Burden Calculation Table

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Overview

Summary
Table 1
Table 2
Capital and O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	52
Number of Respondents	13
Total Estimated Burden Hours	2,200
Total Estimated Costs	$463,000
Annualized Capital O&M	$199,000
Total Annual Responses	43
Form Number	Not Applicable

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Sheet 2: Table 1

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)
					123.94	157.61	62.52
Burden item	(A) Technical Hours per Occurrence	(B) Occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hours per year (E=CxD)	(F) Managerial person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost per Year ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	4	1	4	13	52	2.6	5.2	$7,179.77
B. Required activities
Initial performance test	28	1	28	0	0	0	0	$0
Repeat 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	13	364	18.2	36.4	$50,258.39
Repeat annual performance test d	28	0.2	5.6	0.91	5.10	0.25	0.5	$703.62
Mercury testing - Calciners e	10	1	10	6	60	3	6	$8,284.35
TF testing
a. Oxidation Reactors f	10	1	10	3	30	1.5	3	$4,142.18
b. Calciners e	10	1	10	6	60	3	6	$8,284.35
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
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 3B
Report monitoring exceedances g	16	4	64	1.3	83.2	4.16	8.32	$11,487.63
Report of no excess emissions h	8	2	16	11.7	187.2	9.36	18.72	$25,847.17
Startup/ shutdown/ malfunction report i	8	1	8	0	0	0	0	$0
Develop monitoring plan j	15	1	15	0	0	0	0	$0
Prepare gypsum stack management j	20	1	20	0	0	0	0	$0
Subtotal for Reporting					968			$116,187
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	See 4E
C. Implement activities	See 4E
D. Develop record system	See 4E
E. Time to enter information
Records of operating parameters k	1.5	52	78	13	1014	50.7	101.4	$140,005.52
Records of Hg testing e	3	1	3	6	18	0.9	1.8	$2,485.31
Records of TF testing e, f	3	1	3	9	27	1.35	2.7	$3,727.96
Records of BLDS alarm l	5	1	5	3	15	0.75	1.5	$2,071.09
F. Time to train personnel	See 3B
G. Time to comply with applicable requirements	See 3B
H. Time for audits	N/A
Subtotal for Recordkeeping					1,235			$148,290
TOTAL ANNUAL BURDEN and COST (rounded) m					2,200			$264,000		2,200
CAPITAL AND O&M COST (rounded) m								$199,000		52	hr/response
GRAND TOTAL (rounded) m								$463,000
Assumptions
a Based on data collected during the 2020 final rule and consultation with internal agency experts, we estimate that 12 phosphoric acid units and 11 phosphate fertilizers, for a total of 23 processing units, located at 13 facilities will be subject to the rule. No additional respondents will become subject the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $157.61 ($75.05+ 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We assume that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that 7 percent of respondents will fail the performance test and must repeat it.
e Based on the 2015 RTR and 2020 final rule, we estimate there are 6 phosphate rock calciners that are subject to Hg and TF testing.
f Based on the 2015 RTR and 2020 final rule, we estimate there are 3 oxidation reactors subject to TF testing.
g We have assumed that 10 percent of sources will report exceedances. Respondents are required to report quarterly.
h We have assumed that 90 percent of sources will report no excess emissions semiannually.
i No longer applies.
j This is a one-time activity from the 2015 final rule. We assume the burden was already incurred during the first year of the amendment.
k We have assumed that it will take 1.5 hours per respondent to enter information and that information is entered one-time per week for 52 weeks per year.
l Records of BLDS alarms must be kept, we assume each fabric filter will warrant 5 hours of documenting for this requirement.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

