SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal),

EPA ICR Number 1078.09, OMB Number 2060-0111

1(b)  Short Characterization/Abstract

	The New Source Performance Standards (NSPS) for Phosphate Rock Plants
(40 CFR 60, subpart NN) were proposed on September 21, 1979, and
promulgated on April 16, 1982.  These regulations apply to the following
new facilities at phosphate rock plants with capacities greater than 4
tons per hour: dryers, calciners, grinders, and ground rock handling and
storage facilities, except those facilities producing or preparing
phosphate rock solely for consumption in elemental phosphorus
production.  New facilities include those that commenced construction,
modification or reconstruction after the date of proposal.  This
information is being collected to assure compliance with 40 CFR part 60,
subpart NN.

	In general, all NSPS standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They 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
sources subject to NSPS.

	Any owner or operator subject to the provisions of this part shall
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).

	Over the next three years, an average of 13 facilities per year will be
subject to the standard, and it is estimated that one additional source
will become subject to the standard in the next three years.

	There are approximately 13 phosphate rock plants in the United States,
which are all publicly owned and operated by the Phosphate Rock
industry.  None of the 13 plants in the United States are owned by
either state, local, tribal, or the Federal government.  They are all
owned and operated solely by privately owned for-profit businesses.  The
burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost, NSPS for Phosphate Rock Plants (40
CFR Part 60, Subpart NN) (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:
Annual Agency Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR
Part 60, Subpart NN) (Renewal).

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

	“As part of its submission, EPA should verify that the wage rates
referenced in Sections 6(b) and 6(c) of the supporting statement have
been updated to current values and properly loaded to include overhead,
consistent with current EPA and OMB guidelines.”

	The EPA has addressed these terms of clearance for this ICR by using
the most recent labor rates in Sections 6(b) and 6(c).

 

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 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, particulate matter (PM) emissions from
phosphate rock plants cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NSPS was promulgated for this source category at 40 CFR
part 60, subpart NN.

2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where 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 standard 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 check if the pollution control devices are
properly installed and operated, that leaks are being detected and
repaired, and that the standard is 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.  Non-duplication, Consultations, and Other Collection Criteria

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

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 (75 FR 30812) on June 2, 2010.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

	The Agency has consulted industry experts and internal data sources to
project the number of affected facilities and industry growth over the
next three years.  The primary source of information as reported by
industry, in compliance with the recordkeeping and reporting provisions
in the standard, is the Air Facility System (AFS) which is operated and
maintained by the EPA Office of Compliance.  AFS is the EPA database for
the collection, maintenance, and retrieval of all compliance data.  The
growth rate for the industry is based on our consultations with the
Agency’s internal industry experts.  Approximately 13 respondents will
be subject to the standard over the three year period covered by this
ICR.

	Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

	It is our policy to respond after a thorough review of comments
received since the last ICR renewal as well as those submitted in
response to the first Federal Register notice.  In this case, no
comments were received.

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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

	These reporting or recordkeeping requirements do not violate any of the
regulations  promulgated by OMB under 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

	The reporting or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

	The respondents to the recordkeeping and reporting requirements are
phosphate rock plants.  The United States Standard Industrial
Classification (SIC) code for the respondents affected by the standards
is SIC code 1475, which corresponds to the North American Industry
Classification System (NAICS) code 212393 for phosphate rock plants.

40 CFR Part 60, Subpart NN	SIC Codes	NAICS Codes

Phosphate Rock	1475	212393



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

	In this ICR, all the data that is recorded or reported is required by
the NSPS for Phosphate Rock Plants (40 CFR part 60, subpart NN). 

	A source must make the following reports:

Notifications

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

Notification of actual startup	60.7(a)(3)

Notification of physical or operational change which may increase the
emission rate	60.7(a)(4)

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

Notification of initial performance test	60.8(d)

Report on initial performance test	60.8(a)

Semiannual report on excess emissions	60.7(c)



	A source must keep the following records:

Recordkeeping

Maintain records of startups, shutdowns, malfunctions, periods where the
continuous monitoring system is inoperative	60.7(b)

Maintain all records for two years	60.7(f)



Electronic Reporting

	Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a 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 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate continuous monitoring system
(CMS) for opacity, or for pressure drop and liquid supply pressure for
wet scrubber.

