SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production
Plants
(
40
CFR
part
63,
subparts
AA
and
BB)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production
Plants
(
40
CFR
part
63,
subparts
AA
and
BB)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
phosphoric
acid
manufacturing
and
phosphate
fertilizers
production
plants
were
promulgated
on
December
29,
1992
and
amended
on
December
17,
2001.
These
standards
apply
to
owners
or
operators
of
existing
phosphoric
acid
manufacturing
and
phosphate
fertilizers
production
facilities.
The
rule
applies
to
component
processes
at
these
facilities
and
to
any
new,
modified,
or
reconstructed
sources.
Component
processes
include
wet
process
phosphoric
acid
plants,
superphosphoric
acid
plants,
purified
phosphoric
acid
plants,
phosphate
rock
dryers,
phosphate
rock
calciners,
diammonium
and
monoammonium
phosphate
plants,
and
granular
triple
superphosphate
(
GTSP)
plants.
Since
many
of
the
facilities
affected
by
the
standards
are
also
subject
to
new
source
performance
standards
(
NSPS),
the
standards
include
an
exemption
from
the
NSPS
for
those
sources.
The
exemption
eliminates
a
duplication
of
information
collection
requirements.

Consistent
with
the
General
Provisions
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Source
Categories
(
40
CFR
part
63,
subpart
A),
respondents
are
major
sources.
Respondents
are
required
to
submit
one­
time
notifications
(
where
applicable)
and
a
one­
time
report
on
performance
test
results
and
must
notify
the
Environmental
Protection
Agency
(
EPA)
if
annual
performance
tests
indicate
a
change
in
the
baseline
operating
range
of
emission
control
equipment.
Plants
must
develop
and
implement
a
startup,
shutdown,
and
malfunction
plan,
and
submit
semiannual
reports
of
any
event
in
which
the
plan
was
not
followed.
Semiannual
reports
are
required.
Quarterly
reporting
is
required
when
excess
emissions
occur.
General
requirements
applicable
to
all
NESHAP
require
records
of
applicability
determinations;
test
results;
exceedances;
periods
of
startups,
shutdowns,
or
malfunctions;
monitoring
records,
and
all
other
information
needed
to
determine
compliance
with
the
applicable
standard.
Records
and
reports
must
be
retained
for
a
total
of
five
years
(
two
years
at
the
site;
the
remaining
three
years
of
records
may
be
retained
off­
site).

Respondents
are
required
to
install
monitoring
devices
to
measure
the
pressure
drop
and
liquid
flow
rate
for
wet
scrubbers.
These
operating
parameters
are
permitted
to
vary
within
ranges
determined
concurrently
with
performance
tests.
Respondents
must
perform
annual
performance
tests
to
verify
or
reestablish
operating
ranges
for
purposes
of
determining
exceedances.
2
The
standards
require
sources
to
determine
and
record
the
amount
of
phosphatic
feed
material
processed
or
stored
on
a
daily
basis.
This
requirement
allows
verification
of
plant
operating
rates,
which
is
one
of
the
factors
considered
in
establishing
the
operating
ranges
of
control
devices.
This
requirement
poses
no
additional
burden
upon
the
industry.
This
is
so
because
proper
plant
operation
and
industry
practice
include
daily
recording
of
phosphate­
bearing
feed
processed.
This
practice
predates
the
regulations
and
would
continue
in
their
absence.
Because
of
this
daily
recording
requirement
it
places
no
additional
burden
upon
sources;
thus,
no
estimate
has
been
made
for
this
requirement.

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

This
collection
is
approved
for
three
years.
OMB
notes
that
EPA
should
ensure
that
a
mechanism
is
in
place
to
allow
for
electronic
reporting
of
the
requested
information.
When
EPA
next
submits
this
collection
to
OMB
for
revision
or
renewal,
EPA
should
assure
that
amortized
capital
costs
are
appropriately
included
in
that
submission.

