SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
SUBPART
NN
PHOSPHATE
ROCK
PLANTS
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
NN
­
Phosphate
Rock
Plants
Subject
to
New
Source
Performance
Standards
1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
phosphate
rock
plants
were
proposed
on
September
21,
1979
and
promulgated
on
April
16,
1982.
These
standards
apply
to
the
following
facilities
in
phosphate
rock
plants
with
capacities
greater
than
4
tons/
hour:
dryers,
calciners,
grinders,
and
ground
rock
handling
and
storage
facilities,
(
except
those
facilities
producing
or
preparing
phosphate
rock
solely
for
consumption
in
elemental
phosphorus
production),
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
subpart
NN.

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
anticipated
and
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
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
is
inoperative.
These
notifications,
reports
and
records
are
required,
in
general,
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.

Sixteen
sources
are
currently
subject
to
these
standards,
and
it
is
estimated
that
an
additional
two
sources
per
year
will
become
subject
to
the
standards
in
the
next
three
years.
­
2­

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,
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)).

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
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
particulate
matter
emissions
from
phosphate
rock
plants
cause
or
contribute
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
subpart
NN.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
particulate
matter
from
phosphate
rock
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
particulate
matter
from
phosphate
rock
plants
are
the
result
of
operation
of
the
calciners,
dryers,
grinders,
and
ground
rock
handling
and
storage
facilities.
These
standards
rely
on
the
capture
of
particulate
emissions
by
a
baghouse
or
wet
scrubber.

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
check
if
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
needed
as
these
are
the
­
3­

Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard
and
note
the
operating
conditions
(
flow
rate
and
pressure
drop)
under
which
compliance
was
achieved.
The
quarterly
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
standard
also
requires
semiannual
reporting
of
deviations
from
monitored
scrubber
pressures
or
opacity,
as
these
are
good
indicators
of
the
source's
compliance
status.
EPA
reduced
the
reporting
frequency
for
this
information
from
quarterly
to
semiannual
in
a
December
1990
Federal
Register.
This
reduction
in
reporting
frequency
is
in
response
to
OMB's
previous
questions
regarding
the
need
for
quarterly
versus
semiannual
reporting.
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
the
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.
In
order
to
ensure
compliance
with
these
standards,
adequate
recordkeeping
is
necessary.
In
the
absence
of
such
information,
enforcement
personnel
would
be
unable
to
determine
whether
the
standards
are
being
met
on
a
continuous
basis,
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
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60
subpart
NN.
If
the
standard
has
not
been
delegated
the
information
is
sent
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
regulation
to
implement
NSPS
subpart
NN,
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
Standard.
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
15,
2000
(
65
FR
55955).

3(
c)
Consultations
In
developing
the
standards,
several
States,
a
number
of
State
agencies,
owners
and
operators
of
affected
facilities,
and
other
interested
parties
were
contacted.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
­
4­

If
the
frequency
of
information
collection
was
further
reduced,
the
main
consequence
would
be
that
the
chances
of
detecting
poor
operation
and
maintenance
of
control
equipment
would
decrease.
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied.

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
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
contained
in
40
CFR
Part
60
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
Phosphate
Rock
Plants,
SIC
Code
1479
(
NAIC
Code
212393)
with
a
rated
capacity
in
excess
of
4
tons/
hour
and
which
commenced
construction
modification,
or
reconstruction
after
September
21,
1979.

4(
b)
Information
Requested
(
i)
Data
Items
All
of
the
data
in
this
ICR
that
is
recorded
and
reported
is
required
by
40
CFR
Part
60
subpart
NN,
as
indicated.

Provide
notification
of
­
5­

­
construction/
reconstruction
[
60.7(
a)(
1)]
­
anticipated
startup
[
60.7(
a)(
2)]
­
actual
startup
[
60.7(
a)(
3)]
­
initial
performance
test
[
60.8(
d)]
­
demonstration
of
continuous
monitoring
system
[
60.7(
a)(
5)]
­
physical
or
operational
change
[
60.7(
a)(
4)]

Report
on
­
initial
performance
test
[
60.8(
a)]
­
excess
emissions
[
60.403(
f)]

Record
­
startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
[
60.7(
b)]
­
performance
tests
[
60.7(
d)]
­
install,
calibrate,
maintain,
and
operate
a
device
to
measure
phosphate
rock
feed
to
any
dryer,
calciner,
or
grinder
[
60.403(
d)]
­
install,
calibrate,
maintain,
and
operate
CMS
for
opacity
[
60.403(
a)],
unless
a
wet
scrubber
is
installed
­
if
a
wet
scrubber
is
installed,
install,
calibrate,
maintain,
and
operate
CMS
for
pressure
loss
across
scrubber
and
liquid
supply
[
60.403(
c)]

Records
are
required
to
be
retained
for
two
years.

