SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
PHOSPHATE
FERTILIZER
INDUSTRY
NSPS
SUBPARTS
T,
U,
V,
W,
AND
X
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
T,
U,
V,
W,
and
X
B
Phosphate
Fertilizer
Industry
1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
the
Phosphate
Fertilizer
Industry
were
proposed
on
October
22,
1974
and
promulgated
on
August
6
1975.
These
standards
apply
to
each
wet
phosphoric
acid
plant,
each
super
phosphoric
acid
plant,
each
granular
diammonium
phosphate
plant,
and
each
triple
superphosphate
plant,
having
a
design
capacity
of
more
than
15
tons
of
equivalent
phosphorous
pentoxide
(
P
2
O
5)
feed
per
calendar
day.
These
standards
also
apply
to
granular
triple
superphosphate
storage
facilities.
Specific
affected
facilities
for
each
subpart
are
found
at
40
CFR.
60.200,
60.210,
60.220,
60.230
and
60.240.
Eleven
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
over
the
next
three
years.
The
average
annual
cost
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
52,880.
Fluorides
are
the
pollutants
regulated
under
this
standard.
Phosphate
fertilizer
plants
shall
not
discharge
gases
to
the
atmosphere
in
excess
of
the
following
grams/
metric
tone
of
equivalent
P
2
O
5:
10/
0
g/
ton
for
wet
phosphoric
acid,
5.0
g/
ton
for
super
phosphoric
acid,
30
g/
ton
for
diammonium
phosphate
plant,
100
g/
ton
for
triple
superphosphate
plant,
and
0.25
g/
hours/
metric
ton
for
granular
triple
superphosphate
storage.

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;
the
notification
of
the
initial
performance
test;
and
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.
These
notifications,
reports
and
records
are
required,
in
general,
of
all
sources
subject
to
NSPS.

Recordkeeping
requirements
specific
to
phosphate
fertilizer
industry
provide
information
on
the
amount
of
fertilizer
processed,
and
the
operation
of
the
emission
control
device
(
scrubber
system).
Owners
or
operators
of
affected
facilities
(
excepting
phosphate
storage
facilities)
are
required
to
install,
calibrate,
maintain,
and
operate
a
flow
monitoring
device
which
can
be
used
to
­
2­
determine
the
mass­
flow
of
phosphorous­
bearing
feed
material
to
the
process.
Owners
or
operators
shall
maintain
a
daily
record
of
equivalent
P
2
O
5
feed
calculated
from
the
mass
rate
measured
by
the
CMS.
Owners
or
operators
of
phosphate
storage
facilities
are
required
to
maintain
an
accurate
account
of
triple
superphosphate
stored
to
permit
the
determination
of
the
amount
of
equivalent
P
2
O
5,
and
shall
calculate
and
maintain
daily
records
of
the
equivalent
P
2
O
5
stored.
Owners
or
operators
of
all
affected
facilities
shall
install,
calibrate,
maintain,
and
operate
a
monitoring
device
which
continuously
measures
and
permanently
records
the
total
pressure
drop
across
the
process
scrubbing
system.

Therefore,
the
recordkeeping
requirements
for
phosphate
fertilizer
plants
consist
of
the
occurrence
and
duration
of
all
start­
ups
and
malfunctions
as
described,
the
initial
performance
tests
results,
amount
of
phosphate
feed
material,
equivalent
calculated
amounts
of
P
2
O
5,
and
the
pressure
drop
across
the
scrubber
system.
Records
of
startups,
shutdowns
and
malfunctions
shall
be
noted
as
they
occur.
Records
of
the
performance
test
should
include
information
necessary
to
determine
the
conditions
of
the
performance
test,
and
performance
test
measurements
(
including
pressure
drop
across
the
scrubber
system)
and
results
(
specified
in
detail
at
40
CFR
60.204,
60.214,
60.224,
60.234,
and
60.244
Test
Methods
and
Procedures
and
60.8
Performance
Test).
The
amount
of
equivalent
P
2
O
5
stored
or
the
amount
of
feed
shall
be
calculated
and
recorded
daily.
The
CMS
shall
record
pressure
drop
across
the
scrubbers
continuously
and
automatically.

