SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers
Production (40 CFR Part 63, Subparts AA and BB) (Renewal)

	

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Phosphoric Acid Manufacturing and Phosphate Fertilizers
Production (40 CFR Part 63, Subparts AA and BB) (Renewal), EPA ICR
Number 1790.05, OMB Control Number 2060-0361

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Phosphoric Acid Manufacturing and Phosphate Fertilizers Production
were: proposed on December 27, 1996;  promulgated on June 10, 1999; and
amended on June 12, 2002.  These standards apply to owners, or operators
of existing phosphoric acid manufacturing and phosphate fertilizers
production facilities.  The rule applies to component processes at these
facilities and to any new, modified, or reconstructed sources. 
Component processes include wet process phosphoric acid plants,
superphosphoric acid plants, purified phosphoric acid plants, phosphate
rock dryers, phosphate rock calciners, diammonium and monoammonium
phosphate plants, and granular triple superphosphate (GTSP) plants. 
Since many of the facilities affected by the standards also are subject
to new source performance standards (NSPS), the standards include an
exemption from the NSPS for those sources.  The exemption eliminates a
duplication of information collection requirements.

Consistent with the General Provisions for National Emission Standards
for Hazardous Air Pollutants (NESHAP) for Source Categories (40 CFR part
63, subpart A), respondents are major sources.  Respondents are required
to submit one-time notifications (where applicable) and a one-time
report on performance test results and must notify the United States
Environmental Protection Agency (EPA) if annual performance tests
indicate a change in the baseline operating range of emission control
equipment.  Plants must develop and implement a startup, shutdown, and
malfunction plan, and submit semiannual reports of any event in which
the plan was not followed.  Quarterly reporting is required when excess
emissions occur.  General requirements applicable to all NESHAP require
records of applicability determinations, test results, exceedances,
periods of startups, shutdowns, or malfunctions; monitoring records, and
all other information needed to determine compliance with the applicable
standard.  Records and reports must be retained for a total of five
years (two years at the site; the remaining three years of records may
be retained off-site).

Respondents are required to install monitoring devices to measure the
pressure drop and liquid flow rate for wet scrubbers.  These operating
parameters are permitted to vary within ranges determined concurrently
with performance tests.  Respondents must perform annual performance
tests to verify, or reestablish operating ranges for purposes of
determining exceedances.

The standards require sources to determine and record the amount of
phosphatic feed material processed, or stored on a daily basis.  This
requirement allows verification of plant operating rates, which is one
of the factors considered in establishing the operating ranges of
control devices.  This requirement poses no additional burden upon the
industry.  This is so because proper plant operation and industry
practice include daily recording of phosphate-bearing feedstocks
processed.  This practice predates the regulations and would continue in
their absence.  Even considering this daily recording requirement, it
places no additional burden upon sources; thus, no estimate has been
made for this requirement.

Based on our consultations with industry representatives during a
previous renewal, 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 12 sources currently are subject to the regulation, and it
is estimated that no additional sources will become subject to the
regulation in the next three years.

The active (previous) Information Collection Request (ICR) had the
following Terms of Clearance (TOC): 

The cost of labor assumptions underlying the respondent and agency
burden cost calculations should be updated in the next renewal.

This ICR has been updated to include estimates of the respondent and
agency burden costs based on the most recent rates for managerial,
technical, and clerical labor.  Labor rates for the respondents are from
the United States Department of Labor, Bureau of Labor Statistics,
September 2009, ”Table 2. Civilian Workers, by Occupational and
Industry group.”  Labor rates for the agency are from the Office of
Personnel Management (OPM), 2010 General Schedule, which excludes
locality rates of pay. 

The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost - NESHAP for Phosphoric Acid
Manufacturing and Phosphate Fertilizers Production (40CFR part 63,
subparts AA and BB) (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 - NESHAP for Phosphoric Acid
Manufacturing and Phosphate Fertilizers Production (40CFR part 63,
subparts AA and BB) (Renewal).

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category, or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and will require the maximum degree of emission reduction. 
In addition, section 114(a) states that the Administrator may require
any owner, or operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports;     (C)
install, use, and maintain such monitoring equipment, 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, hazardous air pollutants (HAPs)
emissions from phosphoric acid manufacturing and phosphate fertilizers
plants cause or contribute to air pollution that may reasonably be
anticipated to endanger public health or welfare.  Therefore, the NESHAP
was promulgated for this source category at 40 CFR part 63, subparts AA
and BB.

