SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
National
Emission
Standards
For
Hazardous
Air
Pollutants
(
NESHAP)
Subparts
AA
&
BB,
Standards
For
Phosphoric
Acid
Manufacturing
And
Phosphate
Fertilizers
Production
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP
Subparts
AA
&
BB­­
Phosphoric
Acid
Manufacturing
and
Phosphate
Fertilizers
Production.

1(
b)
Short
Characterization/
Abstract
Potential
respondents
are
owners
or
operators
of
existing
phosphoric
acid
manufacturing
and
phosphate
fertilizers
production
facilities
located
in
seven
States.
The
rule
applies
to
component
processes
at
these
facilities
and
to
any
new,
modified,
or
reconstructed
sources.
Component
processes
include
wet
process
phosphoric
acid
plants,
superphosphoric
acid
plants,
purified
phosphoric
acid
plants,
phosphate
rock
dryers,
phosphate
rock
calciners,
diammonium
and
monoammonium
phosphate
plants,
and
granular
triple
superphosphate
(
GTSP)
plants.
Since
many
of
the
facilities
affected
by
the
standards
are
also
subject
to
new
source
performance
standards
(
NSPS),
the
standards
include
an
exemption
from
the
NSPS
for
those
sources.
The
exemption
eliminates
a
duplication
of
information
collection
requirements.

Consistent
with
the
General
Provisions
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Source
Categories
(
40
CFR
Part
63,
Subpart
A),
respondents
do
not
include
the
owner
or
operator
of
any
facility
that
is
not
a
major
source.
Respondents
submit
one­
time
notifications
(
where
applicable)
and
a
one­
time
report
on
performance
test
results
and
must
notify
EPA
if
annual
performance
tests
indicate
a
change
in
the
baseline
operating
range
of
emission
control
equipment.
Plants
must
develop
and
implement
a
startup,
shutdown,
and
malfunction
plan
and
submit
semiannual
reports
of
any
event
where
the
plan
was
not
followed.
Semiannual
reports
for
periods
of
operation
during
which
the
monitoring
parameter
boundaries
established
during
the
initial
compliance
test
are
exceeded
(
or
reports
certifying
that
no
exceedances
have
occurred)
also
are
required.
General
requirements
applicable
to
all
NESHAP
require
records
of
applicability
determinations;
test
results;
exceedances;
periods
of
startups,
shutdowns,
or
malfunctions;
monitoring
records;
and
all
other
information
needed
to
determine
compliance
with
the
applicable
standard.
Records
and
reports
must
be
retained
for
a
total
of
5
years
(
2
years
at
the
site;
the
remaining
3
years
of
records
may
be
retained
off­
site).
The
files
may
be
maintained
on
microfilm,
on
a
computer
or
floppy
disks,
on
magnetic
tape
disks,
or
on
microfiche.

Subparts
AA
and
BB
require
respondents
to
install
monitoring
devices
to
measure
the
pressure
drop
and
liquid
flow
rate
for
wet
scrubbers.
These
operating
parameters
are
permitted
to
vary
within
ranges
determined
concurrently
with
performance
tests.
Respondents
must
2
perform
annual
performance
tests
to
verify
or
re­
establish
operating
ranges
for
purposes
of
determining
exceedances.

The
standards
require
sources
to
determine
and
record
the
amount
of
phosphatic
feed
material
processed
or
stored
on
a
daily
basis.
This
requirement
allows
verification
of
plant
operating
rate
which
is
one
of
the
factors
considered
in
establishing
the
operating
ranges
of
control
devices.
This
requirement
poses
no
additional
burden
upon
the
industry.
This
is
so
because
proper
plant
operation
and
industry
practice
include
daily
recording
of
phosphate­
bearing
feed
processed.
This
practice
predates
the
regulations
and
would
continue
in
their
absence.
Because
the
daily
recordation
requirement
places
no
additional
burden
upon
sources,
no
estimate
has
been
made
for
this
requirement.
Respondents
also
maintain
records
of
specific
information
needed
to
determine
that
the
standards
are
being
achieved
and
maintained.
These
requirements
are
described
in
Attachment
1.

