SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Sulfuric
Acid
Plants
(
40
CFR
Part
60,
Subpart
H)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Sulfuric
Acid
Plants
(
40
CFR
Part
60,
Subpart
H)

1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
is
for
the
collection
of
periodic
reports,
test
data
and
recordkeeping
by
the
Regional
offices
or
delegated
States.
Initial
and
ongoing
compliance
data
is
being
collected
for
use
by
the
Regional
Offices,
the
Office
of
Enforcement
and
Compliance
Assurance
(
OECA)
and
the
States
in
determining
initial
and
ongoing
compliance
with
the
New
Source
Performance
Standards
(
NSPS).
The
information
is
collected
by
the
Region
or
delegated
authority
and
entered
into
the
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.
The
information
collection
will
involve
106
sources,
23,320
burden
hours
at
a
cost
of
$
1,290,529.
The
Office
of
Management
and
Budget
(
OMB)
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance."

The
New
Source
Performance
Standards
(
NSPS)
for
the
regulations
published
at
40
CFR
Part
60,
Subpart
H
were
proposed
on
August
17,
1971
and
promulgated
on
December
23,
1971.
These
regulations
apply
to
any
sulfuric
acid
facility
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal.
A
sulfuric
acid
plant
is
any
facility
producing
sulfuric
acid
(
H
2
SO
4)
by
the
contact
process
by
burning
elemental
sulfur,
alkylation
acid,
hydrogen
sulfide,
organic
sulfides
and
mercaptans,
or
acid
sludge.
A
sulfuric
acid
plant
does
not
include
facilities
where
conversion
to
sulfuric
acid
is
used
primarily
as
a
means
of
preventing
emissions
to
the
atmosphere
of
sulfur
dioxide
(
SO
2)
or
other
sulfur
compounds.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
H.

In
general,
all
NSPS
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
the
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
Environmental
Protection
Agency
(
EPA)
Regional
Office.
2
Approximately
106
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
new
sources
will
become
subject
to
the
regulation
in
the
next
three
years.
This
was
verified
by
industry
reports
from
Chemical
and
Engineering
News
and
the
on­
line
chemical
periodical,
Chempages.
com.
The
estimated
number
of
sources
was
also
verified
by
AIRS
data
and
reconciliation
with
the
Regional
contacts.
It
is
further
assumed
that
there
is
one
affected
facility
per
plant.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:

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

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,
SO
2
and
acid
mist
emissions
from
sulfuric
acid
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
H.
3
2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
SO
2
from
sulfuric
acid
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
proper
operation
and
maintenance
of
that
equipment.
Emissions
of
SO
2
and
acid
mist
from
sulfuric
acid
plants
are
the
result
of
operation
of
the
affected
facilities.
These
standards
rely
on
the
establishment
of
discharge
limits,
thus
ensuring
continuous
compliance
with
the
standards.
The
required
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
standard
is
being
met.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
EPA
reduced
the
reporting
frequency
for
this
information
from
quarterly
to
semiannually
in
a
December
1990
Federal
Register
notice.
The
reduction
in
reporting
frequency
was
respondent
to
OMB's
previous
questions
regarding
the
need
for
quarterly
versus
semiannual
reporting.
The
information
generated
by
the
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
these
standards,
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
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60,
Subpart
H.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
local
agency.
If
a
State
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
October
29,
2001.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
4
3(
c)
Consultations
No
telephone
consultations
were
performed
as
there
was
no
significant
change
in
burden.
The
preparer
of
this
ICR
consulted
EPA
databases
and
industry
websites
as
detailed
in
section
1(
b)
above
to
determine
industry
growth
and
size.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.6.

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
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
sulfuric
acid
plants.
A
sulfuric
facility
is
any
facility
producing
sulfuric
acid
by
the
contact
process
by
burning
elemental
sulfur,
alkylation
acid,
hydrogen
sulfide,
organic
sulfides
and
mercaptans,
or
acid
sludge,
but
does
not
include
facilities
where
conversion
to
sulfuric
acid
is
used
primarily
as
a
means
of
preventing
emissions
to
the
atmosphere
of
sulfur
dioxide
or
other
sulfur
compounds.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
5
Classification)
2819
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
325188
inorganic
chemical
production.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
the
New
Source
Performance
Standards
for
Sulfuric
Acid
Plants
(
40
CFR,
Part
60,
Subpart
H).

