SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
the
Phosphate
Fertilizer
Industry
(
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
the
Phosphate
Fertilizer
Industry
(
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
the
regulations
published
at
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X
were
proposed
on
October
22,
1974,
and
promulgated
on
August
6,
1975.
These
standards
apply
to
each
wet­
process
phosphoric
acid
plant,
each
superphosphoric
acid
plant,
each
granular
diammonium
phosphate
plant,
and
each
triple
superphosphate
plant,
having
a
design
capacity
of
more
than
15
tons
of
equivalent
phosphorous
pentoxide
(
P
2
O
5)
feed
per
calendar
day.
These
standards
also
apply
to
granular
triple
superphosphate
storage
facilities.
These
standards
establishes
fluorides
emission
limitations
as
a
measure
of
phosphorus­
bearing
feed
material
at
affected
facilities
at
the
above
referenced
plants.
The
affected
facilities
may
include
a
combination
of
reactors,
filters,
evaporators,
hot
wells,
acid
sumps,
cooling
tanks,
granulators,
dryers,
coolers,
screens,
mills,
mixers,
curing
belts
(
dens),
cookers,
and
facilities
which
store
run­
of­
pile
triple
superphosphate,
depending
on
the
type
of
plant.

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
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
protection
Agency
(
EPA)
Regional
office.

Approximately
13
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
new
sources
will
become
subject
to
the
regulation
over
the
next
three
years.
In
order
to
comply
with
the
recordkeeping
and
reporting
requirements
standard,
the
respondents
will
expend
approximately
1,194
hours
and
$
320,000
per
year.
2
These
figures
are
based
on
queries
conducted
on
the
Air
Facility
System
through
the
Online
Tracking
Information
System
(
OTIS),
data
from
the
Profile
of
the
Agricultural
Chemical,
Pesticide,
and
Fertilizer
Industry
Sector
Notebook
published
by
EPA's
Office
of
Compliance,
and
the
Technical
Support
Document
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production,
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
(
1994
Review
Draft)
published
by
EPA
Office
of
Air
Quality
Planning
and
Standards;
queries
conducted
on
the
Missouri
State
Government/
Business
Entity
Database;
consultations
with
the
Florida
State
Government/
Office
of
the
Environment
and
a
number
of
fertilizer
companies.

In
the
development
of
this
Information
Collection
Request
(
ICR),
we
addressed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
on
the
active
ICR
which
states:

This
ICR
is
approved
for
three
years.
Before
re­
submission
of
this
ICR
for
extension,
the
agency
should
revisit
the
estimate
of
the
number
of
respondents
and
demonstrate
to
OMB
that
the
estimates
are
consistent
with
agency
experience.
In
addition,
the
agency
should
revise
wage
estimates
to
reflect
guidance
provided
by
EPA
and/
or
OMB­
especially
with
respect
to
appropriate
calculation
of
wage
overhead.

We
used
the
most
recent
data
available
on
the
Aerometric
Information
Retrieval
System
(
AIRS),
Airs
Facility
System
(
AFS)
database
for
the
NSPS
program
associated
with
the
SIC
(
United
States
Standard
Industrial
Classification)
codes
for
the
respondents
affected
by
the
standards.
We
also
used
the
most
recent
data
on
wages
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
2001,
"
Table
10.
Private
industry,
by
occupational
and
industry
group,"
and
the
guidance
provided
by
the
Agency's
Office
of
Information
and
the
Office
of
Management
and
Budget
to
calculate
the
respondent
burden.
Accordingly,
the
wage
rate
obtained
from
the
table
has
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

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).
3
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
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,
particulate
emissions
from
the
ammonium
sulfate
manufacturing
industry
cause
or
contributed
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X.

2(
b)
Practical
Utility/
Users
of
the
Data
Source
data
and
information
requirements
for
phosphate
fertilizer
plants
are
outlined
in
Section
4(
b)(
i).
These
standards
require
the
initial
reports
in
accordance
with
the
general
provisions
of
40
CFR
60.7.
These
initial
reports
include
notification
of
construction
or
modification,
reconstruction,
and
startup,
shutdown,
or
malfunction.
The
standards
also
require
recordkeeping
to
document
information
relating
to
the
daily
feed
rate
and
storage
of
equivalent
P
2
O
5.
Semiannual
compliance
reporting
is
also
required
by
the
general
provisions.