2(b)  Practical Utility/Users of the Data

The control of emissions of HAP from phosphoric acid manufacturing and
phosphate fertilizers plants requires the installation of properly
designed equipment and the operation and maintenance of that equipment. 
Emissions of HAP from phosphoric acid manufacturing and phosphate
fertilizers plants are the result of operation of the affected
facilities.  The subject standards are achieved by the reduction of HAP
emissions using control technology and/or leak detection and repair
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 semiannual reports are used for problem identification,
as a check on source operation and maintenance, and for compliance
determinations.  The information generated by the monitoring,
recordkeeping and reporting requirements described in this ICR is used
by the Agency to ensure that facilities affected by the NESHAP 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.  The information collected from recordkeeping and
reporting requirements also 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 63, subparts AA and BB).

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 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 74 FR 38004 on July 30, 2009.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

Several consultations were conducted during a previous renewal of this
ICR.  First, the most recent ICR and the preparer of the active ICR were
referenced.  Then, the most recent data available on the Air Facility
System (AFS) database as maintained by the Office of Compliance were
accessed.  Information available from the Office of Compliance Sector
Notebook’s ”Profile of the Agricultural Chemical, Pesticide, and
Fertilizer Industry,” the United States Census Bureau via the
Internet, and other websites covering off-site waste and recovery
operations were also reviewed.  In additionally, the following people
were consulted: EPA’s Office of Air Quality Planning and Standards,
Information Transfer and Program Integration Division; The Fertilizer
Institute (TFI), Mr. William Herz, (202) 544-8123; the Florida
Department of Environmental Protection (FDAP), Ms. Cindy Phillips, (805)
921-9534; and the PCS Phosphate Company Incorporated, Mr. William
Schimming, (847) 849-4302.

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 violates any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

These standards require affected facilities 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 programs 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 (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 contains sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
phosphoric acid manufacturing and phosphate fertilizers production
facilities.  The United States Standard Industrial Classification (SIC)
code for the respondents affected by the standards is SIC 2874 which
corresponds to the North American Industry Classification System (NAICS)
325312 for phosphoric acid manufacturing and phosphate fertilizers
production facilities.

4(b)  Information Requested

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

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
the National Emission Standards for Hazardous Air Pollutants for
Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40
CFR part 63, subparts AA and BB).

A source must make the following reports:

Notifications	Standard Citation by Sections

Notification and application of construction/reconstruction	63.5(d) 

Notification of initial startup	63.09(b), 63.607, and 63.627

Notification of initial performance test	63.7(b), 63.9(e), 63.607, and
63.627

Extension of compliance	63.607, 63.627, and 63.9(c)

Special compliance requirements	63.607, 63.627, and 63.9(d)

Waiver of performance testing	63.607, 63.627, and 63.7(h)

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



Reports for 40 CFR part 63, subparts AA and BB

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

Semiannual report	63.10(e) and 63.607(c)(2)

Quarterly report	63.10(e) and 63.607(c)(2)

Annual report	63.10(e) and 63.607(c)(1)



A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart AA and BB

Performance test report	63.607(b)(1), 63.627(b)(1), and 63.10(b)

Excess emissions report.	63.607(b)(2), 63.627(b)(2), and 63.10(b)

Summary report	63.607(b)(3), 63.627(b)(3), and 63.10(b)

Reports and notifications	63.10(b)

Records retained for 5 years	63.10(b)(1)



Electronic Reporting

Presently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., leaks and spills of phosphoric
acid.  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, so as to reduce the reporting burden. 
However, electronic reporting systems are still not widely used by the
regulatory agencies.  It is estimated that approximately 20 percent of
the respondents use electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate devices for HAPs.

Perform initial performance test, Reference Methods 5 and 13 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 source 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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions 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 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 five years.

5(c)  Small Entity Flexibility

The exact number of small entities affected by this rule could not be
determined based on a review of available documents related to the rule,
including the full text of the Final Rule (60 FR 62930).  According to
both the Final Rule and the Wood Manufacturing Operations NESHAP
Implementation Document (EPA-456/R-97-005, updated March 2004),
additional mechanisms for exempting smaller sources from the standards
were put in place.  The Implementation Document states: “In order to
lessen the burden on … small sources … the EPA included material
usage and emission limits in the NESHAP.  Facilities below these limits
are designated by rule as area sources and are therefore not subject to
the NESHAP.” 

A majority of the affected facilities are large entities (e.g., 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 below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Phosphoric Acid Manufacturing and Phosphate
Fertilizers Production (40 CFR part 63, subparts AA and BB) (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
each of the subparts included in this ICR.  

