SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart
PP) (Renewal) 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart
PP) (Renewal)

EPA ICR Number 1066.06, OMB Control Number 2060-0032

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Ammonium Sulfate
Manufacturing Plants were proposed on February 4, 1980, and promulgated
on November 12, 1980.  These standards apply to each ammonium sulfate
dryer within an ammonium sulfate manufacturing plant in the caprolactam
by-product, synthetic, and coke oven by-products sectors of the ammonium
sulfate manufacturing industry for which construction, modification or
reconstruction commenced after the date of the proposal.

Owners or operators of the affected facilities described must make the
following 

one-time-only reports: notification of the date of construction or
reconstruction; notification of the anticipated and actual dates of
startup; notification of any physical or operational change to an
existing facility which may increase the regulated pollutant emission
rate; and the notification of the date of the initial performance test. 
Owners or operators are also required to maintain records of the
occurrence and duration of any startup, shutdown, or malfunction in the
operation of an affected facility.  These notifications, reports and
records are required, in general, of all sources subject to NSPS.

Recordkeeping requirements specific to the ammonium sulfate industry
provides information on the amount of ammonium sulfate processed and the
operation of the emission control device.  Owners or operators of
affected facilities are required to install, calibrate, maintain, and
operate a flow monitoring device which can be used to determine the
mass-flow of ammonium sulfate feed material to the process, and which
has an accuracy of plus or minus 5 percent across its operating range. 
However, if the plant uses weight scales of the same accuracy to
directly measure production rates of ammonium sulfate, the use of flow
monitoring devices is not required.  Owners or operators of all affected
facilities will install, calibrate, maintain, and operate a monitoring
device which continuously measures and permanently records the total
pressure drop across the emission control system.

Therefore, the recordkeeping requirements for ammonium sulfate plants
consist of the occurrence and duration of all startups and malfunctions
as described, the initial performance test results, amount of ammonium
sulfate feed material, and the pressure drop across the emission control
system.  Records of startups, shutdowns and malfunctions will be noted
as they occur.  Records of the performance test should include
information necessary to determine the conditions of the performance
test, and performance test measurements (including pressure drop across
the emission control system) and results.  The continuous monitoring
system (CMS) will record pressure drop across the scrubbers continuously
and automatically.

The reporting requirements for this industry include the initial
notifications listed and the initial performance test results.  All
reports are sent to the delegated state or local authority.  In the
event that there is no such delegated authority, the reports are sent
directly to the Environmental Protection Agency (EPA) regional office. 
Notifications are used to inform the Agency or delegated authority when
a source becomes subject to the standard.  The reviewing authority may
then inspect the source to ensure that the pollution control devices are
properly installed and operated, and the standard is being met. 
Performance test records are needed as these are the Agency records of a
source's initial capability to comply with the emission standard.

Owners or operators of the affected facilities described are required to
adhere to reporting requirements specific to this rule, e.g., provide
information on the operation of emissions control devices.  Semiannual
excess emissions and monitoring systems reports are required to be
submitted by the respondents.

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.  These records and reports are essential in determining
compliance and are required of all sources subject to NSPS.

Based on the pre-existing number of applicable sources, approximately
two sources are currently subject to the regulations.  Due to the static
nature of the industry, it is estimated that no additional sources will
become subject to the standard over the next three years.  This
information is based on discussions with EPA personnel knowledgeable
about the ammonium sulfate industry.  The industry is dominated by
facilities that have been operating prior to the proposed date of the
rule (February 4, 1980), and there has been a long-term static or
declining market for the product both domestically and globally.  The
average annual cost to industry over the next three years of this
Information Collection Request (ICR) is estimated to be $23,183.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost, NSPS for Ammonium Sulfate
Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal).  The burden
to the “Federal Government” is attributed entirely to work performed
by Federal employees or government contractors; this burden may be found
below in Table 2: Average Annual EPA Burden, NSPS for Ammonium Sulfate
Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal).

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 the Administrator's judgment, particulate emissions from the ammonium
sulfate manufacturing industry causes 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 PP.

2(b)  Practical Utility/Users of the Data

The control of emissions of particulate from ammonium sulfate facilities
requires the installation of properly designed equipment and the
operation and maintenance of that equipment.  Emissions of particulate
from ammonium sulfate facilities are the result of the operation of the
affected facilities.  The subject standards are achieved by the
reduction of particulate emissions using control technology and leak
detection and repair (LDAR) procedures.  The notifications required in
the applicable regulations 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
regulations are being met.

