	SF tc \l2 "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 (H2SO4) 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 (SO2) 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.

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, SO2 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 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
(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).

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)



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.



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 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.

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 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.



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



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. 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 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.

Table 1:  Annual Respondent Burden and Cost - NSPS for Sulfuric acid
Plants (40 CFR Part 60, Subpart H) (Renewal)

	Burden item	

(A)

Technical

Person-

hours per

occurrence	

(B)   

No.  of

occurrences

per respondent

per year	

(C)

Technical

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours per

year

(Ex0.05)	

(G)

Clerical

person-

hours 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



      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



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.



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

Occurrence	

(B)   

Number  of

Occurrences

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



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	

$38,415.70



 Subtotals Labor Burden and Cost	

	

	

	

	

824	

41.2	

82.4	

$38,415.70



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.

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