2032ss08

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal), EPA ICR Number 2032.08, OMB Control Number 2060-0529

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the regulations published at 40 CFR Part 63, Subpart NNNNN were proposed on September 18, 2001, promulgated on April 17, 2003, and amended on April 7, 2006. These regulations apply to existing and new hydrochloric acid (HCI) production facilities. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart NNNNN.

In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They 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 monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this Part shall maintain a file of these measurements, and retain the file for at least five 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 U. S. Environmental Protection Agency (EPA) regional office.

All of the hydrochloric acid production facilities in the United States are owned and operated by the hydrochloric acid production industry (the “Affected Public”). None of the facilities in the United States are owned by state, local, tribal or the federal government. They are all privately-owned, for-profit businesses. The burden to the “Affected Public” is listed below in Table 1: Annual Respondent Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed by either Federal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal).

Based on our consultations with industry representatives, there is an average of one affected facility at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, an average of 87 respondents per year will be subject to the standard, and 2 additional respondents per year will become subject to the standard. The industry growth rate is based on the Agency’s estimate from a previous renewal.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner/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 when 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, hazardous air pollutant (HAP) emissions from hydrochloric acid production facilities either cause or contribute to air pollution that may reasonably be anticipated to endanger either public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR Part 63, Subpart NNNNN.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, leaks are being detected and repaired, and the standard is being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart NNNNN.

3(a) Non-duplication

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 its 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 (80 FR 32116) on June 5, 2015. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS).  ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 87 respondents will be subject to the standard over the three year period covered by this ICR

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted: 1) the Chlorine Chemistry Council, at (202) 249-7000; and 2) BASF, at (301) 725-7017. No comments were received.

It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice.

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 proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.

3(f) Confidentiality

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

The reporting or recordkeeping requirements in the standard do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are hydrochloric acid production facilities. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards, and the corresponding North American Industry Classification System (NAICS) codes are listed below.

Standard (40 CFR Part 63, Subpart NNNNN)	SIC Codes	NAICS Codes
Industrial Inorganic Chemicals, Nonvulcanizable Elastomer Compounds (NEC) (except activated carbon and charcoal, alumina, recovering sulfur from natural gas, and inorganic dyes).	2819	325188
Plastics Materials, Synthetic and Resins, and Nonvulcanizable Elastomers	2821	325211
Industrial Organic Chemicals, NEC (except aliphatics, carbon bisulfide, ethyl alcohol, cyclopropane, diethylcyclohexane, naphthalene sulfoni).	2869	325199

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN).

A source must make the following reports:

Notifications
Initial notification (for sources that start up before April 17, 2003 only); or Application of construction or reconstruction (for sources that start up on or after April 17, 2003)	63.9(b)(2) & (4), 63.9045(b)-(c)
Notification of intent to conduct performance test	63.7(b)-(c), 63.8(f)(4) & (6), 63.9(b)-(h), 63.9045(a)
Notification of compliance status	63.9(h)(2), 63.9045(e)-(f)
First compliance report	63.10(a), 63.9050(b)(2)
Semiannual compliance report	63.9050(b)
Startup, shutdown, malfunction report	63.10(d)(5), 63.9050(d)

A source must keep the following records:

Recordkeeping
Initial notification or notification of compliance status	63.10(b)(2)(xiv), 63.9055(a)
Record of startup, shutdown, and malfunctions	63.6(e)(3), 63.9055(b)(1)
Conduct performance tests	63.10(b)(2)(viii), 63.9055(b)(2)
Record of continuous parameter monitoring systems (CPMS) measurements	63.10(b), 63.9055(b)(3)
Site-specific monitoring plan and equipment LDAR plan	63.9055(b)(5)
Records of planned routine maintenance performed on control device	63.9055(b)(6)
Records are required to be retained for five years	63.10(b)(1)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply pressure for control device.

Perform initial performance test, and repeat performance tests if necessary.

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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

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

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and enforcement 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/operator for five years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. 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 to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

According to the Economic Impact Analysis of the Hydrochloric Acid Production NESHAP¹, 13 percent of the parent companies affected by proposed action were estimated to be small entities as defined by the Small Business Administration. The Agency assumes that 13 percent of the 87 facilities affected by this ICR, or 11 facilities, are small entities.

