### 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 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

regulatio ns 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 hydrochlori c acid (HCI) production facilities . New facilities incl ude 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 own er/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 st ate 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 b urden 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 perform ed by either F ederal 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 facilit y at each plant site and that each plant site has only one respondent (i.e., the

### 2

owner/operator of the plant site).

Over the next three years, an averag e 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

standar ds 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 reduct ion. 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 re cords 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 p ublic health or welfare. Therefore, the

NESHAP was promulgated for this source category at 40 CFR P art 63, S ubpart 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.

### 3

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 complia nce 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 require d semiannual reports are used to determine periods of excess emissions,

identify pr oblems 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

NNNN N

.

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

duplicati on 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 , 201 5

. 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 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

### 4

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 d etermine 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 likel y.

3(e) General Guidelines

T hese reporting or recordk eeping requirements do not violate any of the regulations

promulgated by OMB under 5 CFR P art 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 lim itations 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 t hat 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).

### 5

3(g) Sensitive Questions

T he 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 ) code s for the

respondents affected by the standards , and the corresponding North American Industry

Classification System (NAICS ) 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 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

I n 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:

Notification s

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)

### 6

Notification s

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 r espondents are using monitoring equipment that automatically records

parameter data. Although personnel at the affected facility must still evaluate the data, int ernal

automation has significantly reduced the burden associated with monitoring and recordkeeping at

a plant site.

(ii) Respondent Activities

### 7

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.

### 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 Enforcement and Compliance History Online (ECHO)

and ICIS.

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 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 reco rds 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.

I nformation 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 da ta 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, r etrieve 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 take n 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 us e economies of scale to reduce their burden,

the overall burden will be reduced.

According to the Economic Impact Analysis of the Hydrochloric Acid Production

### 9

NESHAP 1 

### , 13 percent of the parent companies affected by proposed action were estimated to be

sma ll 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 collect ion 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 consi stent with the

concept of burden under the Paperwork Reduction Act. Where ver 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 per son 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 report ing requirement s is estimated to be 113,000 (Total Labor Hours from Table 1)

. T hese

hours are based on Agency studies and background documen ts 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

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

452/R01

- 014

### 10

column 1, “Total compensation.” The rates have been increased by 110 pe rcent 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 $ 7 53,000

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 o f 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/s tartup 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 o f sources of

### 11

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:

Manag erial $ 6 2. 90 (GS

- 13, Step 5, $ 39.31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 29.17 + 60% )

Clerical $2 5. 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

Hydrochlor ic 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 ca lculated 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.



### . C olumn 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

.

### 12

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, 4 00,000

. 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 11 3 ,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

### 13

are assumed to take 10% of the time required for technical tasks becaus e 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

.

Th e 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 technica l 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 I CR. 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, mainta in, 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 inform ation, 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.

### 14

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 m inimizing 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.regulat ions.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

electronicall y. 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), E PA 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, a nd the telephone

number for the docket center i s (202) 566

- 17 52

. 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 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)

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

### 16

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 11 3 ,000 $11, 4 00,000

Captial and O&M Cost o $754,000

Grand TOTAL o $12,200,000

Assumptions:

### 17

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 labo r; $ 1 0 3.97 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

. O nly sou rces 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 eithe r brining a new product on line or

by significantly i ncreasing 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 imp lement 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.

### 18

Table 2: A verage 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)

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 govern ment 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) “201 4 General Schedule” which ex cludes locality rates of pay.

### 19

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 assu med that some facilities will take ten hours to perform tests after the initial compliance determination , by either brining a new produc t on line

or by significantly increasing its production.

g We have assumed that it will take each ne w 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.