STANDARD
FORM
83­
I
SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
No.
2032.03
INFORMATION
COLLECTION
REQUEST
FOR
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FROM
HYDROCHLORIC
ACID
PRODUCTION
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
September
13,
2004
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
The
title
of
this
collection
is
"
Recordkeeping
and
Reporting
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Hydrochloric
Acid
Production."
This
is
a
revision
of
a
currently
approved
information
collection
request
(
ICR),
and
the
tracking
number
is
EPA
ICR
No.
2032.03.

1(
b)
Short
Characterization/
Abstract
This
ICR
was
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
rulemaking
developed
under
authority
of
section
112
of
the
Clean
Air
Act
(
CAA).
The
proposed
rulemaking
would
make
amendment
to
title
40,
chapter
I,
part
63,
subpart
NNNNN
 
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Hydrochloric
Acid
Production
 
of
the
Code
of
Federal
Regulations
(
CFR).
(
Hereafter,
this
subpart
is
referred
to
as
the
"
HCl
Production
NESHAP.")

The
HCl
Production
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAPs).
A
major
source
of
HAP
is
one
that
has
the
potential
to
emit,
considering
controls
(
in
place
under
a
federally
enforceable
agreement),
10
tons
or
more
of
any
one
HAP
or
25
tons
or
more
of
total
HAPs
per
year.
Respondents
are
owners
or
operators
of
affected
sources
regulated
under
the
HCl
Production
NESHAP.
All
existing
major
sources
must
be
in
compliance
with
the
requirements
of
the
HCl
Production
NESHAP
by
April
17,
2006.
All
new
or
reconstructed
affected
sources
must
be
in
compliance
with
the
requirements
of
the
HCl
Production
NESHAP
on
the
date
of
startup
or
the
effective
date
(
April
17,
2003),
whichever
is
later.

The
proposed
amendments
clarify
certain
applicability
provisions,
emission
standards,
and
testing,
maintenance,
and
reporting
requirements;
correct
several
omissions
and
typographical
errors
in
the
final
rule;
and
facilitate
compliance
and
improve
understanding
of
the
final
rule
requirements.

According
to
the
available
information,
the
HCl
production
source
category
consists
of
65
existing
facilities,
all
of
which
are
considered
to
be
potential
major
sources
and
subject
to
requirements
under
the
HCl
Production
NESHAP.
In
the
first
three
years
after
the
effective
date
(
April
17,
2003),
we
anticipate
that
six
new
HCl
production
facilities
will
be
constructed,
at
a
rate
2
of
two
new
sources
per
year
(
three
percent
growth
rate),
all
of
which
may
be
major
sources
and
subject
to
the
requirements
for
new
and
reconstructed
sources
in
the
HCl
Production
NESHAP.

The
period
considered
in
the
initial
ICR
and
throughout
this
supporting
statement
is
the
first
three
years
following
promulgation
of
the
HCl
Production
NESHAP
(
April
17,
2003).
We
estimate
that
the
total
monitoring,
inspecting,
reporting,
and
recordkeeping
(
MIRR)
costs
for
new
and
existing
sources
during
the
first
three
years
after
promulgation
are
$
7,591,435.
Of
the
estimated
total
MIRR
costs,
$
6,849,205
is
labor
dollars
for
the
first
three
years
and
$
742,230
is
capital
and
operation
and
maintenance
(
O&
M)
for
the
first
three
years.
The
annual
costs
for
each
of
the
first
three
years
after
promulgation
are
not
expected
to
be
equal
and
are
expected
to
differ
from
costs
in
subsequent
years,
because
existing
major
sources
will
likely
phase
in
their
compliance
activities
prior
to
the
compliance
date,
which
is
three
years
after
the
promulgation
date,
and
new
sources
may
be
constructed
in
subsequent
years.
See
section
6
for
more
details
on
cost
estimates.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
We
have
been
directed
by
section
112
of
the
CAA
to
regulate
the
emissions
of
HAP
from
stationary
sources.
The
HCl
Production
source
category
contains
major
sources
of
HAP
emissions
and
is
included
on
our
list
of
categories
scheduled
for
regulation.
The
HAP
identified
as
being
emitted
from
HCl
production
sources
are
hydrochloric
acid
(
HCl)
and
chlorine
(
Cl
2).

