SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Nitric
Acid
Plants
(
40
CFR
part
60,
subpart
G)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Nitric
Acid
Plants
(
40
CFR
part
60,
subpart
G)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
nitric
acid
plants
were
proposed
on
August
17,
1971,
and
promulgated
on
June
14,
1974.
These
standards
apply
to
nitric
acid
production
units
which
commenced
construction,
modification
or
reconstruction
after
the
date
of
proposal.
Nitrogen
oxide
(
NO
x)
is
the
pollutant
regulated
under
this
subpart.
The
standards
limit
nitrogen
oxides,
expressed
as
NO
2,
in
excess
of
1.5
kilograms
per
metric
ton
of
acid
produced
(
3.0
lb.
per
ton),
and
limit
opacity
to
10
percent.

Owners
or
operators
of
the
affected
facilities
described
must
make
the
following
one­
timeonly
reports:
notification
of
the
date
of
construction
or
reconstruction;
notification
of
the
actual
dates
of
startup;
notification
of
any
physical
or
operational
change
to
an
existing
facility
which
may
increase
the
regulated
pollutant
emission
rate;
notification
of
demonstration
of
the
continuous
monitoring
system
(
CMS);
notification
of
the
date
of
the
initial
performance
test;
and
the
results
of
the
initial
performance
test.
Owners
or
operators
are
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
required,
in
general,
of
all
sources
subject
to
NSPS.

Monitoring
requirements
specific
to
nitric
acid
plants
provide
information
on
nitrogen
oxide
emissions.
The
owners
or
operators
are
required
to
record
the
production
rate
of
nitric
acid
produced,
the
hours
of
operation
of
the
source,
and
the
levels
of
nitrogen
oxides
emitted
into
the
atmosphere.
Owners
or
operators
of
affected
facilities
are
required
to
install,
calibrate,
maintain,
and
operate
a
continuous
monitoring
system
(
CMS)
for
the
measurement
and
recording
of
nitrogen
oxides.
Recordkeeping
requirements
for
nitric
acid
plants
consist
of
the
occurrence
and
duration
of
any
startup
and
malfunctions
as
described.
They
include
the
initial
performance
test
results
including
information
necessary
to
determine
the
conditions
of
the
performance
test,
and
performance
test
measurements
and
results,
including
the
emission
rate
and
concentration
of
NO
x
and
the
volumetric
flow
rate
of
the
effluent
gas.
Records
of
startups,
shutdowns,
and
malfunctions
should
be
noted
as
they
occur.
Any
owner
or
operator
subject
to
the
provisions
of
this
subpart
will
maintain
a
file
of
all
measurements,
including
continuous
monitoring
system,
2
monitoring
device,
and
performance
testing
measurements;
all
continuous
monitoring
system
performance
evaluations;
all
continuous
monitoring
system
or
monitoring
device
calibration
checks;
and
all
other
information
required
by
this
part,
recorded
in
a
permanent
form
suitable
for
inspection.

The
reporting
requirements
for
this
industry
currently
include
the
initial
notifications
listed,
the
initial
performance
test
results,
and
semiannual
reports
of
instances
of
excess
emissions
and
a
monitoring
system
performance
report.
Periods
of
excess
emissions
will
be
reported
and
are
defined
as
any
3­
hour
period
during
which
the
average
nitrogen
oxides'
emissions
(
arithmetic
average
of
three
contiguous
1­
hour
periods)
as
measured
by
a
continuous
emission
monitoring
system
exceed
the
standard.
Semiannual
excess
emission
reports
and
monitoring
system
performance
reports
will
include
the
date
and
time
of
the
exceedence
or
deviation,
the
nature
and
cause
of
the
malfunction
(
if
known)
and
corrective
measures
taken,
and
identification
of
the
time
period
during
which
the
CMS
was
inoperative
(
this
does
not
include
zero
and
span
checks
nor
typical
repairs/
adjustments).

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.
The
reviewing
authority
may
then
inspect
the
source
to
verify
if
the
standard
is
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
standard,
and
to
note
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.

Owners
or
operators
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.

Approximately
24
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
an
additional
one
source
per
year
will
become
subject
to
the
standard
over
the
next
three
years
due
to
the
modification
or
reconstruction
of
an
existing
affected
facility.

The
Office
of
Management
and
Budget
(
OMB)
approved
the
current
Information
Collection
Request
(
ICR)
without
any
"
Terms
of
Clearance."

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
3
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated.
Section
111(
a)(
l).

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
No
x
from
nitric
acid
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
nitrogen
oxide
from
nitric
acid
plants
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
pollutant
emissions
using
control
technology
and
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
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
leaks
are
being
detected
and
repaired
and
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)
requirement
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
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.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
(
40
CFR
part
60,
subpart
G).

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
4
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
nitric
acid.
We
consulted
with
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer
and
Program
Integration
Division.
In
addition,
we
consulted
The
Fertilizer
Institute
(
TFI),
Mr.
Bill
Herz,
(
202)
515­
2706,
Agrium,
Mr.
Robert
Williams,
(
559)
627­
5553,
Costal
Chemical,
Ms.
Barbara
Cabot,
(
307)
637­
2700,
BP
Chemicals,
Incorporated,
Mr.
Kevin
Sprague,
(
419)
226­
1200.

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
is
a
useful
technique
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
part
1320,
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
Business
Information
(
see
40
CFR
part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
5
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
and
NAIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
nitric
acid
plants.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
United
States
Standard
Industrial
Classification
(
SIC)
2873
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS)
325311
for
nitric
acid.

4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
Section
1320.5.

(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
New
Source
Performance
Standards
(
NSPS)
for
Nitric
Acid
Plants
(
40
CFR
part
60,
subpart
G).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
of
construction
or
modification
application
60.6(
a)

Initial
notifications
60.7(
a)(
3)

Notification
of
actual
startup
60.7(
a)(
3)

Initial
performance
test
60.8(
d)

Initial
performance
test
results
60.8(
a)

Rescheduled
initial
performance
test
60.8(
d)

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

Compliance
status
60.7
(
a)(
7)
6
Physical
or
operational
change
60.7(
a)(
4)

Opacity
or
visible
emissions
60.7(
a)(
6)

Periodic
startup,
shutdown,
malfunction
reports
60.7(
b)

Source
status
report
60.7(
c)

Reports
Standard
Citation
by
Section
Semiannual
60.7(
c)

A
source
must
make
the
following
records:

Recordkeeping
Startup,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
60.7(
b)

Emission
test
results
and
other
data
needed
to
determine
emissions
60.7(
c)

All
reports
and
notifications
60.19
Record
of
applicability
60.70
Records
of
sources
with
continuous
monitoring
systems
(
CMS)
60.7(
c)

Maintain
records
for
two
years
60.7(
f)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
leaks
and
spills
of
mercury.
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
10%
of
the
respondents
use
electronic
reporting.
7
(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
opacity.

Perform
initial
performance
test,
Reference
Method
7
test,
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

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

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

Adjust
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.

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).
8
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
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard
and
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

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
over
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
two
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:
Average
Annual
Industry
Burden
and
Costs
for
NSPS
for
Nitric
Acids
(
40
CFR
part
60,
subpart
G).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
9
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.

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
1,290
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
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
rates
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standard(
s)
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
photocopying
and
postage.
10
(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
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)

NOx
$
68,000
1
$
68,000
$
100,000
24
$
2,400,000
The
total
capital/
startup
costs
for
this
ICR
are
$
68,000.
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
$
2,400,000.
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
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
2,468,000.
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
$
5,515
(
rounded).
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
per
hour.

This
rate
are
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
and
Costs
­
NSPS
for
Nitric
Acid
Plants
(
40
CFR
part
60,
subpart
G).
11
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
24
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
an
additional
one
affected
facility
at
an
existing
source
per
year
will
become
subject
to
the
regulation
over
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

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(
with
initial
notification
requirements)
(
E)
Number
of
Respondents
(
E=
A+
B+
CD

1
1
23
0
1
23
2
1
24
0
1
24
3
1
25
0
1
25
Average
1
24
0
1
24
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
twenty­
four.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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
1
3
24
2
0
51
12
The
number
of
Total
Annual
Responses
is
51.
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
$
81,639.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1,
Average
Annual
Industry
Burden
and
Costs,
NSPS
for
Nitric
Acid
Plants
(
40
CFR
part
60,
subpart
G).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
2,468,000.
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
is
estimated
to
average
25
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
adjustment
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
a
decrease
in
the
number
of
sources.
The
nitric
acid
industry
is
going
through
an
era
of
consolidations
and
buyouts,
due
in
part
to
the
high
cost
of
natural
gas
and
foreign
competition.
This
has
resulted
in
a
reduction
of
the
number
of
plants
producing
nitric
acid.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
25
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.
13
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
0030,
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
Avenue,
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
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,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0030
and
OMB
Control
Number
2060­
0019
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
14
Table
1:
Average
Annual
Industry
Burden
and
Costs
­
NSPS
for
Nitric
Acid
Plants
(
40
CFR
part
60,
subpart
G)