Performance test reports are needed as these are the Agency records of a
source’s initial capability to comply with the emission standards, and
serve as a record of the operating conditions under which compliance was
achieved.  The information generated by the monitoring, recordkeeping
and reporting requirement described in this ICR is used by the Agency to
ensure that facilities which are affected by NSPS continue to operate
the control equipment in compliance with the regulation.  Adequate
monitoring, recordkeeping and reporting are necessary to ensure
compliance with the applicable regulations, as required by the Clean Air
Act.  In addition, the information collected from recordkeeping and
reporting requirements is used for targeting inspections, and is of
sufficient quality to be used as evidence in court.

3.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, subpart PP.

3(a)  Non-duplication

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

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register on July 30, 2009 (74 FR 38004). 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

For this information collection, a previous ICR renewal was used to
obtain burden estimates since this ICR renewal was processed under the
“Expedited Approach (renew without change)” option.  Per this
guidance, all data and assumptions from the previous ICR renewal were
used as the basis for estimating the hourly and cost burdens associated
with this renewal.  

The ICR renewal for the year 2003 used several different resources to
obtain the most recent data available for ammonium sulfate manufacturing
plants.  The most recent ICR and preparer of the ICR were referenced. 
The most recent data available (October 30, 2003) on the Air Facility
System (AFS) database, which is maintained by the Office of Compliance,
was accessed.  The Office of Compliance Sector Notebook “Profile of
the Inorganic Chemical Industry”, information from the United States
Census Bureau internet website, as well as other web sites covering
ammonium sulfate manufacturing were reviewed.  The EPA Office of Air
Quality Planning and Standards, Information Transfer and Program
Integration Division was consulted.  In addition, multiple consultations
with industry were conducted: the American Agricultural Economics
Association (AAEA), Kay Snopek, (515) 233-3202; American Chemical
Society, Hank Whalen, (202) 872-8724; Costal Chemical, Ms. Barbara
Cabot, (307) 637-2700; Agrium, Mr. Robert Williams, (559) 627-5553;
Florida Department of Environmental Protection (FCEP), Ms. Cindy
Phillips, (850) 921-9534; and BP Chemicals, Incorporated, Mr. Kevin
Sprague, (419) 226-1200.

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 a useful
technique 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 Part 1320, Section 1320.5.

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 (CBI) (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
ammonium sulfate manufacturing facilities.  The United States Standard
Industrial Classification (SIC) code for the respondents affected by the
standards is 2873 which corresponds to the North American Industry
Classification System (NAICS) code 325311 for ammonium sulfate
manufacturing facilities.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by
NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR part 60, subpart
PP).

A source must make the following reports:

Notification Reports	Standard Citation by Section

Notification of construction or modification	60.7(a)(1)

Notification of initial startup	60.7(a)(3)

Notification of initial performance test	60.8(d)



Periodic Reports	Standard Citation by Section

Semiannual report	60.7(c)



A source must make the following reports:

Recordkeeping

Initial performance test results	60.8(a) 

Startup, shutdowns, and malfunctions	60.8(c)

Control device operating parameters (continuous)	60.423

Records should be retained for two years	60.7(f)



Electronic Reporting

Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., a pressure drop and volumetric
flow rate.  Although personnel at the source still need to evaluate the
data, this type of monitoring equipment has significantly reduced the
burden associated with monitoring and recordkeeping.  In addition, some
regulatory agencies are setting up electronic reporting systems to allow
sources to report electronically which is reducing the reporting burden.
 However, electronic reporting systems are still not widely used by the
regulatory agencies.  It is estimated that approximately 10 percent of
the respondents use electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate control devices for
particulate matter (PM).

Perform initial performance test, Reference Methods 9 and 5, 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.

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.



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 to note the operating conditions under which
compliance was achieved.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.

Information contained in the reports is entered into the AFS which is
operated and maintained by the EPA Office of Compliance.  AFS is the EPA
database for the collection, maintenance, and retrieval of compliance
and annual emission inventory data for more than 100,000 industrial and
government-owned facilities.  EPA uses 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 or
operator for two years.