Section
114
of
the
CAA
gives
us
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
section
112
of
the
CAA.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
(
1)
identify
existing
and
new
sources
subject
to
the
HCl
Production
NESHAP
and
(
2)
ensure
that
the
requirements
specified
for
an
affected
source
subject
to
the
HCl
Production
NESHAP,
which
are
based
on
maximum
achievable
control
technology
(
MACT),
are
being
achieved.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
our
enforcement
personnel
to
(
1)
identify
existing
and
new
HAP
emission
points
subject
to
the
HCl
Production
NESHAP,
(
2)
ensure
that
MACT
is
being
properly
applied,
and
(
3)
ensure
that
control
equipment
is
being
properly
operated
and
maintained
on
a
continuous
basis
to
reduce
HAP
emissions
from
HCl
production
sources.
3
Records
and
reports
are
necessary
to
enable
us
to
identify
facilities
subject
to
the
HCl
Production
NESHAP
that
may
not
be
in
compliance.
Based
on
reported
information,
we
can
decide
whether
to
inspect
a
facility
and
which
records
or
processes
to
inspect.
The
records
that
facilities
maintain
must
indicate
to
us
whether
facility
personnel
are
operating
and
maintaining
control
equipment
properly.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
A
search
of
our
existing
standards
and
ongoing
ICRs
revealed
no
overlap
in
information
gathering
efforts
between
the
HCl
Production
NESHAP
and
other
Federal,
State,
or
local
rules.

The
HCl
Production
NESHAP
excludes
certain
HCl
Production
facilities
that
are
part
of
other
source
categories
that
are,
or
will
be,
subject
to
other
Federal
air
pollution
standards.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Because
this
is
a
rule­
related
ICR,
it
is
not
necessary
to
solicit
public
comments
prior
to
submittal
of
this
ICR
to
OMB.
However,
a
public
review
and
comment
period
will
occur
after
proposal
of
the
amendments
to
the
HCl
Production
NESHAP
in
the
Federal
Register.

3(
c)
Consultations
OMB
regulations
require
periodic
consultation
with
respondents
and
data
users
such
as
members
of
industry
as
well
as
State
and
local
governments.
We
conducted
consultations
with
several
representatives
of
companies
involved
with
HCl
production
throughout
the
NESHAP
development
process.
We
also
contacted
representatives
of
State
governments
to
obtain
permit
data
for
HCl
Production
facilities.
Table
1
presents
a
list
of
the
names,
affiliations,
and
telephone
numbers
of
several
of
the
people
we
consulted
during
the
rule
development.
4
TABLE
1.
HYDROCHLORIC
ACID
PRODUCTION
CONSULTATIONS
Name
Affiliation
Telephone
Number
Laura
Burrell,
Brad
Shanks
American
Chemistry
Council
(
703)
741­
5247
Ted
Martin
Vulcan
Chemicals
(
205)
298­
3504
Ron
Huffman
Bayer
Corporation
(
412)
777­
7642
Irene
Raiber
PPG
Industries
(
330)
825­
1217
Doris
Grego
DuPont
Dow
Elastomers
3(
d)
Effects
of
Less
Frequent
Collection
If
the
requirement
for
the
designated
representatives
of
owners
and
operators
of
affected
sources
to
submit
compliance
demonstrations
of
relevant
information
were
collected
less
frequently,
we
would
not
be
reasonably
assured
that
a
source
is
in
compliance
with
the
HCl
Production
NESHAP.
In
addition,
our
authority
to
take
administrative
action
would
be
significantly
reduced.

3(
e)
General
Guidelines
The
HCl
Production
NESHAP
requires
owners
or
operators
of
an
affected
source
to
retain
records
for
5
years,
which
exceeds
the
3­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
The
5­
year
retention
period
is
consistent
with
the
subpart
A
General
Provisions
of
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
under
Title
V
of
the
CAA.
All
subsequent
general
guidelines
have
been
followed
and
do
not
violate
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.6.

