SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for the Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T,
U, V, W, and X) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for the Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T,
U, V, W, and X) (Renewal), ICR Number 1061.11, OMB Control Number
2060-0037

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations
published at 40 CFR part 60, subparts T, U, V, W, and X were proposed on
October 22, 1974, and promulgated on August 6, 1975.  These standards
apply to each wet-process phosphoric acid plant, each superphosphoric
acid plant, each granular diammonium phosphate plant, and each triple
superphosphate plant, having a design capacity of more than 15 tons of
equivalent phosphorous pentoxide (P2O5) feed per calendar day.  These
standards also apply to granular triple superphosphate storage
facilities.  These standards establish fluoride emission limitations as
a measure of phosphorus-bearing feed material at affected facilities.
The affected facilities may include a combination of reactors, filters,
evaporators, hot wells, acid sumps, cooling tanks, granulators, dryers,
coolers, screens, mills, mixers, curing belts (dens), cookers, and
facilities which store run-of-pile triple superphosphate, depending on
the type of plant.

In general, all NSPS standards require initial notifications,
performance tests, and periodic reports.  Owners or operators are also
required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction in the operation of an affected
facility, or any period during which the mobnitoring 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.

Approximately 13 sources are currently subject to the regulation, and it
is estimated that no new sources will become subject to the regulation
over the next three years.  In order to comply with the recordkeeping
and reporting requirements standard, the respondents will expend
approximately 1,194 hours and $320,190 per year.

These figures are based on queries conducted through the Online Tracking
Information System (OTIS); data from the Profile of the Agricultural
Chemical, Pesticide, and Fertilizer Industry Sector Notebook published
by the EPA Office of Compliance, and the Technical Support Document for
Phosphoric Acid Manufacturing and Phosphate Fertilizers Production;
queries conducted on the Missouri State Government/Business Entity
Database; consultations with the Florida State Government, Office of the
Environment and a number of fertilizer companies.

	During a previous renewal, the most recent data available on the Air
Facility System (AFS) database for the NSPS program associated with the
United States Standard Industrial Classification (SIC) codes for the
respondents affected by the standards was used.  The most recent data on
wages from the United States Department of Labor, Bureau of Labor
Statistics, March 2001, Table 10. Private industry, by occupational and
industry group, and the guidance provided by the EPA Office of
Environmental Information and the Office of Management and Budget was
also used to calculate the respondent burden.  The wage rate obtained
from the table was increased by 110 percent to account for the benefit
packages available to those employed by private industry.

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

When this ICR is resubmitted for renewal, EPA is reminded that they
should include in the supporting statement the name and contact
information for consultations with members of the public concerning the
collection.

EPA published an announcement of a public comment period for the renewal
of this ICR in the Federal Register on July 8, 2009.  No comments were
received on respondent burden associated with the reporting and
recordkeeping requirements provided in this ICR.  Additionally, EPA
contacted industry representatives to request a voluntary opinion on the
accuracy of the burden estimates associated with the collection and the
potential for minimizing the burden associated with the collection [see
Section 3(c)].

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost.  The burden to the “Federal Government”
is attributed entirely to work performed by federal employees or
government contractors.  This burden may be found in Table 2: Average
Annual EPA Burden.

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 where 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 emissions from the ammonium
sulfate manufacturing industry cause or contributed to air pollution
that may reasonably be anticipated to endanger public health or welfare.
 Therefore, NSPS were promulgated for this source category at 40 CFR
part 60, subparts T, U, V, W, and X.

2(b)  Practical Utility/Users of the Data

Source data and information requirements for phosphate fertilizer plants
are outlined in Section 4(b)(i).  These standards require the initial
reports in accordance with the general provisions of 40 CFR section
60.7.  These initial reports include notification of construction or
modification, reconstruction, and startup, shutdown, or malfunction.
The standards also require recordkeeping to document information
relating to the daily feed rate and storage of equivalent P2O5.
Semiannual compliance reporting is also required by the general
provisions.

Amounts of P2O5 are determined from Continuous Monitoring System (CMS)
records of phosphate-bearing feed material or accounts for triple
superphosphate stored.  The standards are defined in terms of grams of
fluorides emitted per metric ton of equivalent P2O5 processed.

The standards limits total fluoride emission to 100 grams per megagram
(Mg) of equivalent P2O5 feed as measured in Mg/hour.  Therefore, the
regulations require the hourly recording of data and the maintenance of
daily records for purposes of determining the feed rate used in the
standard. Such records must be retained at the facility for a minimum of
two (2) years.