Amounts
of
P
2
O
5
are
determined
from
Continuous
Monitoring
System
(
CMS)
records
of
phosphate­
bearing
feed
material
or
accounts
for
triple
superphosphate
stored.
The
standards
are
defined
in
terms
of
grams
of
fluorides
emitted
per
metric
ton
of
equivalent
P
2
O
5
processed.

The
standards
limits
total
fluoride
emission
to
100
grams
per
megagram
(
Mg)
of
equivalent
P
2
O
5
feed
as
measured
in
Mg/
hour.
Therefore,
the
regulations
require
the
hourly
recording
of
data
and
the
maintenance
of
daily
records
for
purposes
of
determining
the
feed
rate
used
in
the
standard.
Such
records
must
be
retained
at
the
facility
for
a
minimum
of
two
(
2)
years.
4
The
information
generated
by
the
monitoring,
recordkeeping,
and
reporting
requirements
described
above
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
and
control
equipment
used
to
achieve
compliance
with
the
NSPS.
Notification
of
construction
and
startup
indicates
to
enforcement
personnel
when
a
new
affected
facility
has
been
constructed
and
therefore,
is
subject
to
the
standards.
Under
the
standard,
data
collected
by
an
affected
facility
is
retained
at
the
source
for
a
minimum
of
two
years
and
made
available
for
inspection
by
the
Administrator.

If
the
information
required
by
the
standards
were
not
collected,
the
Agency
would
have
no
means
of
ensuring
that
compliance
with
the
NSPS
is
achieved
and
maintained
by
new,
modified,
or
reconstructed
sources
subject
to
the
regulations.
Under
these
circumstances,
an
owner
or
operator
could
elect
to
reduce
operating
expenses
by
not
installing,
maintaining,
or
otherwise
operating
the
control
technology
required
by
the
standards.
In
the
absence
of
the
information
collection
requirements,
compliance
with
the
standards
could
be
ensured
only
through
continuous
on­
site
inspections
by
regulatory
Agency
personnel.
Consequently,
not
collecting
the
information
would
result
in
either
greatly
increased
expenditures
of
resources,
or
the
inability
to
ensure
compliance
with
the
standards.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
Part
60,
Subparts
T,
U,
V
W,
and
X.

3(
a)
Nonduplication
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
on
September
26,
2002.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
5
3(
c)
Consultations
For
this
information
collection,
we
conducted
a
number
of
queries.
We
first
reviewed
the
information
available
from
the
Office
of
Compliance
Sector
Notebook
"
Profile
of
the
Agricultural
Chemical,
Pesticide,
and
Fertilizer
Industry."
Then
we
accessed
the
most
recent
data
available
on
the
Facility
Subsystem
(
AFS)
database
of
the
Aerometric
Information
Retrieval
System
as
maintained
by
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
We
also
reviewed
information
from
the
"
Technical
Support
Document,"
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production,
published
by
the
Office
of
Air
quality
Planning
and
Standards,
and
gathered
information
from
Florida
State
Government/
Office
of
the
Environment,
Missouri
State
Government/
Business
Entity
Database
and
a
number
of
fertilizer
companies
listed
in
our
queries.

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
likelihood
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
1320.5.

3(
f)
Confidentiality
The
required
information
has
been
determined
not
to
be
confidential.
However,
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
Business
Information
(
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.
6
4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
phosphate
fertilizer
facilities.
The
SIC
(
United
States
Standard
Industrial
Classification)
code
for
the
respondents
affected
by
the
standard
is
2874
(
Phosphate
Fertilizer
Plants).

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
New
Source
Performance
Standards
for
the
Phosphate
Fertilizer
Industry
(
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X).

A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X
Notification
of
construction/
reconstruction.
60.7(
a)(
1)

Notification
of
initial
startup
including
compliance
method.
60.7(
a)(
3)

Initial
performance
test
results.
60.8(
a)

Initial
performance
test.
60.8(
d)

Demonstration
of
continuous
monitoring
system.
60.7(
a)(
5)

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

Semiannual
or
as
indicated
by
the
Administrator
reports
of
exceedances
or
monitoring
systems
performance.
60.7(
c)

Site­
specific
methodology
plan
for
demonstrating
compliance
with
standards
for
fluorides.
60.242(
a),
60.243(
d)
7
A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
60.7(
b)

A
file
with
records
of
all
data
measured
during
performance
tests
to
demonstrate
compliance
with
the
standard
including
the
equipment
operating
parameters
and
records
of
periods
of
operations
during
which
the
parameters
where
established.
The
file
shall
be
retained
for
two
years
following
the
date
of
such
measurements,
maintenance,
reports,
and
records.
60.7(
f)

Daily
record
of
equivalent
P
2
O
5
feed
rate.
60.203(
b),
60.213(
b)
60.223(
b),
60.233
Daily
record
of
equivalent
P
2
O
5
feed
rate
and
storage.
60.243(
b)

Other
records
specified
in
an
EPA
approved
site
specific
plan.
60.243(
d)

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
monitoring
devices
that
continuously
measures
the
total
pressure
drop
across
the
process
scrubbing
system.