Perform initial performance test, Reference Methods 5, and 9, and repeat
performance tests if necessary.

Write the notification 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 monitoring equipment that provides
parameter data in an automated way (e.g., continuous parameter
monitoring system).  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

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 could
inspect the source to determine whether the pollution control devices
are properly installed and operated.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard and note the operating conditions 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
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

	The 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 to be the minimum
requirements 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 below Table 1: Annual Respondent Burden and
Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN)
(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 1,602
labor hours.  The recordkeeping hours shown below in Table 1 are 1,338. 
The reporting requirement hours shown below in Table 1 are 264.  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	$116.05 ($55.26 + 110%)  

Technical	$97.21 ($46.29 + 110%)

Clerical	$48.87 ($23.27 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 2010, “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 is 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 monitor and
other costs such as photocopying and postage.

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

‌Startup Cost, (B × C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E × F)

Continuous Opacity Monitor	$37,000	0.33	$12,210	$8,400	13.33	$111,972



	The total capital/startup costs for this ICR are $12,210.  This is the
total of column D in the above table. 

	The total operation and maintenance (O&M) costs for this ICR are
$111,972.  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 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 $6,298.

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010
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: Annual Agency Burden and Cost, NSPS for
Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal).

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 13 existing respondents will be subject to the
standard.  It is estimated that an additional one respondents per year
will become subject.  The overall average number of respondents, as
shown in the table below, is 13 per year.

	The number of respondents is calculated using the following table that
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 a	(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	0.33	13	0	0	13.33

2	0.33	13	0	0	13.33

3	0.33	13	0	0	13.33

Average	0.33	13	0	0	13.33

Assumptions:

a  New respondents include sources with constructed, reconstructed and
modified affected facilities.  In this standard, existing respondents
submit initial notifications.

	Column D is subtracted to avoid double-counting respondents.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 13.33 or 13, when rounded.

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

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=(B×C)+D

Notification of construction or modification	0.33	1	N/A	0.33

Notification of actual startup 	0.33	1	N/A	0.33

Notification of physical or operational change which may increase the
emission rate	0.33	1	N/A	0.33

Notification of demonstration of CMS	0.33	1	N/A	0.33

Notification of initial performance tests	0.33	1	N/A	0.33

Report of initial performance test	0.33	1	N/A	0.33

Semiannual report on excess emissions	13.33	2	N/A	26.66

TOTAL (rounded)



29

N/A – Not Applicable

	The total Number of Respondents is 13.

	The number of Total Annual Responses is 29.  This is the number in
column E of the Respondent Universe and Number of Responses per year in
table above.

	The total annual labor costs are $150,354.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN)
(Renewal). 

6(e)  Bottom Line 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 (below),
respectively, and summarized below.  

(i)  Respondent Tally

	The total annual labor hours are 1,602 labor hours.  Details regarding
these estimates may be found below in Table 1: Annual Respondent Burden
and Cost, NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN)
(Renewal).  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 55
hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $124,182.  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 140 labor hours at a cost of $6,298.  See below Table 2:
Annual Agency Burden and Cost, NSPS for Phosphate Rock Plants (40 CFR
Part 60, Subpart NN) (Renewal).

6(f)  Reasons for Change in Burden

	There is no change in the labor hours, or in the capital/startup and
operation and maintenance costs 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 industry is very
low, negative, or non-existent.

	The increase in labor cost to Respondents and the Agency is due to
labor rate adjustments to reflect the most recent available estimates.  

6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 55 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-2010-0362.  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 Ave., NW, Washington, DC.  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, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2010-0362 and OMB Control Number 2060-0111 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 Phosphate Rock
Plants (40 CFR Part 60, Subpart NN) (Renewal)

Reporting/Recordkeeping Requirements	Person- hours 

per occurrence	No. of occurrences per respondent per year	Person- hours
per respondent per year 

(C = A×B)	Respondents 

per year a	Technical person- hours per year 

(E = C×D)	Management person-hours per year 

(E×0.05)	Clerical person-hours per year 

(E×0.1)	Total

Hours/‌Year

(H = E + F + G)	Cost b ($)