EPA
has
addressed
each
item
of
concern
in
the
TOC
as
instructed
by
OMB
in
the
previous
ICR.
Electronic
reporting
is
in
place
to
adequately
handle
requested
information.
The
capital
cost
associated
with
this
ICR
is
a
one­
time
cost
when
a
facility
becomes
subject
to
the
regulation.
Since
there
are
no
new
sources
expected
during
the
next
three
years,
there
are
no
capital
costs
and
amortization
is
not
necessary.

Approximately
12
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
regulation
in
the
next
three
years.
The
average
annual
cost
to
the
industry
over
the
next
three
years
of
this
Information
Collection
Request
(
ICR)
is
estimated
to
be
$
109,908.

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
will
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:
3
(
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,
hazardous
air
pollutants
(
HAPs)
emissions
from
phosphoric
acid
manufacturing
and
phosphate
fertilizers
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
was
promulgated
for
this
source
category
at
40
CFR
part
63,
subparts
AA
and
BB.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAP
from
phosphoric
acid
manufacturing
and
phosphate
fertilizers
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP
from
phosphoric
acid
manufacturing
and
phosphate
fertilizers
plants
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
HAP
emissions
using
control
technology
and/
or
leak
detection
and
repair
procedures.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
ensure
that
the
pollution
control
devices
are
properly
installed
and
operated,
that
leaks
are
being
detected
and
repaired,
and
that
the
regulations
are
being
met.

Performance
test
reports
are
needed
as
these
are
the
Agency's
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
achieved.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
that
are
affected
by
NESHAP
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
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.
4
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subparts
AA
and
BB.

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
its
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
68
FR
27059
on
May
19,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
the
preparer
of
the
active
ICR,
and
accessed
the
most
recent
data
available
on
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
We
reviewed
information
available
from
the
Office
of
Compliance
Sector
Notebook
"
Profile
of
the
Agricultural
Chemical,
Pesticide,
and
Fertilizer
Industry,"
the
United
States
Census
Bureau
via
the
internet,
and
other
websites
covering
off­
site
waste
and
recovery
operations.
We
consulted
with
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer
and
Program
Integration
Division;
The
Fertilizer
Institute
(
TFI),
Mr.
William
Herz,
(
202)
544­
8123;
the
Florida
Department
of
Environmental
Protection
(
FDAP),
Ms.
Cindy
Phillips,
(
805)
921­
9534;
and
the
PCS
Phosphate
Company
Incorporated,
Mr.
William
Schimming,
(
847)
849­
4302.

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.
5
3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
Section
1320.5.

These
standards
require
affected
facilities
to
maintain
all
records,
including
reports
and
notifications,
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
record's
retention
requirement
is
consistent
with
Part
70
permit
programs
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

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
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.

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
(
SIC)
code
for
the
respondents
affected
by
the
standards
is
SIC
2874
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS)
325312
for
phosphoric
acid
manufacturing
and
phosphate
fertilizers
production
facilities.

4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
Section
1320.5.
6
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production
Plants
(
40
CFR
part
63,
subparts
AA
and
BB).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
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)

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)

Quarterly
report
63.10(
e)
and
63.607(
c)(
2)

Annual
report
63.10(
e)
and
63.607(
c)(
1)
7
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
years
63.10(
b)(
1)

Electronic
Reporting
Presently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
leaks
and
spills
of
phosphoric
acid.
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.
It
is
estimated
that
approximately
20
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
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.

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
any
previously
applicable
instructions
and
requirements.

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

Transmit,
or
otherwise
disclose
the
information.

Currently,
sources
are
using
automated
monitoring
equipment
that
provides
parameter
data.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
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,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
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
operational.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
9
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.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
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
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
five
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Industry
Burden
­
NESHAP
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production
Plants.

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
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
1,542
(
Total
Annual
Burden
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
NESHAP
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
$
64.13
per
hour.
This
rate
is
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rate
has
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
types
of
industry
cost
associated
with
the
information
collection
activity
in
the
standards
are
labor
and
CEMs.
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(
s)
and
other
costs
such
as
photocopying
and
postage.

