**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Hydrochloric Acid Production (40 CFR**  **P art 63,**  **S ubpart NNNNN) (Renewal)** 
**1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Hy drochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal), EPA I CR Number 2032.07, OMB Control Number 2060

- 0529 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for th e 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 appl y to existing and new hy drochlori c acid (HCI) production facilities . New faci lities 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, pe rformance 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 an y startup, shutdown, or malfunction in the operation of an affected facility , or any p eriod during which the monitoring sy stem 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 thi s 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 authorit y, the reports are sent directly to the United States E nvironmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facilit y 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 ye ars, an average of 81 respondents per ye ar will be subject to the standard , and 2 additional respondents per ye ar will become subject to the standard. OMB approved the currently active IC R without any

“Terms of Clearance.” All of the hy drochloric acid production facilities in the United States are owned and operated b y the h yd rochloric acid production industry (the “Affected Public”). None of the facilities in the United States are owned b y state, local, tribal or the federal government. They are privatel y, owned for

- profit businesses. The burden to the “Affected Public” is listed below in2

Table 1: Annual Responde nt Burden and Cost

– NESHAP for Hy drochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal). The burden to the “Federal Government” is attributed entirel y to work performed b y federal employ ees or government contractors and may be found in Tabl e 2: Average Annual EPA Burden and Cost

– NESHAP for Hy drochloric 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 Clea n 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 re quire 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 reasonabl y require. In the Administrator's judgment, hazardous air pollutant ( HAP ) emissions from hy drochloric acid production facilities cause or contribute to air pollution that may reasonabl y 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 t he Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in orde r 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 th e requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated, leaks are being detected and repaired, and the standard is being met. The performance te st may

also be observed. The require d 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 directl y to the appropriate EPA reg ional office. Otherwise, the information is sent directl y 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 cop y of the report submitted to the state or local ag ency 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 th is I CR 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 i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three y ears. 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 Sy ste m (OTIS ) which is operated and maintained b y EPA's Office of Compliance. OTI S 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 intern al 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 mini mum information needed for compliance purposes. In developing this I CR , 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordk eeping requirements do not violate any of the regulations promulgated b y 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 y ears. This is consistent with the General Provisions as applied to the standards. EPA believes that the five ye ar records retention requirement is consistent the Part 70 permit program and the five ye ar statute of lim itations on which the permit program is based. The retention of records for five ye ars allows EPA to establish the compliance history of a source, an y pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has found t hat the most flagrant violators have violations extending bey ond five ye ars. 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; amende d by

43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Inf ormation Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are hy drochloric acid5

production facilities . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards , and the corresponding North American Industry Classification Sy stem (NAI CS ) codes are listed below.

**Standard (40 CFR**  **P art 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 dy es). 2819 325188 Plastics Materials, Sy

nthetic and Resins, and Nonvulcanizable Elastomers 2821 325211 Industrial Organic Chemicals, NEC (except aliphatics, carbon bisulfide, ethy l alcohol, cy clopropane, diethy lcy clohexane, naphthalene sulfoni). 2869 325199

**4(b) Information Requested (i) Data Items** 
I n this ICR , all the data that is recorded or reported is required b y NESHAP for Hy drochloric Acid Production (40 CFR Part 63, Subpart NNNNN). A source must make the following reports:

**Notification s**  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 sy stems (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 r espondents 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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at 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 sy stems for the purpose of collecting, validating, and verify ing information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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 s ys tem . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly red uced 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 ac quisition, analy sis, 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Co llection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to compl y 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.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tra cking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **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 th e process operations and the ty pes of control equipment employ ed, 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, there fore, 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 Anal ys is of the Hy drochloric Acid Production NESHAP 1 , 13 percent of the parent companies affected b y proposed action were estimated to be

1 Economic Impact Analysis of the Proposed Hydrochloric Acid (HCl) Production NESHAP, September 2001, EPA

452/R01

- 0149

small entities as defined by the Small Business Administration. The Agency assumes that 13 percent of the 81 facilities affected by this I CR, or 11 facilities, ar e 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 Hy drochloric 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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, specific tasks and major assumptions have been identified. Responses to this inform ation 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 display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three y ears from these recordkeeping and reporting requirement s is estimated to be 105,03 3 (Total Labor Hours from Table 1)

. T hese hours are based on Agency studies and background documen ts from the development of the reg ulation, Agency

knowledge and experience with the NESHAP program, the previously approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR 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 201 1 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employ ed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the information collection activities in the10

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 photocop ying and postage.

**(iii) Capital/Startup vs. Operation and Maintenan ce (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 mo nitoring 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 I CR are $1,424. This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR 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 y ears of the IC R 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 anal ys is 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 o f sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three y ears of the ICR is estimated to be $ 17,413

. This cost is based on the average hourl y labor rate as follows:
Mana gerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% )11 Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 1 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 employ ees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Hy drochlo ric 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 I CR, on average over the next three ye ars, approximately 79 existing respondents will be subject to the standard. It is estimated that an additional 2 respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below is 81 per year. The number of respondents is ca lculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports Year (A) Number of Ne w 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 7 7 0 0 7 9 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.

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 81

. The total number of annual responses per ye ar 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 Sem iannual 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 Hy drochloric 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, respectivel y, and summarized below. **(i) Respo ndent Tally**  The total annual labor hours are 105,03 3

. Details regarding these estimates may be found in Table 1: Annual Respondent Burden and Cost

- NESHAP for Hy drochloric 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 calculation s are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.13 **(ii) The Agency Tally** The average annual Agency burden and cost over next three y ears is estimated to be 386 labor hours at a cost of $17,413 . See Table 2: Average Annual EPA Burden and Cost

- NESHAP for Hy drochloric 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 recentl y approved ICR. The increase is due to industry growth in the past three y ears, resulting in additional number of respondents that are subject to this standard , and corrections to mathematical errors found in the previous I CR

. The growth in respon dent 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 I CR 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 recentl y approved ICR. The previous I CR includes startup costs for all existing and new respondents. This I CR 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 t otal time, effort, or financial resources expended b y 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 techno logy and s ys tems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 display s 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 informatio n, 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 I CR under Docket ID Number EPA

- HQ

- OECA

- 2011

- 027 5

. 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 the14

contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcemen t 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, exclud ing legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 1927

. Also, y ou can send comments to the Office of In formation and Regulatory Affairs, Office of Management and B udget, 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 P**  **art 63, S**  **ubpart 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)** 

**Managem ent**  **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 95**  **6** 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 $433,834.0816

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 104,07**  **7 TOTAL LABOR BURDEN AND COST**  **(rounded) 105,03**  **3 $10,086,076** 

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be 81. There w ill be two additi onal ne w sources per year that wi ll becom e 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 hou r 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, “Tabl e 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

- tim e only activity for each facility. d We have assumed that two ne w 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 fac ilities will take 4 hours to perform tests after the initial compliance determination , by either brining a new product on li ne or by significantly increasing its production. g We have assumed that it will take each new respondents tw o hours ten times a year to prepare a SSM report. h We have assumed that it w ill 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 responde nt 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 retriev e records/reports once per

- year.18

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Hydrochloric Acid Production**  **(40 CFR P**  **art 63, S**  **ubpart 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)** 

**Managem ent**  **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 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 tw o additiona l ne w sources per year that will become subject to the rule over the three

- year period of this ICR. b This co st is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government ov erhead 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 fac ility. 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 tw ice per year. f We have assumed that some facilities will take ten hours to perform tests after the initial compliance determination , by eit her brining a new produc t on line or by significantly increasing its production. g We have assumed that it w ill take each new respondents eight hours to review the SSM report. This report will be done.