2.
Need
For
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection.

The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
NESHAP
for
new
or
existing
major
sources
or
area
sources
that
reflect:

...
the
maximum
degree
of
reduction
in
emissions
of
[
HAPs]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
emission
reduction,
any
nonair
quality
health
and
environmental
reduction,
and
energy
requirements.
[
section
112(
d)(
2)]

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).
Certain
records
and
reports
are
necessary
for
the
Administrator
to:
(
1)
confirm
the
compliance
status
of
major
sources,
(
2)
identify
any
non­
major
sources
not
subject
to
the
standards,
and
(
3)
identify
new
or
reconstructed
sources
subject
to
the
standards.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.
7414)
and
set
out
in
the
NESHAP
General
Provisions.

2(
b)
Practical
Utility/
Users
of
the
Data.

The
information
is
used
by
Agency
enforcement
personnel
to:
(
1)
identify
major
sources
and
new,
modified,
or
reconstructed
sources
subject
to
the
standards;
(
2)
ensure
that
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.
Based
on
the
reported
information,
EPA
could
decide
which
plants,
records,
or
processes
should
be
inspected.
3
3
Nonduplication,
Consultation,
and
Other
Collection
Criteria
3(
a)
Nonduplication.

For
those
sources
currently
subject
to
NSPS
and
the
accompanying
reporting
requirements,
the
NESHAP
exempts
sources
from
the
NSPS
requirements
whenever
they
are
subject
to
the
NESHAP.
This
eliminates
duplication
resulting
from
Federal
regulations.
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
could
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.
The
EPA
has
issued
guidance
to
State
and
local
agencies
encouraging
them
to
consolidate
duplicative
requirements
into
a
single
element
to
be
reported.

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
Extensive
consultations
occurred
during
development
of
recordkeeping
and
reporting
requirements
at
the
proposal
stage
to
the
rule.
Participants
in
the
development
process
for
this
standard
included
the
States
of
Florida,
North
Carolina,
Mississippi,
Louisiana,
Idaho,
and
Wyoming,
STAPPA/
ALAPCO,
and
The
Fertilizers
Institute
with
its
member
companies.
Several
meetings
with
State
and
industry
representatives
also
were
held
in
the
period
leading
to
proposal.
No
major
problems
regarding
monitoring,
recordkeeping,
or
reporting
procedures
were
encountered.
No
comments
were
received
in
response
to
the
Federal
Register
Notice
of
January
21,
2000.

3(
d)
Effects
of
Less
Frequent
Collection
If
the
relevant
information
were
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
a
plant
is
in
compliance
with
the
standards.

3(
e)
General
Guidelines
None
of
the
general
information
collection
guidelines
in
5
CFR
1320.6
of
the
OMB
regulations
implementing
the
Paperwork
Reduction
Act
are
being
exceeded.
The
Agency
has
taken
all
practicable
steps
to
develop
simplified
requirements.
4
3(
f)
Confidentiality
All
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
39999,
September
28,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes.

Respondents
are
owners
or
operators
of
phosphoric
acid
manufacturing
and
phosphate
fertilizers
production
facilities
at
15
locations.
An
additional
six
sources
are
determined
to
be
area
sources
not
subject
to
the
standard.
Thus,
a
total
of
15
respondents
are
required
to
comply
with
the
monitoring,
recordkeeping,
and
reporting
requirements
in
the
rule.
The
SIC
code
for
the
respondents
affected
by
the
standard
is
2874.

4(
b)
Information
Requested.

(
i)
Data
items,
Including
Recordkeeping
Requirements.

Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
activities.

The
respondent
activities
required
by
the
standards
are
identified
in
Table
1and
introduced
in
Section
6(
a).

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
A
list
of
Agency
activities
is
provided
in
Table
2
and
introduced
in
Section
6(
c).
5
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
(
i.
e.,
pressure
drop
across
scrubbers)
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
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
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
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
Two
of
the
21
companies
comprising
this
industry
are
classified
as
small
businesses
under
the
Small
Business
Administration
definition
(
750
or
less
company
employees).
Information
available
to
the
EPA
indicates
that
these
two
sources
are
currently
subject
to
the
NSPS.
One
of
the
two
is
an
area
source
and
is
subject
to
the
NESHAP.
The
second
company
is
exempted
from
the
NSPS
and
sees
no
change
in
the
current
amount
of
recordkeeping
and
reporting
because
the
NESHAP
has
been
written
to
duplicate
the
NSPS
as
closely
as
possible.
For
the
one
affected
small
entity,
the
standards
require
use
of
existing
controls
for
the
wet
process
phosphoric
acid
plant
and
for
the
diammonium
phosphate
plants.
Those
plants
have
wet
scrubbers
which
use
recycled
process
water
as
the
scrubbing
liquid.