The information generated by the monitoring, recordkeeping, and
reporting requirements described above is used by the Agency to ensure
that facilities affected by the NSPS continue to operate and control
equipment used to achieve compliance with the NSPS.  Notification of
construction and startup indicates to enforcement personnel when a new
affected facility has been constructed and, therefore, is subject to the
standards.  Under the standard, data collected by an affected facility
is retained at the source for a minimum of two years and made available
for inspection by the Administrator.

If the information required by the standards were not collected, the
Agency would have no means of ensuring that compliance with the NSPS is
achieved and maintained by new, modified, or reconstructed sources
subject to the regulations.  Under these circumstances, an owner or
operator could elect to reduce operating expenses by not installing,
maintaining, or otherwise operating the control technology required by
the standards.  In the absence of the information collection
requirements, compliance with the standards could be ensured only
through continuous on-site inspections by regulatory Agency personnel.
Consequently, not collecting the information would result in either
greatly increased expenditures of resources, or the inability to ensure
compliance with the standards.  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 is also used for
targeting inspections, and is of sufficient quality to be used as
evidence in court.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, subparts T, U, V W, and X.

3(a)  Nonduplication

If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted their 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 32580) on July 8, 2009.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

During a previous renewal of this ICR, several consultations were
conducted.  First, information available from the Office of Compliance
Sector Notebook  “Profile of the Agricultural Chemical, Pesticide, and
Fertilizer Industry” was reviewed.  Then, the most recent data
available on the Air Facility System (AFS) database of was accessed.
Additionally, information from the “Technical Support Document for
Phosphoric Acid Manufacturing and Phosphate Fertilizers Production,”
published by the Office of Air Quality Planning and Standards was
reviewed.  Information was also gathered from Florida State Government,
Office of the Environment, the Missouri State Government Business Entity
Database, and a number of fertilizer companies.

For this current renewal, EPA contacted representatives of industry
trade organizations to request a voluntary opinion as to the accuracy of
the burden estimates associated with this ICR and whether there is any
way to reduce the burden.  Consultation with the Florida Institute for
Phosphate Research was conducted, and a representative confirmed that
EPA’s estimation of 13 affected facilities is reasonable (Paul
Clifford, Ph.D.; phone:<PHONE_NUMBER>).  The Fertilizer Institute was
contacted, but did not provide comment (Bill Herz; phone:<PHONE_NUMBER>).

	3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards.
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

3(e)  General Guidelines

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

3(f)  Confidentiality

The required information has been determined not to be confidential.
However, 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
phosphate fertilizer facilities.  The United States Standard Industrial
Classification (SIC) code for the respondents affected by the standard
is 2874, and the North American Industry Classification System (NAICS)
code is 325312.

	4(b)  Information Requested

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by
NSPS for the Phosphate Fertilizer Industry (40 CFR part 60, subparts T,
U, V, W, and X).

A source must make the following reports:

Reports for 40 CFR part 60, subparts T, U, V, W, and X

Notification of construction/reconstruction.	60.7(a)(1)

Notification of initial startup including compliance method.	60.7(a)(3)

Initial performance test results.	60.8(a)

Initial performance test.	60.8(d)

Demonstration of continuous monitoring system.	60.7(a)(5)

Physical or operational change.	60.7(a)(4)

Semiannual or as indicated by the Administrator reports of exceedances
or monitoring systems performance.	60.7(c)

Site-specific methodology plan for demonstrating compliance with
standards for fluorides.	60.242(a), 60.243(d)

	A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subparts T, U, V, W, and X

Startups, shutdowns or malfunctions, periods where the continuous
monitoring system is inoperative.	60.7(b)

A file with records of all data measured during performance tests to
demonstrate compliance with the standard including the equipment
operating parameters and records of periods of operations during which
the parameters where established.  The file shall be retained for two
years following the date of such measurements, maintenance, reports, and
records.	60.7(f)

Daily record of equivalent P2O5 feed rate.	60.203(b), 60.213(b)
60.223(b), 60.233

Daily record of equivalent P2O5 feed rate and storage.	60.243(b)

Other records specified in an EPA approved site-specific plan.	60.243(d)

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate monitoring devices that
continuously measures the total pressure drop across the process
scrubbing system.

Install, calibrate, maintain, and operate a flow monitoring device which
can be used to determine the mass flow of phosphorus bearing feed
material to the process.

As part of the performance test, determine the phosphorus pentoxide
content in megagrams per hour (Rp) of the feed, using the Association of
Official Analytical Chemists (AOAC) Method 9 and Method 13A or 13b to
determine the total fluoride concentration of volumetric flow rate of
the effluent gas from each of the emission points.