(
ii)
Respondent
Activities
­
read
instructions
­
install,
calibrate,
maintain,
and
operate
CMS
for
opacity,
or
for
pressure
drop
and
liquid
supply
pressure
for
wet
scrubber
­
perform
initial
performance
test,
Reference
Method
9
test
(
if
opacity),
and
repeat
performance
tests
if
necessary
­
write
the
notifications
and
reports
listed
above
­
enter
information
required
to
be
recorded
above.

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
information
required
under
40
CFR
subpart
NN:

­
observes
initial
and
repeat
performance
tests
­
6­

­
reviews
notifications
and
reports,
including
excess
emissions
reports,
required
to
be
submitted
by
industry
­
audits
facility
records
5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
check
if
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
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
tabulated
and
published
for
internal
Agency
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
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
The
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
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
EPA
Regional
Offices
and
Headquarters.
EPA
can
edit,
store,
retrieve
and
analyze
the
data
via
PC
terminals.

The
records
required
by
this
NSPS
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
a
small
collection
of
process
equipment
and
reflect
the
burden
on
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
However,
even
though
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
large
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance,
and
therefore
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2.
­
7­

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
The
standard
does
not
specify
reporting
or
recordkeeping
methodology.
Therefore,
the
information
may
be
collected,
to
the
maximum
extent
practicable,
in
a
manner
consistent
and
compatible
with
the
respondent's
existing
reporting
and
recordkeeping
requirements.
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)
Estimates
of
Respondent
Burden
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
The
labor
estimates
used
in
Table
2
were
derived
from
standard
estimates
based
on
EPA's
experience
with
other
standards.
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
3002
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received
about
time
to
prepare
reports.

6(
b)
Estimates
of
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
technical
labor
rate
of
$
56.99
per
hour.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rate
from
column
1:
Total
compensation
was
adjusted
using
the
BLS
Employer
Cost
Index
values
for
2001
The
year
2000
total
compensation
for
technical
workers
was
$
26.35,
which
adjusted
by
a
factor
of
1.03
(
the
2001:
2000
cost
index
ratio)
yielded
a
March
2001
labor
rate
of
$
27.14
per
hour.
This
was
then
adjusted
by
a
110
percent
to
account
for
overhead
and
benefits,
providing
the
hourly
rate
of
$
56.99
per
hour
used
to
estimate
total
labor
costs
in
this
ICR.
The
average
annual
labor
burden
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
171,067.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
and
opacity
continuous
emissions
monitors.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
annual
capital
start
up
cost
for
­
8­

this
regulation
is
$
73,800.
This
is
based
on
two
new
sources
per
year
multiplied
by
$
36,900
per
opacity
monitoring
device.
The
annual
operations
and
maintenance
cost
is
estimated
to
be
$
252,650.
This
is
based
on
an
average
of
31
existing
sources
multiplied
by
$
8,150
for
upkeep
of
the
monitoring
device.
These
costs
are
based
on
the
assumption
that
all
affected
entities
will
face
the
costs
of
the
more
expensive
monitoring
system
(
opacity)
rather
than
the
less
expensive
monitoring
system
(
pressure
drop)
which
would
occur
if
wet
scrubbers
are
used
as
a
control
device.
Therefore,
this
estimate
likely
overstates
the
actual
annual
burden
to
industry.
The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
burden
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
326,450.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Monitoring
Device
Start
up
Cost
($)
Annual
O&
M
Costs
($)
Opacity
Monitor
$
36,900
$
8,150
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
10,328.
This
cost
is
based
on
an
average
wage
of
$
27.17
per
hour
and
a
110
percent
overhead
rate.
Details
upon
which
this
estimate
is
based
appear
in
Table
1.
Breakdown
of
costs
by
cost
category
is
presented
as
follows:

Average
Direct
Personnel
Cost
(
including
overhead)
$
10,328
Other
Direct
Costs
$
1,246
Total
$
11,574
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
respondents
subject
to
40
CFR
Part
60
subpart
NN
is
estimated
to
be
28.
The
number
of
new
respondents
subject
to
40
CFR
Part
60
subpart
NN
is
estimated
to
be
two
per
year,
an
assumption
carried
forward
from
the
last
ICR
renewal
The
total
annual
labor
­
9­

costs
are
$
171,124
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
326,450
Details
upon
which
the
estimate
of
labor
costs
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
Tables
1
and
2.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
number
of
plants
is
assumed
to
continue
to
increase
at
the
rate
presumed
in
the
previous
ICR
at
2
per
year,
for
an
average
total
of
31
plants
during
the
period
of
this
ICR.
The
total
reporting
requirement
for
new
plants
is
determined
to
remain
constant
at
97
hours.
Excess
emission
reporting
burden
is
estimated
to
increase
incrementally
from
160
to
192,
based
on
the
average
number
of
existing
facilities
increasing
from
25
to
31.
Recordkeeping
burden
is
estimated
to
increase
incrementally
from
2,188
hours
to
2,714,
based
on
an
increase
in
the
average
number
of
facilities
to
31.
Finally,
the
capital/
start­
up
and
operating
and
maintenance
(
O&
M)
costs
associated
with
installing
and
operating
continuous
monitoring
systems,
which
was
calculated
for
the
previous
ICR
at
$
257,100,
was
increased
to
$
326,450
for
this
ICR
based
on
an
adjustment
for
inflation
for
costs
and
an
increase
in
the
estimated
number
of
facilities.

