Attachment 2

Burden Item

(A)

(B)

(C)

Number of
Occurrences
Per Year

EPA Hours
Per
Occurrence

Tech Hours
Per Year
(C=A x B)

(D)
(E)
(F)
Management
Clerical
Hours Per
Hours Per
Year
Year
EPA Cost
(D = C x 0.05) (E = C x 0.1) Per Year

not applicable
1. Applications
2. Read and Understand Rule Requirements
10
20
200
10
3. Required Activities
A. Observe stack tests
2
16
32
2
B. Excess emissions -- Enforcement Activities
1
24
24
1
not applicable
C. Create Information
not applicable
D. Gather Information
E. Report Reviews
1. Review performance test report
7
5
35
2
2. Review monitoring plan
23
10
230
12
3. Review gypsum stack and cooling pond management
12
8
96
5
planannual summary report
F. Prepare
1
10
10
1
4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
$881
TOTAL
627
31

Footnotes

Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric
Acid and Phosphate Fertilizers NESHAP - Year 1

20

$10,364

a

3
2

$1,658
$1,244

b
c

4
23
10
1
per trip
63

$1,814
$11,919
$4,975
$518
$1,763
$34,255

d

Footnotes:
a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 respondents).
b Assumes EPA personnel attend 20 percent of the stack tests; only considers facilities with new emission points.
c Assume 10 percent of the facilities will exceed emissions; only considers facilities with new emission points.
d Estimate based on only the hours to review new requirements.
e Estimate based on only the hours to add additional information.

e

Burden Item

(A)

(B)

(C)

Number of
Occurrences
Per Year

EPA Hours Per
Occurrence

Tech Hours
Per Year
(C=A x B)

1. Applications
2. Read and Understand Rule Requirements
0
20
3. Required Activities
A. Observe stack tests
2
16
B. Excess emissions -- Enforcement Activities
1
24
C. Create Information
D. Gather Information
E. Report Reviews
1. Review performance test report
7
5
2. Review monitoring plan
0
7
3. Review gypsum stack and cooling pond management
0
5
planannual summary report
F. Prepare
1
10
4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL

(D)
(E)
(F)
Management
Clerical
Hours Per
Hours Per
Year
Year
EPA Cost
(D = C x 0.05) (E = C x 0.1) Per Year

not applicable
0
0
32
2
24
1
not applicable
not applicable
35
0
0
10
101

2
0
0
1
$881
5

Footnotes

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric
Acid and Phosphate Fertilizers NESHAP - Year 2

0

$0

a

3
2

$1,658
$1,244

b
c

4
0
0
1
per trip
10

$1,814
$0
$0
$518
$1,763
$6,997

d

Footnotes:
a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 respondents).
b Assumes EPA personnel attend 20 percent of the stack tests; only considers facilities with new emission points.
c Assume 10 percent of the facilities will exceed emissions; only considers facilities with new emission points.
d Estimate based on only the hours to review new requirements.
e Estimate based on only the hours to add additional information.

e

Burden Item

(A)

(B)

(C)

Number of
Occurrences
Per Year

EPA Hours Per
Occurrence

Tech Hours
Per Year
(C=A x B)

1. Applications
2. Read and Understand Rule Requirements
0
20
3. Required Activities
A. Observe stack tests
3
16
B. Excess emissions -- Enforcement Activities
1
24
C. Create Information
D. Gather Information
E. Report Reviews
1. Review performance test report
8
5
2. Review monitoring plan
0
7
3. Review gypsum stack and cooling pond management
0
5
planannual summary report
F. Prepare
1
10
4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL

(D)
(E)
(F)
Management
Clerical
Hours Per
Hours Per
Year
Year
EPA Cost
(D = C x 0.05) (E = C x 0.1) Per Year

not applicable
0
0
48
2
24
1
not applicable
not applicable
40
0
0
10
122

2
0
0
1
$881
6

Footnotes

Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric
Acid and Phosphate Fertilizers NESHAP - Year 3

0

$0

a

5
2

$2,487
$1,244

b
c

4
0
0
1
per trip
12

$2,073
$0
$0
$518
$2,644
$8,966

d

Footnotes:
a Number of occurrences is the number of states where affected sources will exist and each EPA Region (6 states + 4 EPA regions = 10 respondents).
b Assumes EPA personnel attend 20 percent of the stack tests; only considers facilities with new emission points.
c Assume 10 percent of the facilities will exceed emissions; only considers facilities with new emission points.
d Estimate based on only the hours to review new requirements.
e Estimate based on only the hours to add additional information.

e

Table 8 - Summary of Annual Designated Administrator Burden and Cost of Recordkeeping and
Reporting Requirements for the Phosphoric Acid and Phosphate Fertilizers NESHAP
Year

Technical
Hours

Management Hours

Clerical Hours

Total Hours

Labor Costs

Non-Labor
Costs

Total Costs

1
2
3

627
101
122

31
5
6

63
10
12

721
116
140

$34,255
$6,997
$8,966

$0
$0
$0

$34,255
$6,997
$8,966

Total
Average

850
283

43
14

85
28

978
326

$50,218
$16,739

$0
$0

$50,218
$16,739