The
rule
allows
the
affected
plants
up
to
three
years
from
the
effective
date
of
the
rule
to
comply.
Under
Section
112(
i),
the
Administrator
or
the
applicable
regulatory
authority
also
may
grant
one
additional
year
if
the
owner
or
operator
demonstrates
that
more
time
is
needed
to
install
controls
for
a
source.
This
additional
time
eases
capital
availability
problems
for
plants
in
marginal
economic
condition
that
need
to
purchase
and
install
new
or
upgraded
emission
controls.

Unless
a
waiver
were
to
be
granted
under
40
CFR
63.7,
an
initial
performance
test
is
required
to
demonstrate
compliance
with
the
standards.
To
reduce
the
amount
of
monitoring
required
to
ensure
compliance
and
to
reduce
the
costs
of
required
emission
testing,
total
fluorides
6
serves
as
a
surrogate
measure
for
HAP
emissions
of
hydrogen
fluoride
(
HF)
from
the
two
process
lines.
The
provisions
in
the
standard
for
determining
compliance
are
the
same
as
those
already
used
by
the
source.

Enhanced
monitoring
requires
the
installation
of
devices
for
the
continuous
measurement
and
recording
of
the
pressure
drop
and
liquid
flow
rate
of
the
emission
control
scrubbers.
These
operating
parameters
are
monitored
in
lieu
of
continuous
emission
monitors
for
HF.
Low­
cost,
pressure
drop
transducers
and
liquid
flow
meters
are
available
for
this
purpose.
The
owner
or
operator
is
required
to
maintain
the
operating
parameters
within
a
range
determined
by
performance
testing.
An
exceedance
of
the
range
is
considered
a
violation
of
the
emissions
limit.
The
rules
provide
an
optional
monitoring
approach
which
include
a
grace
period
for
the
source
to
re­
test
to
demonstrate
that
the
emissions
limits
were
being
met.
If
the
source
were
to
pass
an
emissions
test,
no
violation
is
determined
as
a
result
of
the
exceedances
of
the
operational
range.

The
plant's
choice
of
a
monitoring
option
is
incorporated
into
a
monitoring
plan
containing
monitoring
parameters,
a
monitoring
schedule,
and
recordkeeping
requirements
and
is
submitted
to
the
Administrator
for
approval
and
incorporated
in
the
operating
permit.
A
continuous
emission
monitor
(
CEM)
is
not
required;
consequently,
the
performance
evaluation,
quality
assurance/
quality
control,
notification,
recordkeeping,
and
associated
reporting
and
recordkeeping
requirements
do
not
apply.
The
ICR
requirements
are
the
minimum
necessary
to
demonstrate
and
ensure
compliance.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Industry
Burden..

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
each
of
the
subparts
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory
(
40
CFR
Part
63
Subparts
AA
and
BB).
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.
7
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
4,143
(
total
from
Table
1)
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,
and
MACT
programs,
the
previously
approved
ICR,
and
any
comments
received.
The
startup
burdens
reported
in
Table
1
were
reported
in
the
initial
ICR
for
this
rule.
They
are
repeated
in
this
ICR
because
this
ICR
spans
the
final
compliance
date
of
the
rule
and
hence
the
time
period
when
these
burdens
are
likely
to
be
incurred.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
technical
labor
rate
of
$
54.94
per
hour.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rate
is
from
column
1:
Total
compensation.
The
wage
rate
has
been
loaded
by
adding
110%
overhead.

(
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
CEMs.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor.
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
564,200.
This
corresponds
to
an
annualized
cost
of
$
53,200,
shown
on
the
OMB
83­
I
form
in
block
14
letter
a:
Total
annualized
capital/
startup
costs.

The
total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
13,300.
This
is
the
total
of
column
G.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b:
Total
annual
costs
(
O&
M).