(
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)

Temperature
monitoring
device
$
2,700
0
0
$
886
12
$
10,632
11
The
total
capital/
startup
costs
for
this
ICR
are
zero.
The
cost
of
the
temperature
monitoring
device
would
likely
be
written
off
the
first
year,
so
no
amortization
of
the
cost
is
indicated.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
10,632.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
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
cost
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
11,000
(
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.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
43,922.
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
$
39.49.
This
rate
as
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production
Plants
(
40
CFR
part
63,
subparts
AA
and
BB).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
12
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.
12
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
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
To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
12.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
number
of
responses
per
year
is
calculated
using
the
following
table:

Total
Annual
Responses
(
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
E=(
AxB)+(
CxD)+
F
0
0
12
7
0
84
The
number
of
Total
Annual
Responses
is
84.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
98,908,
based
on
1,542.3
hours
at
$
64.13.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1,
Annual
Industry
Burden
­
NESHAP
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production
Plants
(
40
CFR
part
63,
subparts
AA
and
BB).
13
Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
11,000.
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.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
18
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
in
part
to
a
decrease
in
the
number
of
sources.
Since
there
were
no
new
sources,
the
burden
was
drastically
reduced.
The
decrease
was
also
due
to
an
error
in
the
tables
from
the
active
ICR
that
increased
the
number
of
hours
and
the
burden.
The
state
of
the
economy
also
played
a
part
in
the
decline
of
sources,
as
a
result
of
the
pricing
anomaly,
a
growing
number
of
manufacturing
companies
are
taking
their
operation
overseas
while
others
are
forced
to
close
their
plants.
It
has
become
profitable
for
distributers
to
purchase
fertilizer
products
at
a
much
lower
cost
overseas
than
can
be
produced
in
the
United
States.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
18
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.

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

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0027,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
14
West,
Room
B102,
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,
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
is
(
202)
566­
1752.
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.
When
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,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OECA­
2003­
0027
and
OMB
Control
Number
2060­
0361
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:
Annual
Industry
Burden
­
NESHAP
for
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production
Plants
(
40
CFR
part
63,
subparts
AA
and
BB)

Burden
item
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

per
year
(
C)
Hours/
Respondent/

year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Hours
per
year
(
E=
CxD)
(
F)
Cost/

year
a
(
F=
E
x
$
64.13)

1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
N/
A
4.
Reporting
Requirements
A.
Read
instructions
4
1
4
0
0
0
B.
Required
activities
Initial
performance
test
28
1
28
0
0
0
Repeat
of
initial
performance
test
28
0.1
2.8
0
0
0
Startup,
shutdown,
malfunction
plan
40
1
40
0
0
0
Annual
performance
test
28
1
28
12
b
336
$
21,547.68
Repeat
annual
performance
test
28
0.2
5.6
0.84
c
4.70
$
301.41
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
j
Notification
of
applicability
N/
A
Notification
of
constr./
reconstr.
2
1
2
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
Notification
of
compliance
status
4
1
4
0
0
0
Report
of
performance
test
See
4B
16
Burden
item
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

per
year
(
C)
Hours/
Respondent/

year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Hours
per
year
(
E=
CxD)
(
F)
Cost/

year
a
(
F=
E
x
$
64.13)

Report
of
monitoring
exceedances
16
4
64
1.2
d
76.8
$
4,925.18
Report
of
no
excess
emissions
8
2
16
10.8
e
172.8
$
11,081.66
Startup/
shutdown/
malfunction
report
8
1
16
1f
16
$
1,026.08
5.
Recordkeeping
Requirements
A.
Read
instructions
4
1
4
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
1.5
g
52
h
78
12
b
936
$
60,025.68
F.
Time
to
train
personnel
i
N/
A
G.
Time
to
comply
with
applicable
requirements
See
4B
H.
Time
for
audits
N/
A
TOTAL
ANNUAL
BURDEN
(
rounded)
1,542.3
$
98,908
a
Assume
that
all
tasks
are
to
be
performed
by
a
technical
person.
This
ICR
uses
a
labor
rate
of
$
64.13
for
Technical
labor.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2003,
Table
2:
Employment
Costs
of
Civilian
Workers
by
Occupational
and
Industry
Group.
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
12
major
sources
are
subject
to
the
standard.
No
new
or
reconstructed
plants
or
sources
(
respondents)
are
expected
over
the
3
years
period
of
this
ICR.