5(c)  Small Entity Flexibility

Currently the number of employees at a typical ammonium sulfate plant
exceeds the criterion for small business.  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
to be 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 below in Table 1: Annual Respondent Burden and
Cost, NSPS for Ammonium Sulfate Manufacturing Plants (40 CFR Part 60,
Subpart PP) (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 burdens 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 247
(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	$114.77 ($54.65 + 110%)   

Technical	$97.59 ($46.47 + 110%)

Clerical	$48.26 ($22.98 + 110%)

These rates are from the U. S. Department of Labor, Bureau of Labor
Statistics, March 2009, “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 only costs to the regulated industry resulting from information
collection activities required by the subject standard are labor costs. 
There are no capital/startup or operation and maintenance costs.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

The only types of industry cost associated with the information
collection activity in the regulations are labor costs.  There are no
capital/startup or operation and maintenance 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)

N/A	N/A	N/A	N/A	N/A	N/A	N/A



The total capital/startup costs for this ICR are zero.  This is the
total of column D in the above table.

The devices used to record operating parameters must be installed and
maintained by the respondents in order to operate the processing plant
efficiently.  Therefore, the total operation and maintenance (O&M) costs
for this ICR are zero.  This is the total of column G.  

The total respondent costs 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 cost to industry over the next three years of the ICR is
estimated to be zero.  

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $3,010 (rounded).  

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

	Managerial	$61.36 (GS-13, Step 5, $38.35 + 60%) 

	Technical	$45.52 (GS-12, Step 1, $28.45 + 60%)

	Clerical	$24.64 (GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personnel Management (OPM), 2009
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2: Average Annual EPA Burden, NSPS for
Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP)
(Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately four existing sources
are currently subject to the standard.  It is estimated that no
additional sources will become subject to the regulation in the next
three years.

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	2	0	0	2

2	0	2	0	0	2

3	0	2	0	0	2

Average	0	2	0	0	2



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 two.  The total number of annual responses per year is
calculated using the following table:

Total Annual Responses

(A)

Number of New Respondents	(B)

Number of Reports for New Respondents	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Respondents	(F)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(E)

Total Annual Responses 

E=(AxB)+(CxD)+F

0	0	2	2	0	4



The number of Total Annual Responses is 4.  The total annual labor costs
are $23,183 (rounded).  Details regarding these estimates may be found
below in Table 1: Annual Respondent Burden and Cost, NSPS for Ammonium
Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal).

Note that the total annual capital and O&M costs to the regulated entity
are zero.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached in Tables 1 and 2, respectively.  The annual
public reporting and recordkeeping burden for this collection of
information are estimated to average 62 hours per response.

6(f)  Reasons for Change in Burden

There is an apparent increase of one hour in the total labor hours for
this ICR.  Total labor hours for this ICR is 247 rather than 246 in the
previous ICR, because the previous ICR did not round labor hours up to
the nearest whole number.  There is no change in the per-respondent
labor hours in this ICR compared to the previous ICR.  This is due to
two considerations.  First, the regulations have not changed over the
past three years and are not anticipated to change over the next three
years.  Secondly, the growth rate for the respondents is very low,
negative or non-existent.  Therefore, the labor hours in the previous
ICR reflect the current burden to the respondents and are reiterated
(with a correction for rounding) in this ICR.

	There is an increase in both respondent and Agency costs resulting from
labor rate increases from the year 2003 to the year 2009.  This ICR uses
the year 2009 labor rates because burden and cost calculations in Tables
1 and 2 of this ICR were expanded to include managerial and clerical
labor rates, and the previous ICR only provided a technical labor rate
for the year 2003.  This ICR is, therefore, updated to present the most
recent available labor rates for each of the three labor categories.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 62 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 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
EPA-HQ-OECA-2009-0527.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 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 docket center is (202) 566-1752.  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
EPA-HQ-OECA-2009-0527 and OMB Control Number 2060-0032 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 Ammonium Sulfate
Manufacturing Plants (40 CFR Part 60, Subpart PP)(Renewal)



Reporting / Recordkeeping	(A)

Hours per Occurrence	(B)

Occurrences/ Respondent/ Year	(C)

Hours/ Respondent/ Year

(C=AxB)	(D)

Respondents/ Year	(E)

Total Hours/ Year

(E=CxD)	(F)

Managerial Hours/ Year a	(G)

Technical Hours/ Year a	(H)

Clerical Hours/ Year a	(I)