6(
g)
Burden
Statement
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
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,
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
Mail
code
2822,
1200
Pennsylvania
Avenue,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
­
10­

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
TABLE
1:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
PHOSPHATE
ROCK
INDUSTRY
NSPS
SUBPART
NN
Activity
(
A)
EPA
hr/
Occurrence
(
B)
Occurrence
s
/
yr
(
C)
a
EPA
hr/
yr
(
D)
Respondent
s
/
yr
(
E)
b
EPA
h/
yr
Initial
Performance
Test
New
Plant
24
1
24
2
48
Repeat
Performance
Test
c
New
Plant
24
0.2
4.8
2
9.6
Report
Review
New
Plant
Notification
of
Construction
2
1
2
2
4
Notification
of
anticipated
startup
0.5
1
0.5
2
1
Notification
of
actual
startup
0.5
1
0.5
2
1
Notification
of
initial
test
0.5
1.2
0.6
2
1.2
Review
test
results
8
1.2
9.6
2
19.2
Notification
of
demonstration
of
CMS
0.5
1
0.5
2
1
Excess
emission
reports
d
4
2
8
12
96
TOTAL
ANNUAL
HOURS
181
Travel
expenses
(
1
person
x
2
plants/
yr
x
3
days/
plant
x
$
81
per
diem)
+
($
380/
round
trip
x
2
plants/
yr)
=
$
1,246/
year
Salary
(
1
person
x
181hr/
year
x
57.06/
hr
e)
=
$
10,328
TOTAL
ANNUAL
COST
TO
EPA
=
$
11,574
a
AxB=
C
b
CxD=
E
c
Assume
20
percent
of
initial
performance
tests
are
repeated
due
to
failure
d
Assume
that
40%
of
affected
facilities
must
submit
excess
emissions
reports
e
Assume
an
hourly
wage
of
$
27.17
plus
110
percent
overhead,
which
equals
$
57.06
Table
2.
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements
for
Phosphate
Rock
Industry
B
NSPS
Subpart
NN
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C=
AxB)

Hours/
Respondent/

year
(
D)
Respondents
per
year
(
E­
CxD)

Hours
per
year
(
F)
Cost
per
yearc
1.
APPLICATIONS
N/
A
­
­
N/
A
­
­

2.
SURVEY
AND
STUDIES
N/
A
­
­
N/
A
­
­

3.
REPORTING
REQUIREMENTS
A.
Read
Instructionsa
1
1
1
2
2
$
114
B.
Required
Activities
Initial
performance
testd
28
1
28
2
56
$
3,191
Repeat
of
performance
testde
28
0.2
5.6
2
11.2
$
638
Reference
Method
9
test
4
1
4
2
8
$
456
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
of
construction/

modification
2
1
2
2
4
$
228
Notification
of
anticipated
startup
2
1
2
2
4
$
228
Notification
of
actual
startup
2
1
2
2
4
$
228
Notification
of
initial
performance
test
2
1
2
2
4
$
228
Notification
of
demonstration
CMS
test
2
1
2
2
4
$
228
Report
of
performance
test
Included
in
3B
Excess
opacity
or
scrubber
malfunction
reportsb
8
2
16
12
192
$
10,942
SUBTOTALS
289.2
$
16,482
Table
2.
Burden
to
Industry,
NSPS
Subpart
NN
(
continued)

(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C=
AxB)

Hours/
Respondent/

year
(
D)
Respondents
per
year
(
E­
CxD)

Hours
per
year
(
F)
Cost
per
yearc
4.
RECORDKEEPING
REQUIREMENTS
A,
Read
Instructions
B.
Plan
Activities
C.
Implement
Activities
D.
Develop
Record
System
E.
Time
to
Enter
Information
Record
of
operating
parametersfg
0.25
350
87.5
31
2712.5
$
154,585
F.
Train
Personnel
G.
Audits
TOTAL
ANNUAL
BURDEN
3001.7
$
171,067
a
Assume
a
total
of
2
newly
affected
facilities
per
year.

b
Assume
40%
of
affected
facilities
submit
excess
emissions
reports
c
Assume
an
hourly
wage
of
$
27.14
plus
110
percent
overhead
costs,
which
equals
$
56.99
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

d
Includes
burden
associated
with
monitoring
phosphate
feed
rate
e
Assume
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure.

f
Assume
operation
350
days
per
year
as
specified
in
the
NSPS
review
document.

g
Midpoint
of
ICR.
28
+
(
2
new
per
years
x
3
years)
/
2
=
31