Install,
calibrate,
maintain,
and
operate
a
flow
monitoring
device
which
can
be
used
to
determine
the
mass
flow
of
phosphorus
bearing
feed
material
to
the
process.

As
part
of
the
performance
test,
determine
the
P
2
O
5
content
(
R
p)
of
the
feed
using
the
(
AOAC)
Method
9
and
Method
13A
or
13b
to
determine
the
total
fluoride
concentration
of
volumetric
flow
rate
of
the
effluent
gas
from
each
of
the
emission
points.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.
8
Respondent
Activities
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
previously
applicable
instructions
and
requirements.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

Presently
sources
are
using
monitoring
equipment
that
provides
parametric
data
in
an
automated
way
(
e.
g.,
pressure
drop
and
volumetric
flow
rate).
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.
In
addition,
some
Regulatory
Agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
Regulatory
Agencies.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
no
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
quarterly
reports
of
excess
emissions
reports
or
semiannual
reports
of
no
excess
emission,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.
9
5(
b)
Collection
Methodology
and
Management
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
EPA
Regional
Office.
Notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
of
exceedances
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
AIRS
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
EPA
Office
of
Compliance.
AFS
is
the
EPA
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AFS
for
tracking
air
pollution
compliance
and
enforcement
activity
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
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
Currently
the
number
of
employees
at
a
typical
fertilizer
plant
exceeds
the
criterion
for
small
business,
and
no
new
facilities
are
expected
within
the
next
three
years.
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
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Annual
Industry
Burden
­
NSPS
for
the
Phosphate
Fertilizer
Industry
(
40
CFR
Part
60,
Subparts
T,
U,
V,
W
and
X).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
Subparts
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.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.
10
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
1,194
hours
(
Total
Labor
Hours
from
Table
2).
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
a
Technical
Labor
Rate
of
$
57.12
per
hour.
This
rate
is
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
2001,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rate
have
been
increased
by
110%
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
activity
in
the
regulations
are
labor
and
continuous
emission
monitoring
(
CEM).
There
are
no
capital/
startup
costs
since
we
have
assumed
that
no
new
sources
will
become
subject
to
this
rule
over
the
threeyear
period
of
this
ICR.
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
which
are
itemized
in
the
following
table.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
11
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Startup
Cost
($)
for
One
Source
(
C)
Number
of
New
Sources
to
Startup
(
D)
Total
Startup
(
B
X
C)
(
E)
Annual
O&
M
Costs
($)
for
One
Source
(
F)
Number
of
Existing
Sources
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Pressure
drop
monitor
$
27,720
0
$
0
$
24,630.
13
$
320,190.

As
indicated
above,
there
are
no
capital/
startup
costs
for
this
ICR.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
is
$
320,190.
This
is
the
total
of
column
G.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
non­
labor
costs
in
block
14
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
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
320,000
(
rounded).
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
increase
in
burden
from
the
most
recently
approved
ICR
is
an
adjustment.
We
have
determined
that
the
increase
in
burden
is
primarily
due
to
the
annual
operation
and
maintenance
costs
(
O&
M)
which
are
ongoing
expenses
that
covers
the
maintenance
of
the
monitors
and
other
recordkeeping
costs.
The
information
for
the
costs
could
be
found
in
the
"
EPA
Air
Pollution
Control
Cost
Manual"
dated
October
2000.
The
cost
data
can
be
found
on
pages
4­
19,
Table
4.6:
Cost
Summary
for
Pressure
Drop
Across
Wet
Scrubber.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.
12
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
996
(
see
Table
1:
Average
Annual
EPA
Burden
­
NSPS
for
the
Phosphate
Fertilizer
Industry
(
40
CFR
Part
60,
Subpart
T,
U,
V,
W,
and
X).
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
38.30.
This
rate
is
from
the
Office
of
Personnel
Management
(
OPM)
"
2002
General
Schedule"
which
excludes
locality
rates
of
pay.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
and
Number
of
Responses
Per
Year
Regulation
Citation
(
A)
Average
Number
of
New
Respondents
per
Year
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD)+
F
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X
0
6
13
2
0
26
The
number
of
total
respondents
is
13.
This
number
is
the
sum
of
column
A
and
column
C
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period.
It
is
shown
in
block
13
(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
26.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
It
is
shown
in
block
13(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.