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
cost
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
66,500.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c:
Total
annualized
cost
requested.
8
6(
c)
Estimating
Agency
Burden
and
Cost
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
the
General
Provisions
for
the
MACT
standards,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
the
Compliance
Data
System,
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
that
is
part
of
EPA's
overall
compliance
and
enforcement
program,
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Table
2.
Labor
rates
and
associated
costs
are
based
on
estimated
hourly
rates
for
government
workers
at
a
GS­
10
step
one
level,
or
$
39.26
per
hour
including
110
percent
overhead.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
The
number
of
existing
sources
subject
to
40
CFR
Part
63
Subparts
AA
&
BB
is
15.
There
are
no
new
sources
subject
to
40
CFR
Part
63
Subparts
AA
&
BB.
The
total
annual
labor
costs
are
$
227,210
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
66,500.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
See
Tables
1
and
2,
on
pages
10
and
12)

6(
f)
Reasons
for
Change
in
Burden
This
burden
reflects
an
increase
in
353
hours
total
annual
burden
to
the
industry,
and
a
total
annual
cost
increase
of
$
105,843.
The
change
is
due
to:
(
1)
a
program
change
in
the
final
rule
requirement
for
annual
performance
testing,
causing
an
upward
adjustment
in
burden
hours;
and
(
2)
an
adjustment
in
the
manner
in
which
overhead
costs
and
burden
were
calculated.
The
initial
ICR
adjusted
for
overhead
by
computing
a
small
managerial
and
clerical
increment
to
the
primary
technical
labor
burden.
This
ICR
replaces
that
assumption
with
a
straight
overhead
cost
addition
of
110
percent
of
base
labor
rates,
resulting
in
an
increase
in
the
total
computed
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
9
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
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
1790.02
and
OMB
control
number
2060­
0361
in
any
correspondence.

PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
10
TABLE
1.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
STANDARD
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
H)
Cost,$
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
16m
6
96
5
b
480
26,371
4.
Reporting
Requirements
A.
Read
instructions
4
1
4
5b
20
1,099
B.
Required
activities
Initial
performance
test
28c
6
168
5b
840
46,150
Repeat
performance
test
28d
1
28
0.3
e
8
440
Startup,
shutdown,
malfunction
plan
40
1
40
5b
200
10,988
Annual
performance
test
28c
6
168
5n
840
46,150
Repeat
annual
performance
test
28d
1
28
0.3
e
8
440
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Notification
of
applicability
2
1
2
5b
10
549
Notification
of
constr./
reconstr.
N/
A
Notification
of
anticipated
startup
N/
A
Notification
of
actual
startup
N/
A
Notification
of
special
compliance
reqmts
N/
A
Notification
of
performance
test
2
1
2
5b
10
549
Notification
of
compliance
status
4
1
4
5b
20
1,099
NESHAP
waiver
application
0
0
0
0f
0
Report
of
performance
test
See
4B
Report
of
monitoring
exceedances
16
2
32
1.5g
48
2,637
Report
of
no
excess
emissions
8
2
16
28.5h
456
25,053
Startup,
shutdown,
malfunction
report
8
2
16
1i
1
55
5.
Recordkeeping
Requirements
A.
Read
instructions
4
1
4
5b
20
1,099
B.
Plan
activities
See
5E
TABLE
1,
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
STANDARD,
CONTINUED
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
H)
Cost,$
a
11
C.
Implement
activities
See
5E
D.
Develop
record
system
See
5E
E.
Time
to
enter
information
Records
of
all
info.
required
by
standards
1.5j
52k
78
15b
1170
64,280
F.
Time
to
train
personnel
N/
A
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
N/
A
H.
Time
to
transmit
or
disclose
information
0.25
3.3l
0.825
15b
12.38
680
I.
Time
for
audits
N/
A
TOTAL
BURDEN
AND
COST
(
SALARY)
4,143
$
227,616
a
Costs
are
based
on
the
technical
hourly
rate
of
$
54.94,
which
includes
an
overhead
adjustment
of
110%
of
the
hourly
labor
rate.