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 - NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal).

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 Subpart 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. Wherever 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 113,000 (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 NESHAP 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 $123.93 ($61.87 + 110%)

Technical $103.97 ($49.51 + 110%)

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.

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

The type of industry costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. 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(s) and other costs such as photocopying and postage.

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

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Continuous monitoring systems (CMS)	$712	2	$1,424	$8,473	85 (existing)	$720,205
	N/A	N/A	N/A	$16,385	2 (new)	$32,770
Total			$1,420			$753,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $1,420. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $753,000. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $754,000. These are the total recordkeeping costs.

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 $17,600.

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%)

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule, which excludes the locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 85 existing respondents will be subject to the standard. It is estimated that an additional 2 respondents per year will become subject. The overall average number of respondents, as shown in the table below is 87 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR.

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	2	83	0	0	85
2	2	85	0	0	87
3	2	87	0	0	89
Average	2	85	0	0	87

¹ New respondents include sources with constructed, reconstructed and modified affected facilities.

.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is 87.

The total number of annual responses per year is calculated using the following table:

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Initial notification	0	1	0	0
Application for construction	2	1	0	2
Notification of intent to conduct performance test	2	1	0	2
Notification of compliance status	2	1	0	2
First compliance report	2	1	0	2
Semiannual compliance report	85	2	0	170
Subsequent performance test report	0	1	0	0
Startup, shutdown, malfunction report	2	10	0	20
			Total	198

The number of Total Annual Responses is 198.

The total annual labor costs are $11,400,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 113,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports.  Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 571 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $754,000. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 386 labor hours at a cost of $17,600. See below Table 2: Average Annual EPA Burden and Cost - NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports.  Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an increase in burden hours to the respondent as compared to the most recently approved ICR. The increase is due to industry growth in the past three years, resulting in additional number of respondents that are subject to this standard. The growth in respondent universe also results in an increase in the number of responses and total O&M costs.

In addition, there is an increase in burden costs to both the respondent and the Agency due to an adjustment in labor rates. This ICR uses the most recent labor rates from the Bureau of Labor Statistics in calculating the labor costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 571 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-2011-0275. 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 Ave., NW, Washington, DC. 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 (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0275 and OMB Control Number 2060-0529 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 – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart

NNNNN) (Renewal)

Burden item	(A) Person-hours per occurrence	(B) No. 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) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with rule requirements c	4	1	4	87	348	17.4	34.8	$40,140.23
B. Gather information c	4	1	4	2	8	0.4	0.8	$922.76
C. Write reports
Initial notification c	2	1	2	0	0	0	0	$0.00
Application for construction c	2	1	2	2	4	0.2	0.4	$461.38
Notification of intent to conduct performance test	2	1	2	2	4	0.2	0.4	$461.38
Notification of compliance status c	19.5	1	19.5	2	39	1.95	3.9	$4,498.47
First compliance report c, d	8.5	1	8.5	2	17	0.85	1.7	$1,960.87
Semiannual compliance report e	4.5	2	9	85	765	38.25	76.5	$88,239.31
Subsequent performance test reports f	4	1	4	0	0	0	0	$0.00
Startup, shutdown, malfunction report g	2	10	20	2	40	2	4	$4,613.82
Subtotal for Reporting Requirements					1,409			$141,298
4. Recordkeeping Requirements
A. Plan activities c, h	10	1	10	2	20	1	2	$2,306.91
B. Implement activities
Record startups, shutdown, malfunctions i	1	100	100	87	8700	435	870	$1,003,505.85
Conduct performance test	48.5	1	48.5	87	4219.5	210.975	421.95	$486,700.34
Record CPMS measurements j	1	365	365	87	31755	1587.75	3175.5	$3,662,796.35
CMPS calibration and maintenance k	3.9	50	195	87	16965	848.25	1696.5	$1,956,836.41
Check for and repair leaks l	1	365	365	87	31755	1587.75	3175.5	$3,662,796.35
C. Develop record system
Startup, shutdown, malfunction plan c	40	1	40	2	80	4	8	$9,227.64
Site-specific monitoring plan c	20	1	20	2	40	2	4	$4,613.82
Site-specific test plan c	20	1	20	2	40	2	4	$4,613.82
Leak detection and repair plan c	40	1	40	2	80	4	8	$9,227.64
D. Time to train personnel			0			0	0	$0.00
CPMS acquisition and installation c	20	1	20	2	40	2	4	$4,613.82
CPMS inspection and monitoring c	4	1	4	2	8	0.4	0.8	$922.76
E. Store, file, and maintain records m	20	1	20	87	1740	87	174	$200,701.17
F. Retrieve records/reports n	20	1	20	87	1740	87	174	$200,701.17
Subtotal for Recordkeeping Requirements					111,760			$11,209,564
TOTAL LABOR BURDEN AND COST (rounded) o					113,000			$11,400,000
Captial and O&M Cost o								$754,000
Grand TOTAL o								$12,200,000