The individual burdens are expressed under standardized headings
believed to be consistent with the concept of burden under the Paperwork
Reduction Act.  Wherever 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 1,534
(Total Annual Burden 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 NESHAP 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 United States 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 types of industry cost associated with the information collection
activity in the standards are labor and continuous emission monitoring
systems (CEMs).  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)

Temperature monitoring device	$2,700	0	0	$886	12	$10,632 

	

The total capital/startup costs for this ICR are zero.  The cost of the
temperature monitoring device would likely be written off the first
year, so no amortization of the cost is indicated.  This is the total of
column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are
$10,632.  This is the total of column G.

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 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 $47,129.  

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 - NESHAP for
Phosphoric Acid Manufacturing and Phosphate Fertilizers Production (40
CFR part 63, subparts AA and BB) (Renewal).

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

Based on our research for this ICR, approximately 12 existing sources
currently are subject to the standard.  It is estimated that no
additional sources per year will become subject to the regulation in the
next three years.

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	12	0	0	12

2	0	12	0	0	12

3	0	12	0	0	12

Average	0	12	0	0	12



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 12.

The number of responses per year is calculated using the following
table:

Total Annual Responses

(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Sources	(F)

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

Total Annual Responses 

E=(AxB)+(CxD)+F

0	0	12	7	0	84



The number of Total Annual Responses is 84.

The total annual labor costs are $144,297.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Phosphoric Acid Manufacturing and Phosphate
Fertilizers Production (40 CFR part 63, subparts AA and BB) (Renewal).

Note that the total annual capital and O&M cost to the regulated entity
is $10,632.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

The average annual Agency burden and cost over next three years is
estimated to be 1,062 labor hours at a cost of $47,129.  See below Table
2 Average Annual EPA Burden and Cost - NESHAP for Phosphoric Acid
Manufacturing and Phosphate Fertilizers Production (40 CFR part 63,
subparts AA and BB) (Renewal).

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information are estimated to average 18
hours per response.

6(f)  Reasons for Change in Burden

There is no change in the calculation methodology for labor hours in
this ICR compared to the previous ICR.  This is due to two
considerations: 1) the regulations have not changed over the past three
years and are not anticipated to change over the next three years; and
2) the growth rate for the respondents is very low, negative or
non-existent.  However, due to a mathematical correction, there is a
decrease of eight hours in respondent labor hours. 

This ICR has been updated with the most recent available labor rates for
each of the three labor categories.  There is an increase in both
respondent and Agency costs resulting from labor rate increases from
2003 to 2009.  This ICR uses 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.  The cost figure has also been updated to the
nearest dollar, whereas the previous ICR rounded the figure to the
nearest thousand dollar. 

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 18 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-2009-0535.  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-2009-0535 and
OMB Control Number 2060-0361 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 - NESHAP for Phosphoric Acid
Manufacturing and Phosphate Fertilizers Production (40 CFR part 63,
subparts AA and BB) (Renewal)

 

Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)

	Hours per Occurrence	Occurrences/ respondent/ per year	Hours/
Respondent/ year

(C = AxB)	Respondents per year	Managerial Hours/Yeara	Technical
Hours/Yeara	Clerical Hours/Yeara	Cost/year

($)

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Acquisition, Installation, and Utilization of Technology and
Systems