The
total
annual
labor
costs
are
$
68,173.
This
number
is
not
shown
on
the
OMB
83­
I
form.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Respondents
Burden
­
NSPS
for
the
Phosphate
Fertilizer
Industry,
(
40
CFR
Part
60,
Subparts
T,
U,
V,
W,
and
X).

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
320,000
(
rounded).
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs.
13
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.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recent
approved
ICR
is
due
to
a
increase
in
the
number
of
sources
and
more
accurate
cost
accounting.
We
have
assumed
that
there
will
be
no
new
sources
(
respondents)
over
the
3
years
period
of
this
ICR.
We
first
determined,
based
on
queries
conducted
on
the
Air
Facility
System
through
the
Online
Tracking
Information
System,
that
there
were
19
respondents
potentially
subject
to
this
NSPS
rule.
Since
the
active
ICR
indicated
that
there
were
11
existing
respondents
subject
to
the
rule
and
no
new
sources
were
estimated
for
the
3
year
period,
we
conducted
additional
research
and
contacted
each
facility,
and
subsequently
determined
that
the
number
of
respondents
subject
to
the
rules
addressed
by
this
ICR
is
13.
This
further
research
consisted
of
the
review
of
the
Profile
of
the
Agricultural
Chemical,
Pesticide,
and
Fertilizer
Industry
Sector
Notebook
published
by
EPA's
Office
of
Compliance,
the
Technical
Support
Document
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production
NESHAP
(
1994
Review
Draft)
published
by
EPA
Office
of
Air
Quality
Planning
and
Standards,
queries
conducted
on
the
Missouri
State
Government/
Business
Entity
Database,
consultation
with
the
Florida
State
Government/
Office
of
the
Environment
and
contacted
a
number
of
fertilizer
companies
to
confirm
their
existence.

We
have
determined
that
the
increase
in
burden
from
the
most
recently
approved
ICR
is
also
due
to
the
annual
operation
and
maintenance
costs
(
O&
M)
for
pressure
drop
monitors
which
are
ongoing
costs.
O&
M
costs
were
not
computed
in
the
previous
ICR.
The
information
for
O&
M
costs
can
be
found
in
the
"
EPA
Air
Pollution
Control
Cost
Manual"
dated
October
2000,
in
Chapter
4
which
covers
Monitoring
Systems
and
the
Estimating
of
Capital
and
Annual
Costs.
The
cost
data
for
this
ICR
can
be
found
on
pages
4­
19,
Table
4.6:
Cost
Summary
for
Pressure
Drop
Across
Wet
Scrubber.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
46
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
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

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
14
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0003,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
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
1514.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0003
and
OMB
Control
Number
2060­
0037
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
TABLE
1:
AVERAGE
ANNUAL
EPA
BURDEN
­
NSPS
for
the
PHOSPHATE
FERTILIZER
INDUSTRY
(
40
CFR
PART
60,
SUBPARTS
T,
U,
V,
W,
and
X)

EPA
hrs/
Occurrences
EPA
hr/
Plants/
EPA
occurrences
plant/
year
plant/
year
year
hrs/
year
Burden
Items
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)
___________________________________________________________________________________________________________________________
_
Required
Activities
New
Plant
a
Initial
performance
tests
b
24
1
24
0
0
Repeat
performance
tests
c
24
0.2
4.8
0
0
Report
Review
New
Plant
Notification
of
construction
2
1
2
0
0
Notification
of
initial
startup
0.5
1
0.5
0
0
Notification
of
actual
startup
0.5
1
0.5
0
0
Notification
of
initial
test
0.5
1.2
0.6
0
0
Review
test
results
8
1.2
9.6
0
0
Notification
of
demonstration
of
CMS
0.5
1
0.5
0
0
Existing
Plants
Semiannual
report
of
exceedances
1
2
2
13
26
TOTAL
ANNUAL
HOUR
26
Travel
expenses
d
(
1
person
x
0
plant/
year
x
3
days/
plant
x
$
75
per
diem)
+
($
350
round
trip/
plant
x
0
plant/
year)
=
$
0/
year
Salary
e
(
1
person
x
26
hrs/
year
x
$
38.30/
hrs
)
=
$
996.
(
rounded)

TOTAL
ANNUAL
BURDEN
=
$
996.
(
rounded)

___________________________________________________________________________________________________________________________
____
Assumptions:

a.
Assume
that
there
will
be
no
new
sources
(
respondents)
over
the
3
years
period
of
this
information
collection
request
(
ICR).
b.
Assume
EPA
personnel
attend
all
initial
performance
tests.
c.
Assume
20
percent
of
initial
performance
tests
are
repeated
due
to
failure.