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 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
parametric data in an automated way (e.g., 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.

5.  The Information Collected: Agency Activities, Collection
Methodology, and Information Management

5(a)  Agency Activities

EPA conducts no 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 quarterly reports of excess emissions reports or semiannual reports
of no excess emission, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AIRS (Aerometric Information
Retrieval System) Facility Subsystem (AFS) database.

5(b)  Collection Methodology and Management

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 EPA regional office.  Notifications are used to inform
the Agency or delegated authority when a source becomes subject to the
standard.  Data and records maintained by the respondents are tabulated
and published for use in compliance and enforcement programs.  The
semiannual reports of exceedances 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 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 compliance and annual emission inventory data for over 100,000
industrial and government-owned facilities.  EPA uses AFS for tracking
air pollution compliance and enforcement activity 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 fertilizer plant exceeds
the criterion for small business, and no new facilities are expected
within the next three years.  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.

The specific frequency for each information collection activity within
this request is shown in Table 2: Annual Industry Burden - NSPS for the
Phosphate Fertilizer Industry (40 CFR part 60, subparts T, U, V, W and
X).

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.

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 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.  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 1,194
hours (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 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.

	The previous ICR used only a technical labor rate from 2001.  The
updated labor categories and associated rates result in a change to
total labor cost.

		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	The type of industry costs associated with the information collection
activity in the regulations is labor and continuous emission monitoring
(CEM).  There are no capital/startup costs since we have assumed that no
new sources will become subject to this rule over the three-year period
of this ICR.  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 which are itemized in the
following table.

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

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

(A)

Continuous Monitoring Device	(B)

Startup Cost for One Source	(C)

Number of New Sources to Startup	(D)

Total Startup

(B X C)	(E)

Annual O&M Costs for One Source	(F)

Number of Existing Sources with O&M	(G)

Total O&M

(E X F)

Pressure drop monitor	$27,720	0	$ 0	$24,630	13	$320,190

As indicated above, there are no capital/startup costs for this ICR.
This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR is
$320,190.  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.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information.

The average annual Agency cost during the three years of the ICR is
estimated to be $1,154 (see Table 2).

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% to account for the benefit packages available to
government employees.

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

Respondent Universe and Number of Responses Per Year

Regulation Citation	(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

(AxB)+(CxD)+F

40 CFR Part 60, Subparts T, U, V, W, and X	0	6	13	2	0	26

The number of total respondents is 13.  This number is the sum of column
A and column C of the Respondent Universe and Number of Responses Per
Year table.  This represents the number of existing sources plus the
number of new sources averaged over the three-year period.

The number of Total Annual Responses is 26.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table.

The total annual labor costs are $117,512.  Details upon which this
estimate is based appear in Table 1: Annual Respondents Burden - NSPS
for the Phosphate Fertilizer Industry, (40 CFR part 60, subparts T, U,
V, W, and X).

The total annual capital and O&M costs to the regulated entity are
$320,190.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operating 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.

	6(f)  Reasons for Change in Burden

There is no change in the 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 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 in this ICR.  There is a minor change to
the cost figures, since the previous ICR used a technical labor rate
only.  The updated labor categories and associated rates result in an
increase to total labor cost.  Additionally, the previous ICR rounded to
the nearest $1,000.  This ICR presents cost figures which differ by less
than $500 from the previous ICR due to using exact figures instead of
rounding.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 46 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-2009-0417.  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<PHONE_NUMBER>, and the telephone number
for the docket center is<PHONE_NUMBER>.  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-2009–0417 and OMB Control Number 2060-0037 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 the PHOSPHATE
FERTILIZER INDUSTRY (40 CFR PART 60, SUBPARTS (T, U, V, W, AND X)