c
Assume
7
percent
of
12
respondents
will
fail
the
initial
performance
test
and
must
repeat
it.

d
Assume
10
percent
of
12
respondents
report
exceedances.
Respondents
are
required
to
report
quarterly.

e
Assume
90
percent
of
existing
respondents
report
no
excess
emissions
semiannually.

f
Assume
1
of
12
sources
will
have
to
submit
a
startup,
shutdown,
or
malfunction
report.
17
g
Assume
it
will
take
1.5
hours
per
respondent
to
enter
information.

h
Assume
information
is
entered
one
time
per
week
for
52
weeks
per
year.

i
There
are
no
hours
for
training
personnel
since
no
training
is
required
by
the
rule,
and
hours
have
been
allotted
under
5A
for
reading
and
understanding
the
recordkeeping/
reporting
requirements.

j
Time
to
transmit
or
disclose
information
included.
18
TABLE
2:
AVERAGE
Annual
EPA
Burden
­
NESHAP
for
Phosphoric
Acid
Manufacturing
Plants
and
Phosphate
Fertilizers
Production
Plants
(
40
CFR
Part
63,
Subparts
AA
and
BB)

Burden
Item
(
A)

EPA
hrs/
Occurrence
(
B)
Occurrence
s
plant/
year
(
C)
EPA
person/

hour
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
(
E)
Technical
person/
hours
per
year
(
E=
CxD)
(
H)

EPA
Cost/

year
a
Initial
performance
test
40
1
40
0
0
0
Repeat
initial
performance
test
Retesting
preparation
Retesting
8
40
1
1
8
40
0
0
0
0
0
0
Excess
Emissions
Enforcement
Activities
N/
A
Report
Review
Notification
of
applicability
Notification
of
construction./
reconstruction
Notification
of
anticipated
startup
Notification
of
actual
startup
Notification
of
special
compliance
req.

Notification
of
initial
performance
test
Notification
of
compliance
status
Annual
performance
test
Repeat
annual
performance
test
Excess
emissions
report
No
excess
emissions
report
NESHAP
waiver
application
Startup/
shutdown/
malfunction
report
2
N/
A
N/
A
N/
A
N/
A
2
2
40
40
20
20
N/
A
20
1
1
1
1
1
4
2
1
2
2
2
40
40
80
40
20
0
0
0
12
b
0.84
c
1.2
d
10.8e
1f
0
0
0
480
33.6
96
432
20
0
0
0
$
18,955.20
$
1,326.86
$
3,791.04
$
17,059.68
$
789.80
TOTAL
ANNUAL
EPA
BURDEN
1,062
$
41,922.58
19
Travel
Expenses
(
1
person
x
4
plants/
year
x
2
days/
plant
x
$
75
per
diem)
+
($
350
round
trip
x
4
plants/
year)
=
$
2,000
$
2,000
TOTAL
ANNUAL
EPA
BURDEN
(
rounded)
$
43,922
a
The
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
39.49.
This
rate
is
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

b
Assume
that
12
major
sources
are
subject
to
the
standard.
No
new
or
reconstructed
plants
or
sources
(
respondents)
are
expected
over
the
3
years
period
of
this
ICR.

c
Assume
7
percent
of
12
respondents
will
fail
the
initial
performance
test
and
must
repeat
it.

d
Assume
10
percent
of
12
respondent
report
exceedances.
Respondents
are
required
to
report
quarterly.

e
Assume
90
percent
of
existing
respondents
report
no
excess
emissions
semiannually.

f
Assume
1
of
12
sources
will
have
to
submit
startup,
shutdown,
or
malfunction
report.