b
Six
of
the
21
existing
sources
are
currently
equipped
with
MACT­
level
controls
and
may
be
determined
to
be
area
sources
not
subject
to
the
standards.
No
new
or
reconstructed
plants
or
sources
are
expected.
Thus,
15
plants
are
expected
to
comply
during
the
3­
year
ICR
clearance
period,
for
an
average
of
5.0
plants
per
year
(
15/
3
=
5.0).
Although
15
plants
must
comply
by
the
end
of
the
second
year
of
this
3­
year
ICR
clearance
period,
the
burden
is
annualized
at
5
plants
per
year.

c
Assumes
each
source
has
six
process
lines
requiring
testing
and
would
use
Method
13
or
Method
5
to
measure
emissions.
Twenty
eight
hours
are
estimated
for
measurement/
analysis/
reporting
for
Method
13
or
Method
5
(
2520/
3
=
840
total).

d
Assumes
respondent
may
fail
the
emission
test
using
Method
13.

e
Assumes
7
percent
of
15
respondents
(
1
plant)
will
fail
the
initial
performance
test
and
must
repeat
it,
for
an
average
of
0.3
plant
per
year
(
1/
3
=
0.3).

f
Assumes
no
respondents
will
request
a
waiver
from
performance
test
requirements.

g
Assumes
5%
of
15
respondents
(
0.75)
report
exceedances
twice
a
year,
for
an
average
of
1.5
plants
per
year.

h
Assumes
95%
of
15
existing
respondents
(
14.25)
report
no
excess
emissions
semiannually,
for
an
average
of
28.5
plants
per
year.

i
Assumes
1
of
15
sources
will
have
a
startup,
shutdown,
or
malfunction
occur
in
a
year
that
is
not
managed
according
to
the
plan.

j
Assume
1.5
hours
per
source.

k
Assume
information
is
entered
1
time
per
week
for
52
weeks/
yr.

l
Assume
typical
source
transmits
one­
time
notifications
of
initial
performance
test,
applicability,
and
compliance
status
(
including
performance
test
report);
the
startup,
shutdown,
and
malfunction
plan;
and
6
semi­
annual
reports
of
excess
emissions
(
or
no
excess
emissions)
over
the
three­
year
period,
for
a
total
of
10
items
or
an
average
of
3.3
items
per
year.

m
Assume
16
hours
per
process
line
to
install
flow
measurement/
recording
systems.
These
have
a
twenty
year
life.
So,
the
total
is
for
15/
3
plants
per
year
x
6
lines
per
plant
x
16
hours
per
line
=
480
hours
per
year.

N/
A
=
Not
Applicable.
The
rule
does
not
include
any
application
or
survey/
study
requirement.
The
economic
analysis
does
not
predict
any
newly
constructed,
modified,
or
reconstructed
sources
over
the
next
three
years;
no
plants
have
made
early
reductions
or
other
agreements
which
would
entitle
them
to
special
compliance
requirements.
Hours
for
training
personnel
are
not
applicable
because
no
training
is
required
for
this
non­
complex
rule
and
hours
have
been
alloted
under
4A
and
5A
for
reading
and
understanding
the
recordkeeping/
reporting
requirements.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
is
not
applicable
because
no
previously
applicable
Federal
requirements
exist.
Time
for
audits
in
not
applicable
because
no
audit
is
required
by
the
rule.

n
In
the
third
year
of
the
ICR
clearance
period,
15
plants
must
conduct
annual
performance
testing.
Annualized
over
the
three
year
clearance
period,
this
averages
5
respondents
per
year.
12
TABLE
2.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
OF
THE
STANDARDS
Activity
(
A)

EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)

EPA
personhours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
(
E)
Technical
person­
hours
per
year
(
E=
CxD)
(
H)
Cost,$
a
Initial
performance
test
40
6
240
5b
1200
47,111
Repeat
performance
test
Retesting
preparation
Retesting
8
40
1
1
8
40
0.3c
0.3c
2.4
12
94
471
Litigation
2,080
1
2080
0.15d
312
12,249
Excess
Emissions
Enforcement
Activities
48
1
48
0.5e
24
942
Report
Review
Notification
of
applicability
Notification
of
constr./
reconstr.

Notification
of
anticipated
startup
Notification
of
actual
startup
Notification
of
special
compliance
req.