The
reporting
requirements
for
this
industry
include
the
initial
notifications
listed,
and
the
initial
performance
test
results.
Notifications
shall
be
sent
out
prior
to
the
specified
events.
Deadlines
for
notification
are
listed
at
40
CFR
60.7.
Requirements
for
the
performance
test
reports
are
given
at
the
sections
above,
and
shall
include
the
emissions
of
total
fluorides
in
gram/
metric
ton
of
equivalent
P
2
O
5.
This
industry
is
not
required
to
submit
excess
emission
reports.

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
nonair
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
Section
lll(
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:
­
3­
.
.
.
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)
provide
such
other
information,
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
particulate
emissions
from
the
ammonium
sulfate
manufacturing
industry
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
Subparts
T,
U,
V,
W,
and
X.
.
2(
b)
Practical
Utility/
Users
of
The
Data
Source
data
and
information
requirements
for
phosphate
fertilizer
plants
are
outlined
in
Table
A.
The
standards
require
the
initial
reports
required
by
the
general
provisions
of
40
CFR
60.7.
These
initial
reports
include
notification
of
construction
or
modification,
reconstruction,
and
startup,
shutdown,
or
malfunction.
The
standards
also
require
recordkeeping
to
document
information
relating
to
the
daily
feed
rate
and
storage
of
equivalent
phosphorus
pentoxide.
Equivalent
amounts
of
P
2
O
5
are
determined
from
CMS
records
of
phosphate­
bearing
feed
material
or
accounts
for
triple
superphosphate
stored.
The
standards
are
defined
in
terms
of
grams
of
fluorides
emitted
per
metric
ton
of
equivalent
P
2
O
5
processed.

The
standards
are
hourly
emission
standards
and
are
a
function
of
the
hourly
feed
rate
of
phosphate­
bearing
materials.
As
such,
it
is
incumbent
upon
the
personnel
monitoring
the
source
to
determine
the
feed
rate
per
hour
in
order
to
establish
that
the
facility
is
in
compliance.
The
regulations
require
recordation
and
maintenance
of
daily
records
for
purposes
of
determining
and
verifying
the
feed
rate
factor
used
in
the
compliance
equation.
Requiring
sources
to
record
and
retain
hourly
feed
rate
records
would
allow
EPA
to
monitor
compliance
more
precisely.
However,
the
regulation
requires
daily
rather
than
hourly
recordkeeping
because
it
is
the
least
burdensome
necessary
for
the
proper
performance
of
the
agency's
functions
to
comply
with
legal
requirements
and
program
objectives.
Indeed,
according
to
industry­
personnel
surveyed
in
an
informal
poll,
the
daily
feed
rate
recordation
requirement
places
no
additional
burden
on
the
industry.
This
is
so
because
proper
plant
operation
and
industry
practice
include
daily
recordation
of
amounts
of
phosphate­
bearing
feed
processed.
According
to
industry
personnel,
this
practice
predates
the
regulation
and
would
continue
in
its
absence.
Because
the
daily
recordation
requirement
places
no
additional
burden
on
industry
and
because
P
2
O
5
feed
rates
are
essential
to
determining
compliance
with
the
standard,
the
regulation
requires
daily
recordation
of
the
amount
of
P
2
O
5
stored.
The
records
must
be
retained
at
the
facility
for
a
minimum
of
two
(
2)
years.

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
­
4­
constructed
and
therefore
is
subject
to
the
standards.
Under
the
standard,
data
collected
by
an
affected
facility
is
retained
at
the
source
for
a
minimum
of
two
years
and
made
available
for
inspection
by
the
Administrator.

If
the
information
required
by
the
standards
were
not
collected,
the
Agency
would
have
no
means
for
ensuring
that
compliance
with
the
NSPS
is
achieved
and
maintained
by
new,
modified,
or
reconstructed
sources
subject
to
the
regulations.
Under
these
circumstances,
an
owner
or
operator
could
elect
to
reduce
operating
expenses
by
not
installing,
maintaining,
or
otherwise
operating
the
control
technology
required
by
the
standards.
In
the
absence
of
the
information
collection
requirements,
compliance
with
the
standards
could
be
ensured
only
through
continuous
on­
site
inspections
by
regulatory
agency
personnel.
Consequently,
not
collecting
the
information
would
result
in
either
greatly
increased
expenditures
of
resources,
or
the
inability
to
ensure
compliance
with
the
standards.