3(
f)
Confidentiality
All
information
submitted
to
us
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
our
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
subpart
B,

Confidentiality
of
Business
Information.
See
40
CFR;
41
FR
36902,
September
1,
1976;

amended
by
43
FR
3999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979.
Even
where
we
have
determined
that
data
received
in
response
to
an
ICR
is
eligible
for
confidential
treatment
under
40
CFR
Part
2,
subpart
B,
we
may
nonetheless
disclose
the
information
if
it
is
"
relevant
in
any
proceeding"
under
the
statute
[
42
U.
S.
C.
7414
(
C);
40
CFR
2.301
(
g)].
The
information
collection
complies
with
the
Privacy
Act
of
1974
and
Office
of
Management
and
Budget
(
OMB)
Circular
108.
5
3(
g)
Sensitive
Questions
Information
that
will
be
reported
consists
of
emissions
data
and
other
information
that
are
not
expected
to
be
of
a
sensitive
nature.
Therefore,
this
section
is
not
applicable.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
and
NAICS
Codes
Respondents
are
owners
or
operators
of
all
existing
and
new
HAP­
emitting
affected
sources
in
the
HCl
production
source
category.
The
source
category
and
affected
sources
regulated
by
the
HCl
Production
NESHAP
are
classified
under
the
Standard
Industrial
Classification
(
SIC)
codes
2819,
"
Industrial
Inorganic
Chemicals,
Not
Elsewhere
Classified,"

2821,
"
Plastics
Materials,
Synthetic
Resins,
and
Nonvulcanizable
Elastomers,"
and
2869,

"
Industrial
Organic
Chemicals,
Not
Elsewhere
Classified."
The
corresponding
North
American
Industrial
Classification
System
(
NAICS)
codes
are
325188,
"
All
Other
Basic
Inorganic
Chemical
Manufacturing,"
325211,
"
Plastic
Material
and
Resin
Manufacturing,"
and
325199,
"
All
Other
Basic
Organic
Chemical
Manufacturing."

4(
b)
Information
Requested
The
standards
are
based
on
add­
on
control
devices
to
reduce
HAP
emissions.
In
order
to
demonstrate
compliance
with
the
standards,
facilities
may
use
continuous
parameter
monitoring
systems
(
CPMS).
The
burden
and
cost
estimates
presented
below
assume
the
use
of
CMPS
to
demonstrate
compliance.

4(
b)(
i)
Data
items,
including
recordkeeping
requirements
All
affected
major
sources
with
an
initial
startup
date
before
the
effective
date
of
the
standards
must
submit
a
one­
time
initial
notification
not
later
than
120
days
after
the
effective
date
of
the
HCl
Production
NESHAP.
A
new
or
reconstructed
source
with
an
initial
startup
date
on
or
after
the
effective
date
of
the
standards
would
have
to
submit
the
application
for
construction
or
reconstruction
in
lieu
of
the
initial
notification.
The
application
is
required
to
contain
information
on
the
air
pollution
control
that
will
be
used
for
each
potential
HAP
emission
point.
The
information
in
the
application
for
construction
or
reconstruction
will
enable
enforcement
personnel
to
identify
the
number
of
sources
subject
to,
or
already
in
compliance
with,
the
standards.

Existing
and
new
major
sources
would
also
be
required
to
submit
the
following
notifications:
(
1)
notification
of
intent
to
conduct
a
performance
test,
and
(
2)
notification
of
6
compliance
status.
For
affected
sources
subject
to
standards
under
the
HCl
Production
NESHAP,

a
performance
test
is
required
to
demonstrate
compliance
and
must
be
conducted
within
180
days
after
the
compliance
date.
Affected
sources
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
calendar
days
before
the
performance
test
is
scheduled
to
begin.
The
notification
of
compliance
status
must
be
submitted
within
240
calendar
days
of
the
compliance
date.

Affected
sources
would
also
be
required
to
submit
the
following
reports:
(
1)
semiannual
compliance
reports;
(
2)
performance
test
reports;
and
(
3)
startup,
shutdown,
and
malfunction
reports.

The
first
compliance
report
would
be
due
on
January
31
or
July
31,
whichever
date
follows
the
end
of
the
first
calendar
half
after
the
compliance
date.
Compliance
reports
subsequent
to
the
first
compliance
report
would
be
submitted
semiannually
within
30
days
after
the
end
of
each
calendar
half.
Each
compliance
report
would
have
to
be
signed
by
a
responsible
company
official
who
certifies
its
truth,
accuracy,
and
completeness
and
certifies
that
the
affected
source
has
complied
with
the
relevant
standards.
Affected
sources
would
be
required
to
include
in
the
report
information
on
deviations
from
emission
limitations
as
well
as
information
on
startups,
shutdowns,
and
malfunctions
that
were
consistent
with
the
startup,
shutdown,
and
malfunction
plan
(
SSMP).

Affected
sources
must
conduct
a
performance
test
every
5
years
or
when
the
facility's
Title
V
permit
is
renewed,
whichever
is
earlier,
and
report
the
results
of
these
performance
tests
within
60
days
after
the
completion
of
the
test.
This
report
should
verify
that
the
operating
limits
have
not
changed
or
provide
documentation
of
the
revised
operating
parameters.