Notification
of
initial
performance
test
Notification
of
compliance
status
Performance
test
report
Repeat
performance
test
report
Excess
emissions
report
No
excess
emissions
report
NESHAP
waiver
application
Startup,
shutdown,
malfunction
report
2
N/
A
N/
A
N/
A
N/
A
2
2
40
40
20
20
N/
A
20
1
1
1
1
1
2
2
2
2
2
2
40
40
40
40
40
5b
5b
5b
5b
0.3c
1.5f
28.5g
1h
10
10
10
200
12
60
1140
40
393
393
393
7,852
471
2,356
44,756
1,570
TOTAL
BURDEN
AND
COST
(
SALARY)
3,032
119,036
Travel
Expenses
for
Tests
Attended
(
1
person
x
5
plants/
yr
x
2
days/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
5
round
trips/
yr)
=
$
2,500
TOTAL
ANNUAL
COST
TOTAL
ANNUAL
COST
=
$
119,036
+
$
2,500
=
$
121,536
a
Labor
costs
are
based
on
GS­
10
step
1
hourly
salary
of
$
18.69
plus
110%
overhead,
for
an
hourly
rate
of
$
39.26
b
Six
of
the
21
existing
sources
are
currently
equipped
with
MACT­
level
controls
and
may
be
determined
to
be
area
sources
not
subject
to
the
standards.
No
new
or
reconstructed
plants
or
sources
are
expected.
Thus,
15
sources
are
expected
to
comply
during
the
3­
year
ICR
clearance
period,
for
an
average
of
5.0
plants
per
year
(
15/
3
=
5.0).

c
Of
the
7
percent
that
fail
the
initial
performance
test
(
1),
all
repeat
the
performance
test,
for
an
average
of
0.3
sources
per
year.

d
One
plant
in
100
will
be
involved
in
litigation.

e
Assumes
5
percent
of
the
15
sources
(
0.75)
are
required
to
retest
as
a
result
of
excess
emissions,
for
an
average
of
0.75
sources
per
year.

f
Assume
5%
of
15sources
(
0.75)
report
exceedances
twice
a
year,
for
an
average
of
1.5
sources
per
year.

g
Assume
95%
of
15
sources
(
14.25)
will
file
no
excess
emissions
reports,
for
an
average
of
28.5
sources
per
year.

h
Assume
1
of
15
sources
will
have
a
startup,
shutdown,
or
malfunction
occur
in
a
year
that
is
not
managed
according
to
the
plan.

N/
A
=
Not
applicable.
The
economic
analysis
does
not
predict
any
newly
constructed,
modified,
or
reconstructed
sources
over
the
next
three
years;
no
plant
have
made
early
reductions
or
other
agreements
which
would
entitle
them
to
special
compliance
requirements.
No
plants
are
expected
to
apply
for
a
NESHAP
waiver.
13
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions
citation
Record
Retention
NOTIFICATIONS
Applicability
63.607
and
63.627
63.9(
b)(
1)­(
2)
5
years
Anticipated
startup
(
N/
A)
63.607
and
63.627
63.9(
b)(
3)
"

Actual
startup
(
N/
A)
63.607
and
63.627
63.9(
b)(
4)
"

Intention
to
construct/
reconstruct
(
N/
A)
63.607
and
63.627
63.9(
b)(
5)
"

Extension
of
compliance
(
N/
A)
63.607
and
63.627
63.9(
c)
"

Special
compliance
requirements
(
N/
A)
63.607
and
63.627
63.9(
d)
"

NESHAP
waiver
application
63.607
and
63.627
63.7(
h)
"

Date
of
initial
performance
test
63.607
and
63.627
63.7(
b)
&
63.9(
e)
"

Notification
of
compliance
status
63.607
and
63.627
63.9(
h)
"

REPORTS
Initial
performance
test
report
63.607(
a)(
1)
and
63.627(
a)(
1)
63.10(
d)
"

Excess
emissions/
summary
report
or
no
excess
emissions
reports
63.607(
a)(
2)
and
63.627(
a)(
2)
63.10(
e)
"

RECORDS
Record
retention
63.607(
b)
and
63.627(
b)
63.10(
b)
"

General
NESHAP
records
63.607(
b)
and
63.627(
b)
63.10(
b)
"

N/
A
=
Not
applicable.
