Attachment 1

Burden Item
1. Applications
2. Surveys and Studies
3. Reporting Requirements
A. Read Rule
B. Required Activities
1. Mercury testing
2. Hydrogen fluoride testing
a. Incremental 320 Cost
b. Oxidation Reactors,
Defluorination Units, & Clarifiers
3. TF testing: Oxidation, Defluorination,
& Clarifiers
4. Performance evaluation
C. Create Information
D. Gather Information
E. Report Preparation
1. Performance test report
2. Develop monitoring plan
3. Prepare gypsum stack management
plan
Reporting Subtotal
4. Recordkeeping Requirements
A. Read Instructions
B. Implements Activities
C. Develop Record System
D. Record information
1. Records of Hg testing
2. Records of HF/TF testing
3. Records of Hg control device
E. Personnel Training
F. Time for Audits
Recordkeeping Subtotal
TOTAL

(A)
Respondent
Hours per
Occurrence
(Technical
hours)
NA
NA

(I)
Total Labor
Costs Per
Year

(J)
Total NonLabor Costs
Per Year
(B x C x E)

(K)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid and Phosphate
Fertilizers NESHAP - Year 1
(B)
Non-Labor
Costs Per
Occurrence

(C)
Number of
Occurrences
Per
Respondent
Per Year

(D)
Technical
Hours per
Respondent
Per Year
(A X D)

20

$0

1

23

$43,471

$0

0

a

10

$6,400

0

0

$0

$0

0

0

0

0

$0

$0

0

b
c
c

0

0

0

0

0

$0

$0

0

c

10
0

8
23

80
0

8
0

4
0

$7,560
$0

$44,800
$46,000

0
0

i
d

1
1

10
15

7
23

70
345

7
35

4
17

$6,615
$32,603

$0
$0

7
23

e
f

$0

1

20

12

240
1195

24
120

12
60

$22,681
$112,930

$0
$90,800

12
42

g

$0
$0
$0

1
1
1

3
3
10

0
8
0

0
24
0

0
2
0

0
1
0

$0
$2,268
$0

$0
$0
$0

0
0
0

24
1219

2
122
Total Hours
1,402

1
61
Labor
$115,198

$2,268
$115,198
Non-Labor
$90,800
$43,471
$134,271

$0
$90,800
Total
$205,998

0
42

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
Hours per
Year
(F X .05)

20

23

460

46

1

10

0

0

$8,000

1

0

0

10

$15,000

1

10

10
0
Inc. in 3B
Inc. in 3E

$5,600
$2,000

1
1

10
15

$0
$0

20

Inc. in 3A
NA
NA
3
3
10
Inc. in 3B
NA

Summary of Respondent Burden
Initial Capital and Startup
Annualized Capital/Start-up and O & M

Footnotes:
(a) Facilities must read Subparts AA and BB, first year only. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.
(b) Facilities are not subject to annual Hg testing the first or second years, costs are provided in year 3.
(c) Facilities are not subject to annual HF testing the first year, costs are provided in years 2 and 3.
(d) Facilities must follow performance evaluation criteria (calibrations) for control devices. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.
(e) Includes additional data submitted for Hg and HF tests, for emission points not currently tested. The facilities' emission points that currently conduct TF tests are not considered, as they must already report their
data. No additional Hg and HF tests would be performed in year 1.
(f) Includes development of CPMS performance evaluations/calibration for scrubbers. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.
(g) Includes preparation of gypsum stack and cooling pond management plan for the 12 phosphoric acid facilities. Assumed that each facility would already be employing one of the control measures, so additional
costs to implement a control measure were not estimated.
(h) One facility will install a carbon adsorption system and must determine the carbon bed life; costs not applicable until year 3.
(i) There are 8 emission points (oxidation reactors, defluorination units, and clarifiers) that are currently not tested, but are applicable as noted in the subpart AA clarifications. These emissions points will conduct
total fluoride tests in year 1, before transitioning to HF testing in years 2 and 3.