Burden Item	A

Hours per Occurrence	B

Number of occurrences per respondent per year	C

Hours per respondent per year

(AxB)	D

Respondents per yearb	E

Management hours per year	F

Technical hours per year	G

Clerical hours per year	H

Employee hours per year

(E+F+G)	I

Total cost per year ($)a

1.  RECORDKEEPING REQUIREMENTS 	N/A

2.  SURVEY AND STUDIES	N/A

3.  REPORTING REQUIREMENTS

A.  Read Instructions 	1	1	1	0	0.00	0.00	0.00	0.00	0.00

B.  Required activities

      New Sources

          Initial Performance Test

              AOCA Method 9 testsc	29.7	1	29.7	0	0.00	0.00	0.00	0.00
0.00

                 Reference Method 13A or
   13B testsd	4	1	4	0	0.00	0.00	0.00	0.00	0.00

Repeat performance teste	4	0.2	0.8	0	0.00	0.00	0.00	0.00	0.00

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	0.00	0.00	0.00	0.00	0.00

            Notification of actual
startup	2	1	2	0	0.00	0.00	0.00	0.00	0.00

            Notification of initial
performance test	2	1	2	0	0.00	0.00	0.00	0.00	0.00

            Notification of CMS
demonstration	2	1	2	0	0.00	0.00	0.00	0.00	0.00

     Report of initial performance                                test
Included in 3B

        Site-specific methodology                             planf	2	1
2	0	0.00	0.00	0.00	0.00	0.00

       Existing Sources

             Notification of operational
changeg	2	1	2	2	0.17	3.48	0.35	4.00	376.19

        Semiannual report of
exceedancesh	2	2	4	13	2.26	45.22	4.52	52.00	4,890.46

Reporting Subtotal	 	 	 	 	 	 	 	56

(rounded)	5,267

4.  RECORDKEEPING REQUIREMENTS	0.75	 	0

A.  Read Instructions	Included in 3A

B.  Plan activities	Included in 3B

C.  Implement activities	Included in 3B

D.  Develop record system	N/A

E.  Time to enter information

         Records of operationg parameters                 and emissionsi
0.25	350	87.5	13	49.46	989.13	98.91	1,137.50	106,978.91

Recordkeeping Subtotal	 	 	 	 	 	 	 	1,138

(rounded)	106,979

TOTAL ANNUAL BURDEN	 	 	 	 	 	 	 	1,194	117,512.22

Assumptions:

a. This ICR uses the following labor rates: Managerial $114.77 ($54.65 +
110%); Technical $97.59 ($46.47 + 110%); and 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.  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. 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 the spectrophotometric
molybdovanadophosphate method (AOAC) Method 9 published in the 11
Edition of the Official Methods of Analysis of the Association of
Official Analytical Chemists dated 1970, to determine the P2O5 feed
rate.

d. 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.
For these rules, the total fluoride concentration and volumetric flow
rate of the effluent gas shall

be determined by Method 13 which requires a sampling time and a sample
volume for each run of at least 60 minutes and 0.85 dscm (30 dscf).

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

f. Only sources that have a granular triple superphosphate storage
facility are required to submit this initial plan.

g. We assume that 15 percent of the source would be attributed to
operational changes.

h. We assume that each source will submit a semiannual report due to
excess emission and monitoring systems performance over the three-year
period.

i. Sources are required to maintain a daily record of operating
parameters (e.g., determine equivalent P2O5 content, and total pressure
drop across the scrubbing system).  We assume that the operation is 350
days per year as specified in the NSPS review document.

TABLE 2:  AVERAGE ANNUAL EPA BURDEN - NSPS for the PHOSPHATE FERTILIZER
INDUSTRY (40 CFR PART 60, SUBPARTS T, U, V, W, and X)

Burden Item	A

EPA Hours per Occurrence	B

Number of occurrences per plant per year	C

EPA hours per plant per year

(AxB)	D

Plants per yearb	E

EPA management hours per year	F

EPA technical hours per year	G

EPA clerical hours per year	H

Employee hours per year

(E+F+G)	I

Total cost per yeara ($)

1.  REPORT REVIEW

New Plants

	                 Notification of
construction/reconstruction	2	1	2	0	0.00	0.00	0.00	0.00	0.00

Notification of initial startup	0.5	1	0.5	0	0.00	0.00	0.00	0.00	0.00

Notification of actual startup	0.5	1	0.5	0	0.00	0.00	0.00	0.00	0.00

Notification of initial  test	0.5	1.2	0.6	0	0.00	0.00	0.00	0.00	0.00

Review test results	8	1.2	9.6	0	0.00	0.00	0.00	0.00	0.00

                  Notification of CMS
demonstration	0.5	1	0.5	0	0.00	0.00	0.00	0.00	0.00

Existing Plants

                  Semiannual report 	1	2	2	13	1.13	22.61	2.26	26.00
1,154.22

TOTAL ANNUAL BURDEN	 	 	 	 	 	 	 	26	1,154

Assumptions:

a. 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%); and Clerical $24.64 (GS-6, Step 3, $15.40
+ 60%).  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 information collection request (ICR).

 PAGE

 PAGE  2

 PAGE

 PAGE

 PAGE  16

 PAGE