202) 566

- 1752. 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

- 2009

- 0527 and OMB Control Number 2060

- 0032 in any correspondence. Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.13 TABLE 1: Annual Respondent Burden and Cost, NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)

Reporting / Recordkeeping (A) Hours per Occurrence (B)

Occurrences/ Respondent/ Year (C)

Hours/ Respondent/ Year (C=AxB) (D)

Respondents/ Year (E)

Total Hours/ Year (E=CxD) (F)

Managerial Hours/ Year a (G)

Technical Hours/ Year a (H)

Clerical Hours/ Year a (I)

Cost/ Year b

1. APPLICATIONS Not Applicable
2. SURVEY AND STUDIES Not Applicabl e 3. REPORTING REQUIREMENTS New Sources c A. Read Instructions 1 1 1 0 0 0 0.0 0.0 0 B. Required Activities New Sources c Initial performance test d Ref Method 9 tests f 29.7 4 118.8 0 0 0 0.0 0.0 0 Ref Method 5 f 4 1 4 0 0 0 0.0 0.0 0 Repeat performance test e 4 0.2 0.8 0 0 0 0.0 0.0 0 Existing sources Monitoring of operations and emissions Included in 3F C. Create Information Included in 3B D. Gather Existing Information Included in 3E E. Write Report New Sources Notification of construction/reconstruction 2 1 2 0 0 0 0.0 0.0 0 Notification of actual startup 2 1 2 0 0 0 0.0 0.0 0 Notification of initial performance test 2 1 2 0 0 0 0.0 0.0 014 TABLE 1: Annual Respondent Burden and Cost, NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)

Reporting / Recordkeeping (A) Hours per Occurrence (B)

Occurrences/ Respondent/ Year (C)

Hours/ Respondent/ Year (C=AxB) (D)

Respondents/ Year (E)

Total Hours/ Year (E=CxD) (F)

Managerial Hours/ Year a (G)

Technical Hours/ Year a (H)

Clerical Hours/ Year a (I)

Cost/ Year b

Notification of demonstration of CMS 2 1 2 0 0 0 0.0 0.0 0 Report of initial performance test Included in 3B Existing Sources Notification of operational change 2 1 2 0 0 0 0.0 0.0 0 Semiannual reports 16 2 32 2 64 3 55.7 5.6 6,019.03 Subtotal Reporting 64 $6,019 4. RECORDKEEPING REQUIREMENTS
A. Read Instructions Included in 3A
B. Plan Activities Included in 3B
C. Implement Activities Included in 3B
D. Develop Record System Not Ap plicable E. Tim e to Enter Information Records of operating parameters f 0.25 365 91.25 2 182.5 8 158.7 15.9 17,163.65
F. Audits Not Applicable Subtotal Recordkeeping 183 $17,164
TOTAL ANNUAL BURDEN (rounded) 247 $23,183 Assumptions15

a. This ICR assumes that Managerial hours are 5 percent of Technical h ours, and Clerical hours are 10 percent of Technical hours. b. We a ssume a technical labor rate of $97.59, managerial rate $114.77, and clerical rate of $48.26 from the United States Department of Labor, Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by occupational and industry group.” Workers by Occupational and Industry Group. The rates are from column 1: Total compensation . The w age rate obtained from the table has been increased by 110 percent to account for the benefit packages available to those employed by private industry. c
. We a ssume that there will be no new s ources (respondents) over the 3

- year period of this ICR

. d

. As specified in the general provisions each performance test shall consist of three separate runs using the applicable test m ethod. Sources are required to use Method 9 published in the 11 th Edition of the Official Methods of Analysis of the Association of Official Analytical Chemists dated 1970. As specified in the general provisions, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specif ic in the applicable rule. The p articulate matter concentration and volumetric flow rate of the effluent gas shall be determined by Method 5 whic h requires a sampling time and a sample volume for each run of at least 60 minutes and 1.50 dscm (53 dscf). e
. We a ssume 20 percent of initial performance tests must be repeated due to failure. f

. Sources are required to maintain a daily record of operating parameters. We a ssume records will be recorded 365 days per year.16
TABLE 2: Average Annual EPA Burden
- NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)

Burden Item s (A) EPA Hours per Occurrence (B)

Occurrences per Plant per Year (C)

EPA Hours per Plant per Year (C=AxB) (D)

Plants per Year (E)

Total EPA Hours per Year (E=CxD) (F)

Managerial Hours per Year a (G)

Technical Hours per Year a (H)

Clerical Hours per Year a
Required Activities New Plant a Initial performance tests b 24 1 24 0 0 0 0 0 Repeat performance tests c 24 0.2 4.8 0 0 0 0 0 Report Review New Plant Notification of construction 2 1 2 0 0 0 0 0 Notification of initial startup 0.5 1 0.5 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 demonstration of CMS 0.5 1 0.5 0 0 0 0 0 Existing Plants Semiannual reports 8 2 16 2 32 1.4 27.8 2.8
TOTAL 32 Salary d, e (1 person x 1.4 hrs/year x $114.77/hrs ) + (1 person x 27.8 hrs/year x $97.59/hrs) + (1 person x 2.8 hrs/year x $48.26/hrs) = $3,009.52 TOTAL ANNUAL BURDEN = $3,010 (rounded) Assumptions: a
. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. b. We assume that there will be no new sources (respondents) over the 3

- year period of this ICR. c. We assume that EPA personnel attend all initial performance tests. d. There will be no travel expenses associated with this ICR since we have assumed that no new sources will become subject to this rule over the 3

- year period of this ICR. e. The cost a technical labor rate of $97.59, managerial rate $114.77, and clerical rate of $48.26 from the United Stat es Department of Labor, Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by occupational and industry group.”