h

Burden Item
1. Applications
2. Surveys and Studies
3. Reporting Requirements
A. Read Rule
B. Required Activities
1. Mercury testing
2. Hydrogen fluoride testing
a. Incremental 320 Cost
b. Oxidation Reactors,
Defluorination Units, & Clarifiers
3. TF testing: Oxidation, Defluorination,
& Clarifiers
4. Performance evaluation
C. Create Information
D. Gather Information
E. Report Preparation
1. Performance test report
2. Develop monitoring plan
3. Prepare gypsum stack management
plan
Reporting Subtotal
4. Recordkeeping Requirements
A. Read Instructions
B. Implements Activities
C. Develop Record System
D. Record information
1. Records of Hg testing
2. Records of HF testing
3. Records of Hg control device
E. Personnel Training
F. Time for Audits
Recordkeeping Subtotal
TOTAL

(A)
Respondent
Hours per
Occurrence
(Technical
hours)
NA
NA

(I)
Total Labor
Costs Per
Year

(J)
Total NonLabor Costs
Per Year
(B x C x E)

(K)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid and Phosphate
Fertilizers NESHAP - Year 2
(B)
Non-Labor
Costs Per
Occurrence

(C)
Number of
Occurrences
Per
Respondent
Per Year

(D)
Technical
Hours per
Respondent
Per Year
(A X D)

20

$0

1

0

$0

$0

0

a

10

$6,400

0

0

$0

$0

0

0

0

0

$0

$624,000

0

b
c
c

0

8

80

8

4

$7,560

$120,000

0

c

10
0

0
23

0
0

0
0

0
0

$0
$0

$0
$46,000

0
0

g
d

1
1

10
15

7
0

70
0

7
0

4
0

$6,615
$0

$0
$0

7
0

e
a

$0

1

20

0

0
150

0
15

0
8

$0
$14,175

$0
$790,000

0
7

a

$0
$0
$0

1
1
1

3
3
10

0
8
0

0
24
0

0
2
0

0
1
0

$0
$2,268
$0

$0
$0
$0

0
0
0

24
174

2
17

1
9

$2,268
$16,443

$0
$790,000

0
7

Total Hours
200

Labor
$16,443

Non-Labor
$790,000
$0
$790,000

Total
$806,443

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
Hours per
Year
(F X .05)

20

0

0

0

1

10

0

0

$8,000

1

0

78

10

$15,000

1

10

10
0
Inc. in 3B
Inc. in 3E

$5,600
$2,000

1
1

10
15

$0
$0

20

Inc. in 3A
NA
NA
3
3
10
Inc. in 3B
NA

Summary of Respondent Burden
Initial Capital and Startup
Annualized Capital/Start-up and O & M

Footnotes:
(a) Only applicable to first year.
(b) Facilities are not subject to annual Hg testing the first or second years, costs are provided in year 3.
(c) Must perform annual HF testing. For 78 emission points, the incremental cost for using Method 320 versus 13B are included ($8,000). There are 8 emission points (oxidation reactors, defluorination units, and
clarifiers) that are currently not tested, but are applicable as noted in the subpart AA clarifications (they would incur the full Method 320 cost of $15,000).
(d) Facilities must follow performance evaluation criteria (calibrations) for control devices. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.
(e) Includes additional data submitted for Hg and HF, for emission points not currently tested. The facilities' emission points that currently conduct TF tests are not considered, as they must already report their data.
Only facilities that perform HF tests are included in year 2 costs.
(f) One facility will install a carbon adsorption system and must determine the carbon bed life; costs not applicable until year 3.
(g) Facilities will perform HF tests instead of TF tests from year 2 forward.

f

Burden Item
1. Applications
2. Surveys and Studies
3. Reporting Requirements
A. Read Rule
B. Required Activities
1. Mercury testing
2. Hydrogen fluoride testing
a. Incremental 320 Cost
b. Oxidation Reactors,
Defluorination Units, & Clarifiers
3. TF testing: Oxidation, Defluorination,
& Clarifiers
4. Performance evaluation
C. Create Information
D. Gather Information
E. Report Preparation
1. Performance test report
2. Develop monitoring plan
3. Prepare gypsum stack management
plan
Reporting Subtotal
4. Recordkeeping Requirements
A. Read Instructions
B. Implements Activities
C. Develop Record System
D. Record information
1. Records of Hg testing
2. Records of HF testing
3. Records of Hg control device
E. Personnel Training
F. Time for Audits
Recordkeeping Subtotal
TOTAL