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
Certain
reports
or
records
required
by
State
or
local
agencies
may
duplicate
information
required
by
this
rule.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
these
standards.

There
are
no
other
sources
of
similar
information
since
the
standards
ask
for
records
of
daily
feed
rate
and
storage
unique
to
each
phosphate
fertilizer
plant.

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
January
21,
2000.

3(
c)
Consultations
No
comments
were
received
in
response
to
the
published
federal
register
notice.
In
addition
to
soliciting
public
comment,
Agency
program
personnel
with
expertise
in
this
industry
were
consulted.
­
5­
3(
d)
Effects
of
less
Frequent
Collection
If
the
information
required
by
these
standards
was
collected
less
frequently,
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
and
emission
limitations
are
met.

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
and
Sensitive
Questions
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
requirements
are
phosphate
fertilizer
plants
(
SIC
Code
2874).

4(
b)
INFORMATION
REQUESTED
i.
Data
Items
Reporting
Provide
notification
of
­
construction/
reconstruction
­
anticipated
startup
­
actual
startup
­
6­
­
initial
performance
test
Record
­
daily
feed
rate
and
storage
­
initial
performance
test
results
­
startups,
shutdowns,
and
malfunctions
­
control
device
operating
parameters
(
continuous)

ii.
Respondent
Activities
­
read
instructions
­
perform
initial
performance
test,
and
repeat
performance
tests
­
write
the
notifications
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
no
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
information
required
under
40
CFR
Subparts
T,
U,
V,
W,
and
X.
No
new
facilities
are
anticipated
to
open
during
the
next
three
years.
The
only
requirement
for
existing
facilities
is
recordkeeping
by
the
respondents,
which
does
not
require
activity
by
the
Agency.

5(
b)
Collection
Methodology
and
Management
All
reports
are
sent
to
the
delegated
State
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.
Notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
operated.

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.
­
7­
5(
c)
Small
Entity
Flexibility
Currently
the
number
of
employees
at
a
typical
fertilizer
plant
exceeds
the
criterion
for
small
business,
and
no
new
facilities
are
expected
within
the
next
three
years,
so
this
information
collection
requirement
is
not
anticipated
to
impact
small
businesses.
The
recordkeeping
requirements
were
selected
within
the
context
of
a
small
collection
of
process
equipment
and
reflect
the
burden
on
either
small
or
larger
businesses
should
they
fall
under
the
recordkeeping
requirements
of
this
rule.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
their
overall
burden
will
be
reduced.
However,
even
though
the
recordkeeping
requirements
are
the
same
for
small
and
larger
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
information
collection
activity
within
this
request
consists
of
daily
(
350
per
year)
recordkeeping
occurrences
of
0.25
hours
each.

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.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory
as
required
at
40
CFR
Part
60
Subparts
T,
U,
V,
W,
and
X.
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
at
962.5
(
total
from
industry
table)
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,
NESHAP,
MACT)
program,
the
previously
approved
ICR,
and
any
comments
received
about
time
to
prepare
reports.

6(
b)
Estimating
Respondent
Costs
This
ICR
uses
a
technical
labor
rate
of
$
54.94
per
hour
including110
per
cent
overhead
to
determine
the
cost
to
respondents.
This
rate
is
from
the
United
States
Department
of
Labor
­
8­
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.
The
wage
rates
have
been
loaded
by
adding
110%
overhead.
The
average
annual
cost
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
52,880.

The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.

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.

Since
the
Agency
burden
is
associated
with
the
analysis
of
reported
information,
and
reporting
is
only
associated
with
the
construction
or
reconstruction
of
facilities,
and
no
such
construction
or
reconstruction
is
anticipated
in
the
next
three
years,
no
Agency
burden
is
anticipated
in
this
ICR.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
40
CFR
Part
60
Subparts
T,
U,
V,
W,
and
X
is
11.
No
new
sources
are
anticipated.
The
total
annual
labor
costs
are
$
52,880.
There
are
no
annual
capital
and
operating/
maintenance
costs
to
the
regulated
entity.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
(
See
Table
1,
attached)

6(
f)
Reasons
for
Change
in
Burden
There
is
no
change
in
burden
from
the
existing
ICR.

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
­
9­
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
through
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,
NW,
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
1061.08
and
OMB
control
number
2060­
0037
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