1. Applications	N/A

2. Survey and Studies	N/A

3. Reporting requirements	  

A.  Read instructions	1	1	1.00	0.3	0.33	0.02	0.03	0.38	$35.61

B.  Required activities	 

Initial emissions tests	32	1	32.00	0.3	10.56	0.53	1.06	12.14	$1,139.42

Report performance test c	32	1	32.00	0.1	2.24	0.11	0.22	2.58	$241.69

C.  Create Information	See 3B

D.  Gather existing information 	See 3B

E.  Write report  	 

Notification of construction/‌reconstruction	2	1	2.00	0.3	0.66	0.03
0.07	0.76	$71.21

Notification of actual startup	2	1	2.00	0.3	0.66	0.03	0.07	0.76	$71.21

Notification of physical or operational change which may increase the
emission rate d	2	1	2.00	0	0.00	0.00	0.00	0.00	$0.00

Notification of CMS demonstration e 	2	1	2.00	0.3	0.66	0.03	0.07	0.76
$71.21

Notification of initial performance test	2	1	2.00	0.3	0.66	0.03	0.07
0.76	$71.21

Report of initial performance test	2	1	2.00	0.3	0.66	0.03	0.07	0.76
$71.21

Semiannual report on excess emissions f	8	2	16.00	13.3	213.28	10.66
21.33	245.27	$23,012.81

Reporting Subtotal







264	$24,786 

4.  Recordkeeping requirements	 

A.  Read instructions	See 3E

B.  Plan activities	See 3E

C.  Implement activities	See 3E

D.  Develop record system 	See 3E

E.  Time to enter information	 

Record operating parameters g	0.3	350	87.50	13.3	1,163.75	58.19	116.38
1,338.31	$125,568.04

F.  Time to transmit or disclose information	N/A

G.  Train personnel	N/A

H.  Audits	N/A

Recordkeeping Subtotal	 	 	 	 	 	 	 	1,338	$125,568 

TOTAL ANNUAL BURDEN AND COST	 	 	 	 	 	 	 	1,602	$150,354 

N/A – Not Applicable.

Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 13.33.  It is estimated that one new source
will become subject to the rule over the three-year period of this ICR.

b  This ICR uses the following labor rates: $116.05 per hour for
Executive, Administrative, and Managerial labor; $97.21 per hour for
Technical labor, and $48.87 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December 2003, “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.

c  We have assumed that 20 percent of initial performance test will be
repeated due to failure.

d  We have assumed that no facility will be engaged in physical or
operational changes.

e  We have assumed that it will take each respondent 2 hours each to
write CMS notification report.

f  We have assumed that each respondent will take 8 hours, two times per
year, to write semiannual report on excess emissions.

g  We have assumed that each respondent will take 15 minutes per day to
record operating parameters information.

Table 2.  Annual Agency Burden and Cost, NSPS for Phosphate Rock Plants
(40 CFR Part 60, Subpart NN) (Renewal)

	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)

Activity	EPA person- hours per occurrence	No. of occurrences per plant
per year	EPA person- hours per plant per year 

(C = A×B)	Plants per year a	Technical person- hours per year 

(E = C×D)	Management person-hours per year 

(E×0.05)	Clerical person-hours per year 

(E×0.1)	Total

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.00	0.33	2.64	0.13	0.26	3.04	$136.82 

Semiannual report on excess emissions f	4	2	8.00	13.33	106.64	5.33	10.66
122.64	$5,526.56 

Report Review Subtotal	 	 	 	 	 	 	 	129	$5,800 

TOTAL ANNUAL BURDEN	 	 	 	 	 	 	 	140	$6,298 

Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 13.33.  It is estimated that one new source
will become subject to the rule over the three-year period of this ICR.

b  The cost is based on the following labor rate which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses.  Managerial rates of $62.27 (GS-13, Step 5, $38.92 x 1.6),
Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical
rate of $25.01 (GS-6, Step 3, $15.63 x 1.6).  These rates are from the
Office of Personnel Management (OPM), 2010 General Schedule, which
excludes locality rates of pay.

c  We have assumed that 20 percent of initial performance test will be
repeated due to failure.

d  We have assumed that no facility will be engaged in physical or
operational changes.

e  We have assumed that it will take each respondent 2 hours each to
review CMS notification report.

f  We have assumed that each respondent will take 8 hours two times per
year to review semiannual report on excess emissions.

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