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
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
38.30.
This
rate
is
from
the
Office
of
Personnel
Management
(
OPM)
"
2002
General
Schedule"
which
excludes
locality
rates
of
pay.
16
TABLE
2:
ANNUAL
INDUSTRY
BURDEN
­
NSPS
for
the
PHOSPHATE
FERTILIZER
INDUSTRY
(
40
CFR
PART
60,
SUBPARTS
(
T,
U,
V,
W,
AND
X)

Occurrences/
Hours/
Hours
per
respondent/
Respondent/
Respondents
Hours
Cost/

Occurrence
year
year
per
year
per
year
year
a
Reporting/
Recordkeeping
(
A)
(
B)
(
C=
A
x
B)
(
D)
(
E
=
C
x
D)
(
F=
E
x
$
57.12)
___________________________________________________________________________________________________________________________

1.
APPLICATIONS
Not
Applicable
2.
SURVEY
AND
STUDIES
Not
Applicable
3.
REPORTING
REQUIREMENTS
New
Sources
b
A.
Read
Instructions
1
1
1
0
0
0
B.
Required
Activities
New
Sources
b
Initial
performance
test
AOCA
Method
9
tests
c
29.7
1
29.7
0
0
0
Reference
Method
13A
or
4
1
4
0
0
13B
tests
d
Repeat
performance
test
e
4
0.2
0.8
0
0
0
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
New
Sources
Notification
of
construction/
2
1
2
0
0
0
reconstruction
Notification
of
2
1
2
0
0
0
actual
startup
Notification
of
initial
2
1
2
0
0
0
performance
test
Notification
of
demonstration
2
1
2
0
0
0
of
CMS
Report
of
initial
performance
test
Included
in
3B
Site­
Specific
methodology
plan
f
2
1
2
0
0
0
Existing
Sources
Notification
of
operational
change
g
2
1
2
2
4
228.48
Semiannual
report
of
exceedances
h
2
2
4
13
52
2,970.24
SUBTOTAL
56
3,198.72
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
Applicable
E.
Time
to
Enter
Information
Records
of
operating
parameters
0.25
350
87.5
13
1,137.5
$
64,974.
and
emissions
i
A.
Audits
Not
Applicable
17
TOTAL
ANNUAL
BURDEN
(
rounded)
1,194
____________________________________________________________________________________________________________________
__________
Assumptions:

a.
Assume
a
technical
labor
rate
of
$
57.12
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2001,
Table
2:
Employment
Costs
of
Civilian
Workers
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.
The
wage
rate
obtained
from
the
table
has
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
b.
Assume
that
there
will
be
no
new
sources
(
respondents)
over
the
3
years
period
of
this
ICR.

c.
As
specified
in
the
general
provisions
each
performance
test
shall
consist
of
three
separate
runs
using
the
applicable
test
method.
Sources
are
required
to
use
the
spectrophotometric
molybdovanadophosphate
method
(
AOAC)
Method
9
published
in
the
11
Edition
of
the
Official
Methods
of
Analysis
of
the
Association
of
Official
Analytical
Chemists
dated
1970,
to
determine
the
P2O5
feed
rate.
d.
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
specific
in
the
applicable
rule.
For
these
rules,
the
total
fluoride
concentration
and
volumetric
flow
rate
of
the
effluent
gas
shall
be
determined
by
Method
13
which
requires
a
sampling
time
and
a
sample
volume
for
each
run
of
at
least
60
minutes
and
0.85
dscm
(
30
dscf).
e.
Assume
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure.
f.
Only
sources
that
have
a
granular
triple
superphosphate
storage
facility
are
required
to
submit
this
initial
plan
.
g.
Assume
that
15%
of
the
source
would
be
attributed
to
operational
changes.

h.
Assume
each
source
will
submit
a
semiannual
report
due
to
excess
emission
and
monitoring
systems
performance
over
the
three
year
period.

i.
Sources
are
required
to
maintain
a
daily
record
of
operating
parameters
(
e.
g.,
determine
equivalent
P2O5
content,
and
total
pressure
drop
across
the
scrubbing
system).
Assume
operation
350
days
per
year
as
specified
in
the
NSPS
review
document.