Burden
Item
(
A)
Respondent
Hours
per
Occurrence
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Hours
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
(
E)
Technical
Hours
Per
Year
@$
64.13
(
CXD)
(
F)
Management
Hours
Per
Year
@$
93.09
(
E
x
0.05)
(
G)
Clerical
Hours
Per
Year
@$
39.65
(
E
x
0.1)
(
H)
Total
Costs
Per
Year
a
1.
APPLICATIONS
N/
A
2.
SURVEY
AND
STUDIES
N/
A
3.
REPORTING
REQUIREMENTS
New
Sources
b
A.
Read
Instructions
1
1
1
1
1
0.05
0.1
$
72.74
B.
Required
Activities
Initial
Performance
Test
Demonstration
of
monitoring
system
Repeat
performance
test
c
Ref
Method
7
Ref
Method
2
360
Included
in
3B
360
4
4
1
1
1
1
360
360
4
4
1
0.2
1
1
360
72
4
4
18
3.6
0.2
0.2
36
7.2
0.4
0.4
$
26,189.82
$
5,237.96
$
291.00
$
291.00
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
N/
A
E.
Write
Report
New
Sources
Notification
of
construction/
reconstruction
Notification
of
initial
startup
Notification
of
initial
performance
test
Performance
test
report
Existing
Sources
Notification
of
physical/
operational
changes
d
Semiannual
reports
of
excess
emissions
e
2
2
2
Included
in
3B
8
8
1
1
1
1
1
2
2
2
8
8
1
1
1
2.4
24
2
2
2
19.2
192
0.1
0.1
0.1
0.96
9.6
0.2
0.2
0.2
1.92
19.2
$
145.50
$
145.50
$
145.50
$
1,396.80
$
13,967.90
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
4E
B.
Plan
Activities
Included
in
4E
C.
Implement
Activities
Included
in
4E
D.
Develop
record
systems
N/
A
E.
Time
to
enter
information
Records
of
daily
production
rate
and
hours
of
operation
8
1
8
24
192
9.6
19.2
$
13,967.90
Records
of
occurrence
of
startup,
shutdown,
and
malfunctions
Records
of
performance
test
data
8
80
1
1
8
80
24
1
192
80
9.6
4
19.2
8
$
13,967.90
$
5,819.96
G.
Audits
N/
A
TOTAL
ANNUAL
BURDEN
(
rounded)
1,122
f
56
f
112
f
$
81,639
15
Assumptions:

a.
Assume
that
all
tasks
are
to
be
performed
by
managerial,
technical
and
clerical
personnel.
This
ICR
uses
the
following
labor
rates:
$
93.09
for
Managerial
labor,
$
64.13
for
Technical
labor
and
$
39.65
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor
Bureau
of
Labor
Statistics,
September
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
We
also
included
contractors
at
$
100.
The
labor
rate
was
also
taken
from
the
above
occupational
and
industry
group
under
Blue­
Collar
occupation,
that
covers
Machine
operators,
and
took
the
rates
from
column
1,
"
Total
compensation."

b.
Assume
that
there
will
be
one
new,
modified
or
reconstructed
facility
constructed
for
the
next
three
years.

c.
Assume
that
20
percent
of
facilities
would
have
to
repeat
performance
testing
each
year
due
to
failure.

d.
Assume
that
10
percent
of
the
facilities
would
be
modified
or
reconstructed
over
the
next
three
years.

e.
Assume
that
it
will
take
eight
hours
to
write
semiannual
reports.

f.
The
total
number
of
hours
requested
is
1,290.
16
TABLE
2:
Average
Annual
EPA
Burden
and
Costs
­
NSPS
for
Nitric
Acid
Plants
(
40
CFR
part
60,
subpart
G)

Burden
Items
(
A)

EPA
hr./

Per
Occurrenc
e
(
B)
Occurrences
/
plant/
yr
(
C)

EPA
hr/

plant/
yr
(
C=
AxB)
(
D)
Plants/

year
(
E)
f
EPA
Hours
Per
Year
(
E=
CxD
)
(
F)
a
EPA
Cost
Per
Year
($)

(
Ex$
39.49)

Required
Activities
New
Plant
b
Initial
performance
test
c
Repeat
performance
tests
d
24
24
1
0.2
24
4.8
1
0.2
24
0.96
$
947.76
$
37.91
Report
Review
New
Plant
Notification
of
Construction/
Reconstruction/
Modification
Notification
of
initial
startup
Notification
of
actual
startup
Notification
of
initial
test
Existing
Plants
Semiannual
reports
2
0.5
0.5
0.5
2
1111
2
2
0.5
0.5
0.5
4
1111
24
2
0.5
0.5
0.5
96
$
78.98
$
19.74
$
19.74
$
19.74
$
3,791.04
Travel
Expenses:
e
(
1
person
x
1.2
plant
year
x
2
days/
plant
x
$
75
per
diem)
+

($
350
round
trip
x
1.2
plant/
year)
$
600.00
TOTAL
ANNUAL
BURDEN
(
rounded)
$
5,515
Assumptions:

a.
The
cost
is
based
on
the
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
is
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

b.
Assume
that
there
will
be
one
new
source
(
respondent)
per
year
over
the
three
years
period
of
this
ICR.

c.
Assume
that
it
would
take
24
hours
to
complete
initial
performance
test.

d.
Assume
20
percent
of
initial
performance
tests
are
repeated
due
to
failure.

e.
Assume
EPA
personnel
attend
10
percent
of
initial
tests
plus
10
percent
of
repeat
performance
tests.

f.
Total
number
of
burden
hours
of
this
ICR
is
124
(
rounded).
17