The
HCl
Production
NESHAP
would
require
owners
or
operators
of
affected
sources
to
develop
equipment
leak
detection
and
repair
(
LDAR)
plans
that
describe
in
detail
the
measures
that
will
be
put
in
place
to
detect
leaks
and
repair
them
in
a
timely
fashion.

The
HCl
Production
NESHAP
would
also
require
owners
or
operators
of
affected
sources
to
develop
an
SSMP
to
document
procedures
that
will
be
taken
in
the
case
of
any
of
these
events.

The
SSMP
must
be
prepared
by
the
affected
sources'
compliance
date.
If
a
startup,
shutdown,
or
malfunction
occurs
that
is
not
consistent
with
the
SSMP,
the
affected
source
would
be
required
to
submit
a
startup,
shutdown
and
malfunction
report
by
fax
or
telephone
within
two
working
days
7
after
starting
actions
inconsistent
with
the
SSMP
and
by
letter
within
seven
working
days
after
the
end
of
the
event.

Affected
sources
would
be
required
to
develop
a
site­
specific
test
plan
prior
to
conducting
a
performance
test.
The
test
plan
must
be
submitted
to
the
Administrator
only
if
requested
by
us.

Affected
sources
would
also
be
required
to
develop
a
site­
specific
monitoring
plan
detailing
installation,
operation,
maintenance,
and
quality
assurance
procedures
for
monitoring
equipment.

The
monitoring
plan
also
must
be
submitted
to
the
Administrator
only
if
requested
by
us.

Affected
sources
subject
to
the
HCl
Production
NESHAP
would
be
required
to
maintain
records
of
the
following:
(
1)
a
copy
of
each
notification
and
report
submitted,
and
documentation
supporting
each
notification
and
report
submitted,
(
2)
records
related
to
startup,
shutdown,
and
malfunction,
(
3)
records
of
performance
tests,
(
4)
records
of
operating
parameter
values,
and
(
5)

records
of
all
deviations
from
emission
limitations.
The
HCl
Production
NESHAP
would
require
owners
or
operators
of
affected
sources
to
retain
records
for
5
years.
Records
must
be
maintained
on­
site,
or
readily
accessible
from
on­
site
through
a
computer
or
other
means,
for
at
least
2
years
after
the
date
of
each
occurrence,
measurement,
maintenance,
corrective
action,

report,
or
record.
Records
may
be
kept
offsite
for
the
remaining
3
years
but
must
be
made
readily
available
upon
request.

4(
b)(
ii)
Respondent
activities
The
activities
that
we
assumed
would
be
performed
by
respondents
to
meet
the
requirements
of
the
HCl
Production
NESHAP
for
each
of
the
first
three
years
are
presented
in
Tables
2a
through
2c
for
existing
sources
and
in
Tables
2d
through
2f
for
new
sources.
We
have
assumed
that
two
new
HCl
production
facilities
will
be
constructed
during
each
of
the
first
three
years
after
promulgation,
all
of
which
will
be
major
sources
and
subject
to
the
rule.

In
the
first
year,
we
have
assumed
that
all
existing
major
sources
will
read
the
rule
and
submit
the
initial
notification.
In
each
of
the
second
and
third
years,
we
have
assumed
that
half
of
the
existing
facilities
will
conduct
performance
test
and
complete
other
reporting
and
recordkeeping
activities.
In
each
of
the
first
three
years,
we
have
assumed
that
two
new
sources
will
startup,
install
control
and
monitoring
equipment,
conduct
a
performance
test
and
submit
notifications
and
reports.
The
cost
of
control
equipment
is
not
included
in
this
ICR
because
it
is
not
purchased
for
the
purpose
of
satisfying
the
reporting
or
recordkeeping
requirements.
8
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
A
list
of
our
activities
for
each
of
the
first
three
years
after
promulgation
of
the
HCl
Production
NESHAP
is
provided
in
Tables
4a
through
4f.
Table
5
summarizes
the
estimated
labor
hours
and
costs
for
us
over
the
first
three
years.
These
tables
are
introduced
in
Section
6(
c)

of
this
ICR.