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)
					52.37	70.56	28.34
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hours per year (E=CxD)	(F) Managerial person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost per Year ($) b
Initial performance test	40	1	40	0	0	0	0	$0
Repeat initial performance test
Retesting preparation	8	1	8	0	0	0	0	$0
Retesting	40	1	40	0	0	0	0	$0
Excess emissions enforcement activities	N/A
Report review
Notification of applicability	2	1	2	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
Notification of compliance status	2	1	2	0	0	0	0	$0
Observe stack tests c	20	1	20	3	60	3	6	$3,523.92
Annual performance test	40	1	40	13	520	26	52	$30,540.64
Repeat annual performance test d	40	1	40	0.91	36.4	1.82	3.64	$2,137.84
Excess emissions report e	20	4	80	1.3	104	5.2	10.4	$6,108.13
No excess emissions report f	20	2	40	11.7	468	23.4	46.8	$27,486.58
Review monitoring plan g	10	1	10	0	0	0	0	$0
Review gypsum stack and cooling pond management plan g	8	1	8	0	0	0	0	$0
Waiver application	N/A
Startup, shutdown, malfunction report h	20	1	20	0	0	0	0	$0.00
TOTAL ANNUAL BURDEN AND COST (rounded) i					1,370			$69,800
Assumptions
a Based on data collected during the 2020 final rule and consultation with internal agency experts, we estimate that 12 phosphoric acid units and 11 phosphate fertilizers, for a total of 23 processing units, located at 13 facilities will be subject to the rule. No additional respondents will become subject the rule over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
c Assumes EPA will attend 20 percent of stack tests. Only considers facilities with new emission points.
d We have assumed that 7 percent of respondents will fail the initial performance test and must repeat it.
e We have assumed that 10 percent of respondent will report exceedances. Respondents are required to report quarterly.
f We have assumed that 90 percent of existing respondents report no excess emissions semiannually.
g This is a one-time activity. We assume the burden was already incurred during the first year of the amendment.
h No longer applies.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital and O&M

												2015 --> 2020 (CEPCI):	1.0708
Capital/Startup vs. Operation and Maintenance (O&M) Costs												2015 $	2020 $			2015 $	2020 $
(A)	(B)	(C)	(D)	(E)	(F)	(G)						(B)	(B)			(E)	(E)
Continuous Monitoring Device	Capital/Startup Cost for One Respondente	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondente	Number of Respondents with O&M	Total O&M, (E X F)						Capital/Startup Cost for One Respondent	Capital/Startup Cost for One Respondent			Annual O&M Costs for One Respondent	Annual O&M Costs for One Respondent
Temperature monitoring device	$2,891	0	$0	$949	13	$12,333						$2,700	$2,891			$886	$949
Mercury testinga	$0	0	$0	$8,566	6	$51,397						$0	$0			$8,000	$8,566
TF testinga,b	$0	0	$0	$5,996	9	$53,966						$0	$0			$5,600	$5,996
Performance evaluationc	$0	0	$0	$2,142	23	$49,255						$0	$0			$2,000	$2,142
BLDS alarmd	$26,983	0	$0	$10,601	3	$31,802						$25,200	$26,983			$9,900	$10,601
Totalf			$0			$199,000
a Based on the 2015 RTR, we estimate there are 6 phosphate rock calciners that are subject to Hg and TF testing.
b Based on the 2015 RTR, we estimate there are 3 oxidation reactors subject to TF testing.
c Facilities must follow performance evaluation criteria (calibrations) for control devices. There are 23 process units at the 13 facilities.
d Based on the 2015 RTR, we estimate there are 3 BLDS alarms. We assumed capital costs were incurred during the first year of the amendment.
e Costs have been adjusted from $2015 to $2020 using the annual Chemical Engineering Plant Cost Index (CEPCI).
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction	0	0	0	0
Notification of initial performance test	0	0	0	0
Notification of compliance status	0	0	0	0
Annual performance test report	13.9	1	0	13.9
Quarterly reports of excess emissions	1.3	4	0	5.2
Semiannual report of no excess emissions	11.7	2	N/A	23.4
			Total	43

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	13	0	0	13
2	0	13	0	0	13
3	0	13	0	0	13
Average	0	13	0	0	13
a New respondents include sources with constructed and reconstructed affected facilities.