Reports
for
40
CFR
Part
60,
Subpart
H
Construction/
reconstruction
60.7(
a)(
1)

Anticipated
startup
60.7(
a)(
2)

Actual
startup
60.7(
a)(
3)

Initial
performance
test
results
60.8
(
a)

Initial
performance
test
60.8(
d)

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

Physical
or
operational
change
60.7(
a)(
4)

Excess
emissions
60.7(
a)

Reference
Test
Method
9
60.11(
b)

A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
60,
Subpart
H
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
60.7(
b)

Records
are
required
to
be
retained
for
2
Years
60.7(
f)

Subsequent
annual
performance
tests,
as
required
60.7(
f)
6
(
ii.)
Respondent
Activities
Respondent
Activities
Read
instructions.

Perform
initial
performance
test,
Reference
Method
9
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
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

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

The
information
may
be
collected
manually
or
electronically.
Electronic
submissions
can
be
made.

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.
7
Agency
Activities
Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.

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
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
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
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
The
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
2:
Industry
Burden.
8
6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
Subpart
H.
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.

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
23,320
(
Total
Labor
Hours
from
Table
2).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
Technical
Labor
Rate
of
$
55.34
per
hour.
This
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rate
was
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
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
and
the
purchase
of
a
continuous
emissions
monitoring
(
CEM)
device.
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.
9
(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Startup
Cost
($)
for
One
Affected
Facility
(
C)
Number
of
New
Affected
Facilities
to
Startup
(
D)
Total
Startup
(
B
X
C)
(
E)
Annual
O&
M
Costs
($)
for
One
Affected
Facility
(
F)
Number
of
Affected
Facilities
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

CEM
120,000
0
0
4,500
106
$
477,000
The
total
capital/
startup
costs
for
this
ICR
are
$
0,
since
there
are
no
new
source
purchasing
monitors.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
477,000.
This
is
the
total
of
column
G.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
non­
labor
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
are
estimated
to
be
$
477,000.
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.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
31,359
(
see
Table
1
in
Section
6(
e)).
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
$
36.98.
These
rates
are
from
the
Office
of
Personnel
and
Management's
(
OPM)
"
2001
General
Schedule"
which
excludes
locality
rates
of
pay.
10
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
Regulation
Citation
(
A)
Number
of
New
Sources/
Year
(
B)
Number
of
Initial
Reports
for
New
Sources
(
C)
Number
of
Existing
Sources
(
D)
Number
of
Reports
for
Existing
Sources
(
E)
Total
Annual
Responses
(
AxB)+(
CxD)

60.7(
a)
0
2
106
2
212
60.7(
a)(
1)&(
a)(
4)
0
1
106
0
0
60.7(
a)(
2)
0
1
106
0
0
60.7(
a)(
3)
0
1
106
0
0
60.7(
a)(
5)
0
1
106
0
0
60.8(
a)
0
1
106
0
0
60.8(
d)
0
1
106
0
0
Total
212
The
number
of
total
respondents
is
106.
This
number
is
the
sum
of
column
A
and
column
C
of
the
Respondent
Universe
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period.
It
is
shown
in
block
13
(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
212.
This
is
the
number
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
in
block
13
(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
The
total
annual
labor
costs
are
$
1,290,529.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2.
Annual
Respondent
Burden
and
Cost.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
477,000.
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
as
Table
1
and
2
respectively.
11
6(
f)
Reasons
for
Change
in
Burden
There
is
no
change
in
burden
from
the
most
recently
approved
ICR
since
there
are
no
new
sources.
The
burden
costs,
however,
have
increased
due
to
a
more
accurate
adjustment
benefit
packages,
and
an
updating
to
the
most
recently
available
labor
costs.