5(
b)
Collection
Methodology
and
Management
Information
contained
in
the
one­
time­
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
our
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Information
contained
in
the
periodic
reports
submitted
to
us
will
be
reviewed
for
accuracy
and
completeness.
Data
from
records
maintained
by
the
respondents
and
obtained
during
periodic
visits
by
our
personnel
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.

5(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
on
our
part.
We
have
reduced
the
recordkeeping
and
reporting
requirement
respondent
burden
to
include
only
the
information
needed
by
us
to
determine
compliance
with
the
HCl
Production
NESHAP.
The
HCl
Production
NESHAP
is
applicable
only
to
major
sources.

By
definition,
a
small
business
is
any
business
that
is
independently
owned
and
operated
and
not
dominant
in
its
field
as
defined
by
the
Small
Business
Administration
(
SBA)
regulations
under
Section
3
of
the
Small
Business
Act.
For
the
purpose
of
assessing
the
impacts
of
the
final
HCl
Production
NESHAP
on
small
entities,
a
small
entity
is
defined
based
on
definitions
provided
by
the
SBA.
Based
on
the
SBA
definitions,
we
identified
four
small
businesses
potentially
affected
by
the
final
NESHAP.
The
results
of
a
screening
analysis
showed
that
none
of
the
small
businesses
are
expected
to
have
compliance
costs
of
1
percent
or
more.
Therefore,
the
final
rule
will
not
have
a
significant
impact
on
a
substantial
number
of
small
entities,
and
small
business
considerations
do
not
apply.
9
5(
d)
Collection
Schedule
The
HCl
production
NESHAP
was
promulgated
in
the
Federal
Register
on
April
17,

2003.
Collection
of
data
has
begun.
The
schedule
for
reports
that
would
be
required
by
the
HCl
production
NESHAP
is
summarized
below.

The
initial
notification
for
existing
major
sources
and
new
major
sources
with
startup
dates
before
the
promulgation
date
of
the
HCl
Production
NESHAP
was
due
no
later
than
August
15,

2003.
The
notification
of
intent
to
conduct
a
performance
test
must
be
submitted
at
least
60
days
before
the
performance
test
is
scheduled
to
begin.
The
initial
performance
test
must
be
conducted
within
180
days
after
the
compliance
date.
The
notification
of
compliance
status
would
have
to
be
submitted
within
240
days
after
the
compliance
date.

Affected
major
sources
subject
to
standards
under
the
HCl
Production
NESHAP
are
required
to
submit
compliance
reports,
with
the
first
compliance
report
being
due
on
July
31,

2006.
Compliance
reports
subsequent
to
the
first
compliance
report
would
be
submitted
semiannually.
In
addition,
performance
test
reports
would
have
to
be
submitted
within
60
days
after
the
completion
of
each
subsequent
performance
test.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
The
annual
burden
for
respondent
activities
includes
labor
cost,
capital/
startup
cost,
and
O&
M
cost.
Our
estimates
of
total
burden
for
respondents
for
each
of
the
first
three
years
after
promulgation
of
the
HCl
production
NESHAP
are
presented
in
Tables
2a
through
2f.

6(
b)
Estimating
Respondent
Costs
6(
b)(
i)
Estimating
labor
costs
The
estimates
of
annual
total
technical
labor
hours
per
source
and
the
annual
number
of
activities
per
respondent
listed
in
each
of
Tables
2a
through
2f
are
based
upon
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts
and
the
number
of
emission
points
in
each
source.
Activities
that
are
one­
time­
only
activities
are
identified
as
such
in
the
tables.

The
estimated
costs
of
the
activities
listed
in
Tables
2a
through
2f
were
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics'
Internet
web
site
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t12.
htm),
Table
12,
accessed
September
26,
2002.
Labor
costs
were
divided
into
the
following
three
categories:
(
1)
technical,
(
2)
managerial,
and
1
Memorandum.
Hartmann,
A.
EC/
R
Incorporated
to
Maxwell,
W.,
U.
S.
Environmental
Protection
Agency.
Monitoring
Equipment
Cost
Estimates
for
Hydrochloric
Acid
Production.
March
21,
2001.
10
(
3)
clerical.
Managerial
and
clerical
labor
hours
were
calculated
as
5
and
10
percent,
respectively,

of
each
technical
labor
hour
requirement.
In
addition,
the
labor
rates
were
multiplied
by
1.5
to
account
for
overhead
costs.
Therefore,
we
estimated
the
cost
of
technical
labor
for
HCl
production
to
be
$
46.34
per
hour
($
46.34/
hr),
the
cost
of
managerial
labor
to
be
$
74.49/
hr,
and
the
cost
of
clerical
labor
to
be
$
31.71/
hr.
These
estimates
included
fringe
benefits.