Assumptions:

^a We have assumed that the average number of respondents that will be subject to the rule will be 87. There will be two additional new sources per year that

will become subject to the rule over the three-year period of this ICR.

^b This ICR uses the following labor rates: $123.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. 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% to

Account for the benefit packages available to those employed by private industry.

^c This is a one-time only activity for each facility. Only sources that started up prior to April 17, 2003 are required to submit initial notification.

^d We have assumed that two new respondents will prepare the first compliance report.

^e We have assumed that it will take each respondent 4.5 hours two times per-year to prepare the semiannual compliance report.

^f We have assumed that some facilities will take 4 hours to perform tests after the initial compliance determination , by either brining a new product on line or

by significantly increasing its production.

^g We have assumed that it will take each new respondents two hours ten times a year to prepare a SSM report.

^h We have assumed that it will take each respondent 10 hours to record plan activities.

ⁱ We have assumed that each respondent will have to implement SSM activities 100 times per-year.

^j We have assumed that respondents will have to record CPMS measurements 365 time per year.

^k We have assumed that respondents will have to implement CMPS calibration and maintenance activities 50 times per year.

^l We have assumed that respondent are required to check for and repair leaks 365 times per-year.

^m We have assumed that each respondent will take 20 hours once per-year to store, file and maintain records.

ⁿ We have assumed that it will take respondent 20 hours to retrieve records/reports once per-year.

^o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart

NNNNN) (Renewal)

Activity	(A) Person-hours per occurrence	(B) No. 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) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Review initial notification c	4	1	4	0	0	0	0	$0.00
Review application for construction c	4	1	4	2	8	0.4	0.8	$418.72
Review notification of intent to conduct test d	4	1	4	2	8	0.4	0.8	$418.72
Review notification of compliance status c	20	1	20	2	40	2	4	$2,093.60
Review compliance report e	20	2	40	2	80	4	8	$4,187.20
Review subsequent performance test report f	10	1	10	0	0	0	0	$0.00
Review startup, shutdown, malfunction report g	8	10	80	2	160	8	16	$8,374.40
Attend performance test	20	1	20	2	40	2	4	$2,093.60
TOTAL ANNUAL BURDEN AND COST (rounded) h					386			$17,600

Assumptions:

^a We have assumed that the average number of respondents that will be subject to the rule will be 87. There will be two additional new sources per year that

will become subject to 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 $62.90 (GS-13, Step 5, $39.31 x 1.6), Technical rate of $46.67(GS-12, Step 1, $29.17 x 1.6), and Clerical rate of $25.25 (GS-6, Step 3,

$15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality rates of pay.

^c This is a one-time only activity for each facility. Only sources that started up prior to April 17, 2003 are required to submit initial notification.

^d We have assumed that each respondent will take 4 hours to review notification of intent to conduct test.

^e We have assumed that each respondent will take twenty hours to review compliance report twice per year.

^f We have assumed that some facilities will take ten hours to perform tests after the initial compliance determination , by either brining a new product on line

or by significantly increasing its production.

^g We have assumed that it will take each new respondents eight hours to review the SSM report. This report will be done.

^h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

1 Economic Impact Analysis of the Proposed Hydrochloric Acid (HCl) Production NESHAP, September 2001, EPA-452/R01-014