Cost/ Year b

1. APPLICATIONS

Not Applicable







	2. SURVEY AND STUDIES

Not Applicable







	3. REPORTING REQUIREMENTS









	New Sources c









	A. Read Instructions	1	1	1	0	0	0	0.0	0.0	0

B. Required Activities









	New Sources c









	Initial performance test d









	Ref Method 9 tests f	29.7	4	118.8	0	0	0	0.0	0.0	0

Ref Method 5 f	4	1	4	0	0	0	0.0	0.0	0

Repeat performance test e	4	0.2	0.8	0	0	0	0.0	0.0	0

Existing sources









	Monitoring of operations and emissions

Included in 3F







	C. Create Information

Included in 3B







	D. Gather Existing Information

Included in 3E







	E. Write Report









	New Sources 









	Notification of construction/reconstruction	2	1	2	0	0	0	0.0	0.0	0

Notification of actual startup	2	1	2	0	0	0	0.0	0.0	0

Notification of initial performance test	2	1	2	0	0	0	0.0	0.0	0

Notification of demonstration of CMS	2	1	2	0	0	0	0.0	0.0	0

Report of initial performance test

Included in 3B 







	Existing Sources

 







	Notification of operational change 	2	1	2	0	0	0	0.0	0.0	0

Semiannual reports	16	2	32	2	64	3	55.7	5.6	6,019.03

Subtotal Reporting



	64



$6,019

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

Not Applicable







	E. Time to Enter Information 

 







	     Records of operating parameters f	0.25	365	91.25	2	182.5	8	158.7
15.9	17,163.65

F. Audits

Not Applicable







	Subtotal Recordkeeping



	183



$17,164











	TOTAL ANNUAL BURDEN (rounded)



	247



$23,183



Assumptions

a.  This ICR assumes that Managerial hours are 5 percent of Technical
hours, and Clerical hours are 10 percent of Technical hours.

b.  We assume a technical labor rate of $97.59, managerial rate $114.77,
and clerical rate of $48.26 from the United States Department of Labor,
Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by
occupational and industry group.”

Workers by Occupational and Industry Group.  The rates are from column
1: Total compensation.  The wage rate obtained from the table has been
increased by 110 percent to account for the benefit packages available
to those employed by private industry.

c.  We assume that there will be no new sources (respondents) over the
3-year period of this ICR.

d.  As specified in the general provisions each performance test shall
consist of three separate runs using the applicable test method. 
Sources are required to use Method 9 published in the 11th Edition of
the Official Methods of Analysis of the Association of Official
Analytical Chemists dated 1970.  As specified in the general provisions,
each performance test shall consist of three separate runs using the
applicable test method.  Each run shall be conducted for the time and
under the conditions specific in the applicable rule.  The particulate
matter concentration and volumetric flow rate of the effluent gas shall
be determined by Method 5 which requires a sampling time and a sample
volume for each run of at least 60 minutes and 1.50 dscm (53 dscf).

e.  We assume 20 percent of initial performance tests must be repeated
due to failure.

f.  Sources are required to maintain a daily record of operating
parameters.  We assume records will be recorded 365 days per year.



TABLE 2:  Average Annual EPA Burden - NSPS for Ammonium Sulfate
Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)



Burden Items	(A)

EPA Hours per Occurrence	(B)

Occurrences per Plant per Year	(C)

EPA Hours per Plant per Year

(C=AxB)	(D)

Plants per Year	(E)

Total EPA Hours per Year

(E=CxD)	(F)

Managerial Hours per Year a	(G)

Technical Hours per Year a	(H)

Clerical Hours per Year a











Required Activities









New Plant a









Initial performance tests b	24	1	24	0	0	0	0	0

Repeat performance tests c	24	0.2	4.8	0	0	0	0	0

Report Review 









New Plant









Notification of construction	2	1	2	0	0	0	0	0

Notification of initial startup 	0.5	1	0.5	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 demonstration of CMS 	0.5	1	0.5	0	0	0	0	0

Existing Plants









Semiannual reports	8	2	16	2	32	1.4	27.8	2.8











TOTAL



	32













	Salary d, e









(1 person x 1.4 hrs/year x $114.77/hrs ) + (1 person x 27.8 hrs/year x
$97.59/hrs) + (1 person x 2.8 hrs/year x $48.26/hrs) = $3,009.52













TOTAL ANNUAL BURDEN = $3,010 (rounded)







	

Assumptions:

a.  This ICR assumes that Managerial hours are 5 percent of Technical
hours, and Clerical hours are 10 percent of Technical hours.

b.  We assume that there will be no new sources (respondents) over the
3-year period of this ICR.

c.  We assume that EPA personnel attend all initial performance tests.

d.  There will be no travel expenses associated with this ICR since we
have assumed that no new sources will become subject to this rule over
the 3-year period of this ICR.

e.  The cost a technical labor rate of $97.59, managerial rate $114.77,
and clerical rate of $48.26 from the United States Department of Labor,
Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by
occupational and industry group.”

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