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
standards
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
through
the
use
of
automated
collection
techniques
to
Ms.
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822T),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
Number
and
OMB
Control
Number
in
any
correspondence.

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
MONITORING
OF
SULFURIC
ACID
PLANTS
Activity
(
A)

EPA
hour/
Occurrences
(
B)
Occurrences
Plant/
year
(
C)
a
EPA
hour/

Plant/
year
(
D)
Plants/

year
(
E)
b
EPA
Hr/
yr
(
F)
c
EPA
Cost
($)

New
Plants
Initial
Performance
Tests
d
50
1
50
0
0
$
0
Repeat
Performance
Test
Observed
e
24
0.2
4.8
0
0
$
0
Report
Review:

Notified
of
Construction
2
1
2
0
0
$
0
Notified
of
Anticipated
Startup
0.5
1
0.5
0
0
$
0
Notified
of
Actual
Startup
0.5
1
0.5
0
0
$
0
Notified
of
Initial
Test
0.5
1.2
0.6
0
0
$
0
Review
Test
Results
8
1.2
9.6
0
0
$
0
Notified
of
CMS
Demonstation
0.5
1
0.5
0
0
$
0
Existing
Plants
Excess
Emission
Reports
4
2
8
106
848
$
31,359
TOTAL
ANNUAL
HOURS
848
$
31,359
a)
A
x
B
=
C.

b)
C
x
D
=
E.

c)
F
=
E
x
$
36.98[
GS­
12,
Step
1
@
23.11
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses].

d)
Includes
CEM
demonstration.

e)
Assumes
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure.
TABLE
2:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDS
NSPS
SUBPART
H
SULFURIC
ACID
PLANTS
(
A)

Person/
hours
Occurrences
(
B)
Occurrences/

Plant
(
C=
AxB)
a
Person/
hrs
Responden
t
(
D)
Number
of
Respondents
(
E=
CxD)

Total
Annual
Person/
hours
(
F)
b
Industry
Cost/
year
1.
APPLICATIONS
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
Not
Applicable­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

2.
SURVEY
&
STUDIES
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
Not
Applicable­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
1
1
1
0
0
0
B.
Required
Activities
Initial
Performance
Test
c
300
1
300
0
0
0
Reference
Method
9
Test
4
1
4
0
0
0
Repeat
of
Performance
9
Test
d
300
0
0
0
0
0
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3B
E.
Write
Report
­
Notify
of
construction/

reconstruction/
modification/
physical
or
operational
change
2
1
2
0
0
0
­
Notify
of
anticipated
startup
2
1
2
0
0
0
­
Notify
of
actual
startup
2
1
2
0
0
0
­
Notify
of
initial
performance
test
2
1
2
0
0
0
(
A)

Person/
hours
Occurrences
(
B)
Occurrences/

Plant
(
C=
AxB)
a
Person/
hrs
Responden
t
(
D)
Number
of
Respondents
(
E=
CxD)

Total
Annual
Person/
hours
(
F)
b
Industry
Cost/
year
­
Notify
of
demonstration
of
CMS
2
1
2
0
0
0
­
Excess
Emission
Reports
40
2
80
106
8480
$
469,283
SUBTOTAL:
REPORTING
BURDEN
8480
$
469,283
4.
RECORDKEEPING
REQMTS
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
3B
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
N/
A
E.
Time
to
enter
information:

Records
of
Operating
Parameters
0.25
350
88
106
9275
$
513,279
Calculation/
Record
of
Conversion
Factors
e
0.05
1050
53
106
5565
$
307,967
F.
Train
Personnel
N/
A
G.
Audits
N/
A
SUBTOTAL:
RECORDKEEPING
BURDEN
14840
$
821,246
TOTAL
ANNUAL
BURDEN
TO
INDUSTRY:
23320
$
1,290,529
a)
A
x
B
=
C.

b)
F
=
E
x
55.34
([
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rate
has
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

c)
Includes
CEM
demonstration.

d)
Assume
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure.

e)
Assume
conversion
factor
calculated
three
times
daily:
3
x
350
=
1,050
occurrences/
respondent/
year.