(A)
Respondent
Hours per
Occurrence
(Technical
hours)
NA
NA

(I)
Total Labor
Costs Per
Year

(J)
Total NonLabor Costs
Per Year
(B x C x E)

(K)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Phosphoric Acid and Phosphate
Fertilizers NESHAP - Year 3
(B)
Non-Labor
Costs Per
Occurrence

(C)
Number of
Occurrences
Per
Respondent
Per Year

(D)
Technical
Hours per
Respondent
Per Year
(A X D)

20

$0

1

0

$0

$0

0

a

10

$6,400

7

4

$6,615

$44,800

0

0

0

0

$0

$624,000

0

b
c
c

0

8

80

8

4

$7,560

$120,000

0

c

10
0

0
23

0
0

0
0

0
0

$0
$0

$0
$46,000

0
0

g
d

1
1

10
15

8
0

80
0

8
0

4
0

$7,560
$0

$0
$0

8
0

e
a

$0

1

20

0

0
230

0
23

0
12

$0
$21,735

$0
$834,800

0
8

a

$0
$0
$0

1
1
1

3
3
10

7
8
1

21
24
10

2
2
1

1
1
1

$1,985
$2,268
$945

$0
$0
$0

0
0
0

55
285

6
29

3
14

$5,198
$26,933

$0
$834,800

0
8

Total Hours
328

Labor
$26,933

Non-Labor
$834,800
$0
$834,800

Total
$861,733

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
Hours per
Year
(F X .05)

20

0

0

0

1

10

7

70

$8,000

1

0

78

10

$15,000

1

10

10
0
Inc. in 3B
Inc. in 3E

$5,600
$2,000

1
1

10
15

$0
$0

20

Inc. in 3A
NA
NA
3
3
10
Inc. in 3B
NA

Summary of Respondent Burden
Initial Capital and Startup
Annualized Capital/Start-up and O & M

Footnotes:
(a) Only applicable to first year.
(b) Must perform annual Hg testing, plus semi-annual testing on one representative carbon adsorber system (there are six phosphate rock calciners).
(c) Must perform annual HF testing. For 78 emission points, the incremental cost for using Method 320 versus 13B are included ($8,000). There are 8 emission points (oxidation reactors, defluorination units, and
clarifiers) that are currently not tested, but are applicable as noted in the subpart AA clarifications (they would incur the full Method 320 cost of $15,000).
(d) Facilities must follow performance evaluation criteria (calibrations) for control devices. There are 23 process units at the 13 facilities, 12 phosphoric acid units and 11 phophate fertilizer units.
(e) Includes additional data submitted for Hg and HF, for emission points not currently tested. The facilities' emission points that currently conduct TF tests are not considered, as they must already report their data.
(f) One facility will install a carbon adsorption system and must determine the carbon bed life.
(g) Facilities will perform HF tests instead of TF tests from year 2 forward.

f

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements for the Phosphoric Acid and Phosphate Fertilizers NESHAP

Labor Costs

Non-Labor
(Annualized
Capital/Startup and
O&M) Costs

Total Costs

Year

Technical
Hours

Clerical
Hours

Management
Hours

Total
Labor
Hours

1
2
3

1,219
174
285

122
17
29

61
9
14

1,402
200
328

$115,198
$16,443
$26,933

$90,800
$790,000
$834,800

$205,998
$806,443
$861,733

Total
Average

1,678
559

168
56

84
28

1,930
643

$158,574
$52,858

$1,715,600
$571,867

$1,874,174
$624,725

Year

Number of
Responses

Reporting
Hours

Recordkeeping
Hours

Total
Hours

Hours per
Response

1
2
3

42
7
8

1,374
173
265

28
28
63

1,402
200
328

33
29
41

Total
Average

57
19

1,811
604

118
39

1,930
643

34
34