Table 1: Annual Respondent Burden and Cost – NSPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V,
W and X) (Renewal)
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103.97 |
129.93 |
51.79 |
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| Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
| Person Hours Per Occurrence |
Number of Occurrences Per Respondent Per Year |
Person Hours Per Respondent Per Year (C=AxB) |
Respondents Per Year a |
Technical Person-Hours Per Year (E=CxD) |
Management Person Hours Per Year
(E x 0.05) |
Clerical Person Hours Per Year
(E x 0.10) |
Total Costs Per Year ($)b |
| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting Requirements |
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| A. Read and understand rule requirements |
1 |
1 |
1 |
DWang:
Changed from 0 to 13.
13 |
13 |
0.65 |
1.3 |
$1,503.39 |
| B. Required activities |
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| New Sources |
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| Initial Performance Test |
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| AOCA Method 9 tests c |
29.7 |
1 |
29.7 |
0 |
0 |
0 |
0 |
$0.00 |
| Reference Method 13A or 13B tests d |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0.00 |
| Repeat performance test e |
4 |
0.2 |
0.8 |
0 |
0 |
0 |
0 |
$0.00 |
| C. Create Information |
See 3B |
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| D. Gather existing information |
See 3E |
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| E. Write Report |
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| New Sources |
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| Notification of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of initial performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of CMS demonstration |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Report of initial performance test |
See 3B |
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| Site-specific methodology plan f |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Existing Sources |
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| Notification of operational change g |
2 |
1 |
2 |
2 |
4 |
0.2 |
0.4 |
$462.58 |
| Semiannual report of exceedances h |
2 |
2 |
4 |
13 |
52 |
2.6 |
5.2 |
$6,013.57 |
| Subtotal Reporting Requirements |
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79 |
$7,980 |
| 4. Recordkeeping Requirements |
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| A. Read and understand rule requirements |
See 3A |
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| B. Plan activities |
See 3B |
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| C. Implement activities |
See 3B |
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| D. Develop record system |
N/A |
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| E. Time to enter information |
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| Records of operation parameters and emissions i |
0.25 |
350 |
87.5 |
13 |
1137.5 |
56.88 |
113.75 |
$131,546.76 |
| Subtotal Recordkeeping Requirements |
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1,308 |
$131,547 |
| TOTAL LABOR BURDEN AND COST (rounded)j |
1,390 |
$140,000 |
| Total Capital/O&M Costs (rounded)j |
$320,000 |
| Grand Total (Labor and Capital/O&M Costs)(rounded)j |
$460,000 |
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| Assumptions: |
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| a. We have assumed that the average number of respondents that will be subject to the rule will be 13. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR. |
| b. This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “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. |
| 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. |
|
DWang:
Does this mean that each source will submit only one semiannual report over the three year period? Because the calc table has all sources submitting 2 semiannual reports each year.
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. |
| j. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
Table 2: Average Annual EPA Burden and Cost –NSPS for Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V,
W and X) (Renewal) |
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46.67 |
62.9 |
25.25 |
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| Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
| EPA Hours per Occurrence |
Number of Occurrences Per Year |
EPA Person Hours Per Year
(A x B) |
Plants Per Year a |
Technical Hours Per Year
(C x D) |
Management Hours Per Year
(E x 0.05) |
Clerical Hours Per Year
(E x 0.10) |
Total Cost Per Year
($) b |
| Report Review |
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| New Plants |
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| Notification of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of initial startup |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of actual startup |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of initial test |
0.5 |
1.2 |
0.6 |
0 |
0 |
0 |
0 |
$0.00 |
| Review test results |
8 |
1.2 |
9.6 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of CMS demonstration |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
| Existing Plants |
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| Semiannual reportc |
1 |
2 |
2 |
13 |
26 |
1.3 |
2.6 |
$1,360.84 |
| TOTAL ANNUAL BURDEN AND COST (rounded)d |
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30 |
$1,360 |
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| Assumptions: |
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| a. We have assumed that the average number of respondents that will be subject to the rule will be 13. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR. |
| b. This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2014 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. |
| c. We have assumed that each plant will take one hour twice per year to review semiannual report. |
| d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |