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

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

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Sulfuric
acid
Plants
(
40
CFR
part
60,
subpart
H),
were
proposed
on
August
17,
1971
and
promulgated
on
December
23,
1971,
amended
on
June
14,
1974
(
39
FR
20794),
October
6,
1975
(
40
FR
46258),
May
25,
1983
(
48
FR
23611),
September
29,
1983
(
48
FR
4700),
October
20,
1983
(
48
FR
48669),
February
14,
1989
(
54
FR
6666)
and
October
17,
2000
(
65
FR
61753).
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.

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
affected
facilities.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
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
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

Based
on
our
consultations
with
industry
representatives,
there
is
an
average
of
one
affected
facility
at
each
plant
site
and
that
each
plant
site
has
only
one
respondent
(
i.
e.,
the
owner/
operator
of
the
plant
site).

Approximately
103
respondents
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
additional
respondents
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
2
The
Office
of
Management
and
Budget
(
OMB)
approved
the
current
Information
Collection
Request
(
ICR)
without
any
"
Terms
of
Clearance."

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

.
.
.
application
of
the
best
technological
system
of
continuous
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/
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,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
SO
2
emissions
from
sulfuric
acid
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
were
promulgated
for
this
source
category
at
40
CFR
part
60,
subpart
H.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standard
ensure
compliance
with
the
3
applicable
regulations
which
were
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.

Performance
tests
are
required
in
order
to
determine
an
affected
facility's
initial
capability
to
comply
with
the
emission
standard.
Continuous
emission
monitors
are
used
to
ensure
compliance
with
the
standard
at
all
times.
During
the
performance
test
a
record
of
the
operating
parameters
under
which
compliance
was
achieved
may
be
recorded
and
used
to
determine
compliance
in
place
of
a
continuous
emission
monitor.

The
notifications
required
in
the
standards
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
ensure
that
the
pollution
control
devices
are
properly
installed
and
operated,
that
leaks
are
being
detected
and
repaired,
and
that
the
standards
are
being
met.
The
performance
test
may
also
be
observed.

The
required
semiannual
reports
are
used
to
determine
periods
of
excess
emissions,
identify
problems
at
the
facility,
verify
operation/
maintenance
procedures
and
for
compliance
determinations.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
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
its
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
(
70
FR
24020)
on
May
6,
2005.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
consulted
with
the
preparer
of
the
active
ICR,
and
used
other
resources
to
obtain
the
most
recent
data
available.
We
reviewed
information
available
from
the
United
States
Census
Bureau,
the
Air
Facility
System
4
(
AFS),
and
websites
covering
sulfuric
acid
plants.
We
also
consulted
with
the
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer,
the
Program
Integration
Division.

After
reviewing
our
internal
data
sources
and
industry
experts,
we
have
determined
that
additional
consultations
with
industry
are
inappropriate
for
this
ICR
renewal.

The
standard
was
developed
with
the
participation
and/
or
consultation
with
industry
representatives.
In
addition,
the
Agency
has
performed
additional
reviews
to
determine
additional
burden
reduction
opportunities.
The
Agency
currently
collects
the
minimum
amount
of
information
necessary
to
ensure
compliance
with
the
standard.

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
1320.5.

These
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
records
retention
requirement
is
consistent
with
Part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
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).
5
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.
The
United
States
Standard
Industrial
Classification
(
SIC)
code
for
the
respondents
affected
by
the
standards
is
SIC
2819
which
corresponds
to
the
The
North
American
Industry
Classification
System
(
NAICS)
325188
for
inorganic
chemical
manufacturing.

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

(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
NSPS
for
Sulfuric
Acid
Plants
(
40
CFR
part
60,
subpart
H)
(
Renewal).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
of
construction/
reconstruction
60.7(
a)(
1)

Notification
of
actual
startup
60.7(
a)(
3)

Notification
of
physical
or
operational
change
60.7(
a)(
4)

Notification
of
continuous
monitoring
system
(
CMS)
demonstration
60.7(
a)(
5)

Initial
performance
test
results
60.8(
a)

Initial
performance
test
60.8(
d)

Reference
Test
Method
9
60.11(
b)

Reports
Semiannual
report
of
excess
emissions
60.7(
c)
6
A
source
must
keep
the
following
records:

Recordkeeping
Maintain
records
of
startup,
shutdown,
malfunction
period
where
the
continuous
monitoring
system
is
inoperative
60.7(
b)

Maintain
records
for
two
years
60.7(
f)

Subsequent
annual
performance
tests,
as
required
60.7(
f)

Electronic
Reporting
At
the
present,
respondents
are
using
monitoring
equipment
that
automatically
records
parameter
data.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

Also,
regulatory
agencies
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
electronic
reporting
systems
are
still
not
widely
used.
At
this
time,
it
is
estimated
that
approximately
20
percent
of
the
respondents
use
electronic
reporting.

