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 2032.07, 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 United 

States Environmental Protection Agency (EPA) regional office.

 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 81 respondents per year will be subject to the 

standard, and 2 additional respondents per year will become subject to the standard. 

OMB approved the currently active ICR without any “Terms of Clearance.” 

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 privately, owned for-profit businesses. The burden to the “Affected Public” is listed below in 
2

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 federal employees or government contractors and may

be found in Table 2: Average Annual EPA Burden and Cost – NESHAP for Hydrochloric Acid 

Production (40 CFR Part 63, Subpart NNNNN) (Renewal). 

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 cause or contribute to air pollution that may reasonably be 

anticipated to endanger 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. 
3

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. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart

NNNNN.

3(a) Nonduplication

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 (76 FR 26900) on May 9, 2011. 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 Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of all compliance data. The growth rate for the industry is based on 

our consultations with the Agency’s internal industry experts. 

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 the Chlorine Chemistry Council at (202) 249-

7000, and DuPont at (800) 441-7515. 
4

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 (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 
5

production facilities. The United States Standard Industrial Classification (SIC) code 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 NESHAP for 

Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN). 

A source must make the following reports:

Notifications

Initial notification 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)

Annual performance test report 63.10(d)(2), 63.9050

Startup, shutdown, malfunction report 63.10(d)(5), 63.9050(d)

A source must keep the following records:
6

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(a)(2)

Record of continuous parameter monitoring systems 

(CPMS) measurements 63.10(b), 63.9055(b)(3)

CMPS calibration and maintenance 63.9055(b)

Check for and repair leaks 63.9055(b)(5)

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. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities
7

Respondent Activities

Read instructions.

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.

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way e.g., continuous parameter monitoring system. Although personnel at the source 

still need to evaluate the data, this type of monitoring equipment has significantly reduced the 

burden associated with monitoring and recordkeeping.

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.
8

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 Online Tracking Information System (OTIS). 

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 entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS 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 

 

1 Economic Impact Analysis of the Proposed Hydrochloric Acid (HCl) Production NESHAP, September 2001, EPA452/R01-014
9

small entities as defined by the Small Business Administration. The Agency assumes that 13 

percent of the 81 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 105,033 (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 $120.77 ($57.51 + 110%) 

Technical $99.39 ($47.33 + 110%)

Clerical $50.04 ($23.83 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

December 2011, “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 
10

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 79 (existing) $669,367

N/A N/A N/A $16,385 2 (new) $32,770

Total $1,424 $702,137

The total capital/startup costs for this ICR are $1,424. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $702,137. 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 $703,561. These are 

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 

$17,413. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)
11

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2011 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. 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

79 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 81 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 77 0 0 79

2 2 79 0 0 81

3 2 81 0 0 83

Average 2 79 0 0 81

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 81. 

The total number of annual responses per year is calculated using the following table: 
12

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 79 2 0 158

Subsequent performance test 

report 0 1 0 0

Startup, shutdown, 

malfunction report 2 10 0 20

Total 186

The number of Total Annual Responses is 186.

The total annual labor costs are $10,086,076. 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 105,033. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost - NESHAP for Hydrochloric Acid Production 

(40 CFR Part 63, Subpart NNNNN) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 565 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $703,561. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.
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(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 $17,413. See Table 2: Average Annual EPA Burden and Cost -

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

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, and corrections to 

mathematical errors found in the previous ICR. The growth in respondent universe also results 

in an increase in the 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. 

There is a decrease in capital/startup costs in this ICR as compared to the most recently 

approved ICR. The previous ICR includes startup costs for all existing and new respondents. 

This ICR was updated to correctly reflect capital/startup costs associated with new sources only. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 565 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 
14

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) 566-1927. 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.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart

 NNNNN) (Renewal)

Burden item

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

Personhours 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. Read instructions c

4 1 4 2 8 0.4 0.8 $883.46

 B. Gather information c

4 1 4 2 8 0.4 0.8 $883.46

 C. Write reports

 Initial notification c

2 1 2 0 0 0 0 $0

 Application for construction c

2 1 2 2 4 0.2 0.4 $441.73

 Notification of intent to conduct 

performance test 2 1 2 2 4 0.2 0.4 $441.73

 Notification of compliance status c

19.5 1 19.5 2 39 1.95 3.9 $4,306.87

 First compliance report c, d 8.5 1 8.5 2 17 0.85 1.7 $1,877.35

 Semiannual compliance report e

4.5 2 9 79 711 35.55 71.1 $78,517.51

 Subsequent performance test reports f

4 1 4 0 0 0 0 $0

 Startup, shutdown, malfunction 

report g 2 10 20 2 40 2 4 $4,417.30

Subtotal for Reporting Requirements 956

4. Recordkeeping Requirements

 A. Plan activities c, h 10 1 10 2 20 1 2 $2,208.65

 B. Implement activities 

 Record startups, shutdown, 

malfunctions i 1 100 100 81 8,100 405 810 $894,503.25

 Conduct performance test 48.5 1 48.5 81 3,928.5 196.43 392.85 $433,834.08
16

 Record CPMS measurements j

1 365 365 81 29,565 1,478.25 2,956.5 $3,264,936.86

 CMPS calibration and maintenance k

3.9 50 195 81 15,795 789.75 1,579.5 $1,744,281.34

 Check for and repair leaks l

1 365 365 81 29,565 1,478.25 2,956.5 $3,264,936.86

 C. Develop record system

 Startup, shutdown, malfunction plan c 40 1 40 2 80 4 8 $8,834.60

 Site-specific monitoring plan c

20 1 20 2 40 2 4 $4,417.30

 Site-specific test plan c

20 1 20 2 40 2 4 $4,417.30

 Leak detection and repair plan c  40 1 40 2 80 4 8 $8,834.60

 D. Time to train personnel

 CPMS acquisition and installation c

20 1 20 2 40 2 4 $4,417.30

 CPMS inspection and monitoring c

4 1 4 2 8 0.4 0.8 $883.46

 E. Store, file, and maintain records m

20 1 20 81 1,620 81 162 $178,900.65

 F. Retrieve records/reports n

20 1 20 81 1,620 81 162 $178,900.65

Subtotal for Recordkeeping Requirements 104,077

TOTAL LABOR BURDEN AND COST

(rounded) 105,033 $10,086,076 

 Assumptions:

 a

 We have assumed that the average number of respondents that will be subject to the rule will be 81. 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: $120.77 per hour for Executive, Administrative, and Managerial labor; $99.39 per hour for Technical labor, and 

 $50.04 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2011, “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.

 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.
17

 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.
18

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

 NNNNN) (Renewal)

Activity

(A) 

Personhours per 

occurrence

(B) No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

Personhours per 

year 

(E=CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per year 

(Ex0.1)

(H) Cost, $ 

b

 Review initial notification c

4 1 4 0 0 0 0 $0 

 Review application for construction c

4 1 4 2 8 0.4 0.8 $414.60 

 Review notification of intent to conduct test d

4 1 4 2 8 0.4 0.8 $414.60 

 Review notification of compliance status c

20 1 20 2 40 2 4 $2,072.98 

 Review compliance report e

20 2 40 2 80 4 8 $4,145.96 

 Review subsequent performance test report f

10 1 10 0 0 0 0 $0 

 Review startup, shutdown, malfunction report

8 10 80 2 160 8 16 $8,291.92 

 Attend performance test 20 1 20 2 40 2 4 $2,072.98 

TOTAL ANNUAL BURDEN AND COST 

386 $17,413.03 

 Assumptions:

 a We have assumed that the average number of respondents that will be subject to the rule will be 81. 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 $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step 3,

 $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.
19

 c

 This is a one-time only activity for each facility.

 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.