	N/A







	4.  Reporting Requirements









     A.  Read instructions	4	1	4	0	0	0	0	$0

     B.  Required activities









         Initial performance test	28	1	28	0	0	0	0	$0

         Repeat of initial performance test	28	0.1	2.8	0	0	0	0	$0

         Startup, shutdown, malfunction plan	40	1	40	0	0	0	0	$0

         Annual performance test 	28	1	28	12 b	14.6	292.2	29.2	$31,600

         Repeat annual performance test	28	0.2	5.6	0.84 c	0.2	4.1	0.4
$442

    C.  Create information	See 4B







	    D.  Gather existing information	See 4B







	    E.  Write report j









        Notification of applicability	N/A







	        Notification of construction./reconstruction	2	1	2	0	0	0	0	$0

        Notification of actual startup	N/A







	        Notification of compliance requirements	N/A







	        Notification of performance test	2	1	2	0	0	0	0	$0

        Notification of compliance status	4	1	4	0	0	0	0	$0

        Report of performance test	See 4B







	        Report of monitoring exceedances	16	4	64	1.2 d	3.3	66.8	6.7
$7,223

        Report of no excess emissions	8	2	16	10.8 e	7.5	150.3	15.0
$16,251

        Startup/ shutdown/ malfunction report	8	1	8	1f	0.3	7.0	0.7	$752

Subtotal for Reporting



	598	$56,269

5.  Recordkeeping Requirements









    A.  Read instructions	4	1	4	0	0	0	0	$0

    B.  Plan activities	See 5E







	    C.  Implement activities	See 5E







	    D.  Develop record system	See 5E







	    E.  Time to enter information









        Records of operating parameters	1.5 g	52 h	78	12 b	40.7	813.9
81.4	$88,028

    F.  Time to train personnel i	N/A







	    G. Time to comply with applicable                      requirements
See 4B







	    H.  Time for audits	N/A







	Subtotal for Recordkeeping



	936	$88,028

TOTAL ANNUAL BURDEN (rounded)





1,534

$144,297

Assumptions:

a  This ICR assumes that managerial hours are 5 percent of technical
hours, and clerical hours are 10 percent of technical hours.  This ICR
uses a labor rate of $114.77 for managerial hours, $97.59 for technical
hours, and $48.26 for clerical hours.

b  We have assumed that the average of respondents that will be subject
to the rule will be twelve.  There will be no additional new sources per
year that will become subject to the rule over the three-year period of
this ICR.

c  We have assumed that 7 percent of respondents will fail the initial
performance test and must repeat it.

d  We have assumed that 10 percent of respondents will report
exceedances.  Respondents are required to report quarterly.

e  We have assumed that 90 percent of existing respondents report no
excess emissions semiannually. 

f  We have assumed that 1 of 12 sources will have to submit a startup,
shutdown, or malfunction report.

g  We have assumed that it will take 1.5 hours per respondent to enter
information. 

h  We have assumed that information is entered one-time per week for 52
weeks per year. 

i  There are no hours for training personnel since no training is
required by the rule and hours have been allotted under 5A for reading
and understanding the recordkeeping/reporting requirements.

TABLE 2:  AVERAGE Annual EPA Burden - NESHAP for Phosphoric Acid
Manufacturing Plants and Phosphate Fertilizers Production (40 CFR part
63, subparts AA and BB) (Renewal)

 

Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)

	EPA hrs/ Occurrence	Occurrences /plant / year	EPA person/ hour per
plant per year

(C=AxB)	Plants per year	Managerial person /hours per year	Technical
person /hours per year	Clerical person /hours per year	EPA Cost /year a

Initial performance test	40	1	40	0	0.0	0.0	0.0	$0

Repeat initial performance test	 	 	 	 	 	 	 	 

   Retesting preparation	8	1	8	0	0.0	0.0	0.0	$0

   Retesting	40	1	40	0	0.0	0.0	0.0	$0

Excess Emissions Enforcement Activities	N/A	 	 	 	 	 	 	 

Report Review	 	 	 	 	 	 	 	 

   Notification of applicability	2	1	2	0	0.0	0.0	0.0	$0

   Notification of construction./reconstruction	N/A	 	 	 	 	 	 	 

   Notification of anticipated startup	N/A	 	 	 	 	 	 	 

   Notification of actual startup	N/A	 	 	 	 	 	 	 

   Notification of special compliance requirements	N/A	 	 	 	 	 	 
 

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

   Notification of compliance status	2	1	2	0	0.0	0.0	0.0	$0

   Annual performance test	40	1	40	12	20.9	417.4	41.7	$21,309

   Repeat annual performance test	40	1	40	0.84	1.5	29.2	2.9	$1,492

   Excess emissions report	20	4	80	1.2	4.2	83.5	8.3	$4,262

   No excess emissions report	20	2	40	10.8	18.8	375.7	37.6	$19,178

   Waiver application	N/A	 	 	 	0.0	0.0	0.0	$0

   Startup, shutdown, malfunction report	20	1	20	1	0.9	17.4	1.7	$888

TOTAL ANNUAL EPA BURDEN



	1,062	$47,129



Assumptions:

a  The cost is based on rates from the Office of Personnel Management
(OPM) ”2010 General Schedule“ which excludes locality rates of pay.

b  We have assumed that the average of respondents that will be subject
to the rule will be 12.  There will be no additional new sources per
year that will become subject to the rule over the three-year period of
this ICR. 

c  We have assumed that 7 percent of respondents will fail the initial
performance test and must repeat it.

d  We have assumed that 10 percent of respondent will report
exceedances.  Respondents are required to report quarterly.

e  We have assumed that 90 percent of existing respondents report no
excess emissions semiannually. 

f  We have assumed that 1 of 12 sources will have to submit startup,
shutdown, or malfunction report.

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