(
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.
7
Respondent
Activities
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.

Transmit,
or
otherwise
disclose
the
information.

Currently,
sources
are
using
automated
monitoring
equipment
that
provides
parameter
data.
Although
personnel
at
the
sources
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

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
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
8
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner/
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
respondents
are
large
entities
(
i.
e.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Industry
Burden
for
NSPS
for
Sulfuric
Acid
Plants
(
40
CFR
Part
60,
Subpart
H)
(
Renewal).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
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
26,177
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.
9
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
97.46
($
46.41
+
110%)
Technical
$
83.71
($
39.86
+
110%)
Clerical
$
42.55
($
20.26
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standard
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startup
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startup
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

CMS
$
120,000
0
$
0
$
4,500
103
$
463,500
The
total
capital/
startup
costs
for
this
ICR
are
$
0.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
463,500.
This
is
the
total
of
column
G.
These
costs
are
shown
on
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
10
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
464,000
(
rounded).
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
38,416.

This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
Technical
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2005
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
NSPS
for
Sulfuric
Acid
Plants
(
40
CFR
Part
60,
Subpart
H)
(
Renewal),
attached.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
on
average
over
the
next
three
years,
approximately
103
existing
respondents
will
be
subject
to
the
standard.
It
is
estimated
that
no
additional
respondents
per
year
will
become
subject.
The
overall
average
number
of
respondents,
as
shown
in
the
table
below
is
103
per
year.

The
number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.
11
Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
103
0
0
103
2
0
103
0
0
103
3
0
103
0
0
103
Average
0
103
0
0
103
To
avoid
double­
counting
respondents
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
103.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

Total
Annual
Responses
(
A)
Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Application
of
construction
or
modification
0
1
N/
A
0
Notification
of
actual
startup
0
1
N/
A
0
Notification
of
physical
or
operational
change
0
1
N/
A
0
Notification
of
demonstration
of
CMS
0
1
N/
A
0
Notification
of
initial
performance
test
0
1
N/
A
0
Semiannual
report
of
excess
emissions
103
2
N/
A
206
Total
206
12
The
number
of
Total
Annual
Responses
is
206.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
2,113,271.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NSPS
for
Sulfuric
Acid
Plants
(
40
CFR
Part
60,
Subpart
H)
(
Renewal),
attached.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
2,113,271.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NSPS
for
Sulfuric
Acid
Plants
(
40
CFR
Part
60,
Subpart
H)
(
Renewal),
attached.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
127
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
464,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
948
labor
hours
at
a
cost
of
$
38,416.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NSPS
for
Sulfuric
Acid
Plants
(
40
CFR
Part
60,
Subpart
H)
(
Renewal),
attached.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
the
fact
that
we
are
presently
accountings
for
management
and
clerical
person
hours
per
year,
which
was
omitted
in
the
active
ICR,
and
a
revised
salary
table.
There
is,
however,
a
decline
in
the
number
of
sources.
13
The
renewal
ICR
shows
that
there
are
approximately
103
sources
associated
with
the
rule,
as
compared
to
the
active
ICR
that
shows
106
sources.
This
decline
in
the
number
of
sources
is
due
to
plant
closure.
No
new
facilities
are
expected
to
be
constructed
in
the
next
three
years.

Because
there
are
no
new
sources
with
reporting
requirements,
no
capital/
startup
costs
are
incurred.
The
only
cost
that
is
incurred
is
for
the
operation
and
maintenance
(
O&
M)
of
the
monitoring
equipment.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
127
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2005­
0025,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
N.
W.,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
14
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.
Please
include
the
EPA
Docket
ID
Number
OECA­
2005­
0025
and
OMB
Control
Number
2060­
0041
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1:
Annual
Respondent
Burden
and
Cost
­
NSPS
for
Sulfuric
acid
Plants
(
40
CFR
Part
60,
Subpart
H)
(
Renewal)

Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
requirements
A.
Read
Instructions
c
1
1
1
0
0
0
0
$
0
B.
Required
Activities
N/
A
Initial
performance
tests
d
300
1
300
0
0
0
0
$
0
Reference
Method
9
test
e
4
1
4
0
0
0
0
$
0
Repeat
of
performance
tests
f
300
1
300
0
0
0
0
$
0
C.
Create
information
Included
in
3B
D.
Gather
existing
information
Included
in
3B
E.
Write
report
Application
of
construction
or
modification
2
1
2
0
0
0
0
$
0
Notification
of
actual
startup
2
1
2
0
0
0
0
$
0
Notification
of
physical
or
operational
change
2
1
2
0
0
0
0
$
0
16
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
Notification
of
demonstration
of
continuous
monitoring
system
(
CMS)
2
1
2
0
0
0
0
$
0
Notification
of
initial
performance
test
2
1
2
0
0
0
0
$
0
Semiannual
report
of
excess
emissions
g
40
2
80
103
8,240
412
824
$
764,985.12
4.
Recordkeeping
Requirements
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
h
0.25
350
88
103
9,064
453.2
906.4
$
841,483.63
Record
of
conversion
factors/

calculation
i
0.05
1,050
53
103
5,459
272.95
545.9
$
506,802.64
F.
Time
to
train
personnel
N/
A
G.
Time
for
audits
N/
A
Subtotal
Labor
Burden
22,763
1,138.15
2,276.3
$
2,113,271.39
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
26,177
$
2,113,271
17
Assumptions:

a
We
have
assumed
that
there
are
103
existing
sources,
and
that
no
additional
new
sources
will
become
subject
to
the
rule
over
the
next
three
years.

b
This
ICR
uses
the
following
labor
rates:
$
97.46
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
83.71
per
hour
for
Technical
labor,
and
$
42.55
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

c
We
have
assumed
that
it
will
take
one
hour
to
read
instructions.

d
We
have
assumed
that
it
will
take
300
hours
to
complete
an
initial
performance
test.

e
We
have
assumed
that
it
will
take
four
hours
to
complete
a
reference
method
9
test.

f
We
have
assumed
that
it
will
take
300
hours
to
repeat
the
test
due
to
failure.

g
We
have
assumed
that
it
will
take
forty
hours
to
write
an
excess
emission
report
on
a
semiannual
basis.

h
We
have
assumed
that
each
respondents
will
enter
information
on
records
of
operating
parameters
350
time
per
year.

i
We
have
assumed
that
records
of
conversion
factors
will
be
recorded
three
times
daily
at
350
days
per
year
for
a
total
of
3x350=
1,050
times
per
year.
18
Table
2:
Average
Annual
EPA
Burden
­
NSPS
for
Sulfuric
acid
Plants
(
40
CFR
Part
60,
Subpart
H)
(
Renewal)

Burden
item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)
Plants
Per
Year
a
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
Cost,

Per
Yearb
New
Facility
Initial
performance
tests
c
50
1
50
0
0
0
0
$
0
Repeat
performance
test
/
observed
d
24
1
24
0
0
0
0
$
0
Review
reports
Notification
of
construction
2
1
2
0
0
0
0
$
0
Notification
of
actual
startup
0.5
1
0.5
0
0
0
0
$
0
Notification
of
initial
test
0.5
1.2
0.6
0
0
0
0
$
0
Review
test
results
8
1.2
9.6
0
0
0
0
$
0
Notification
of
CMS
demonstration
0.5
1
0.5
0
0
0
0
$
0
19
Burden
item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)
Plants
Per
Year
a
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
Cost,

Per
Yearb
Existing
Facility
0.5
1
0.5
0
0
0
0
$
0
Excess
emission
reports
e
4
2
8
103
824
41.2
82.4
$
38,415.7
0
Subtotals
Labor
Burden
and
Cost
824
41.2
82.4
$
38,415.7
0
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
948
$
38,416
Assumptions:

a
We
have
assumed
that
there
are
103
existing
sources,
and
that
no
additional
new
sources
will
become
subject
to
the
rule
over
the
next
three
years.

b
This
cost
is
based
on
the
following
hourly
labor
rates
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
$
56.02
for
Managerial
(
GS­
13,

Step
5,
$
35.01
x
1.6),
$
41.57
for
Technical
(
GS­
12,
Step
1,
$
25.98
x
1.6)
and
$
22.50
Clerical
(
GS­
6,
Step
3,
$
14.06
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2005
General
Schedule"
which
excludes
locality
rates
of
pay.

c
We
have
assumed
that
it
will
take
fifty
hours
to
perform
initial
performance
test.

d
We
have
assumed
that
it
will
take
twenty­
four
hours
to
repeat
performance
test.

e
We
have
assumed
that
it
will
take
four
hours
per
respondent
to
review
excess
emission
reports
on
a
semiannual
basis.