6(
b)(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
HCl
production
facilities
subject
to
standards
under
the
HCl
Production
NESHAP
would
incur
capital
costs
associated
with
monitoring
equipment
that
these
sources
can
use
to
demonstrate
continuous
compliance
and
meet
reporting
and
recordkeeping
requirements.
For
the
purpose
of
assessing
the
impacts
of
the
final
HCl
production
NESHAP,
two
monitoring
devices
(
pH
and
liquid
flow
rate)
and
a
data
recorder
are
assumed
to
be
used
by
each
facility
to
demonstrate
compliance.
The
total
installed
capital
cost
of
this
equipment
is
estimated
at
$
5,000
($
2,000
per
monitor
and
$
1,000
for
the
data
recorder)
based
on
quotes
provided
by
equipment
manufacturers.
1
The
cost
of
add­
on
control
equipment
is
not
included
in
this
ICR
because
it
is
not
purchased
for
the
purpose
of
satisfying
the
reporting
and
recordkeeping
requirements.
See
Table
3
for
capital
cost
information.

The
total
annual
estimated
O&
M
costs
in
Box
14
of
OMB
83­
I
were
calculated
based
on
(
1)
operation
and
maintenance
costs
for
monitoring
equipment,
(
2)
the
estimated
postage
costs
for
responses
(
see
Box
13
of
OMB
83­
I)
associated
with
the
provisions
of
the
HCl
production
NESHAP
and
(
3)
contracting
costs
for
the
performance
test
required
to
demonstrate
compliance
with
this
standard.
The
annual
O&
M
cost
for
operating
the
monitoring
equipment
is
estimated
at
10
percent
of
the
total
capital
cost,
or
$
500.
Postage
costs
are
for
submittal
to
regulatory
agencies
of
notifications
and
reports
required
by
the
rule.
The
postage
rates
($
3.85
per
onepound
package
by
Priority
Mail,
and
$
0.37
per
one­
ounce
First­
Class
letter)
were
based
on
data
from
U.
S.
Postal
Services
Internet
web
site
(
http://
www.
usps.
com),
accessed
May
31,
2002,
for
rate
changes
taking
effect
on
June
30,
2002.

The
per­
scrubber
cost
of
performance
test
contracting
is
estimated,
based
on
information
provided
by
test
contractors,
to
be
$
5,275.
Using
the
assumption
that
half
of
the
existing
major
11
sources
will
have
two
separate
scrubbers
and
half
of
the
existing
major
sources
will
have
one
scrubber,
this
test
cost
is
multiplied
by
a
factor
of
1.5
to
obtain
the
average
per­
facility
contractor
cost.
It
is
assumed
that
all
new
sources
will
have
separate
scrubbers
for
process
vents,
storage
tanks
and
transfer
operations
are
routed,
so
the
contractor
cost
is
multiplied
by
a
factor
of
3.0
for
new
sources.
See
Table
3
for
O&
M
cost
information.

6(
b)(
iii)
Annualizing
Capital
Costs
The
total
installed
capital
cost
of
the
monitoring
equipment
($
5,000)
was
multiplied
by
a
capital
recovery
factor
(
CRF)
of
0.1424,
using
an
interest
rate
of
seven
percent
and
an
estimated
equipment
life
of
10
years,
to
calculate
the
annualized
capital
cost.
The
annualized
capital
cost
is
$
712.

6(
c)
Estimating
the
EPA's
Burden
and
Cost
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
HCl
Production
NESHAP,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
recordkeeping
and
reporting
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
operated
and
maintained
by
our
OAQPS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
affected
sources.
Periodic
inspections
are
part
of
our
overall
compliance
and
enforcement
program.
Therefore,
these
examinations
are
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information
and
attending
performance
tests.
It
is
assumed
that
our
staff
will
attend
only
one
performance
test
per
facility.
Labor
rates
and
associated
costs
are
based
on
the
2002
General
Schedule
(
GS)
base
annual
salary
data
from
the
U.
S.
Office
of
Personnel
Management
Internet
web
site
(
http://
www.
opm.
gov/
oca/
02tables/
gs.
htm),
accessed
September
26,
2002.
We
estimated
an
average
hourly
labor
cost
of
$
40.99
for
technical
staff,
$
67.76
for
managerial
staff,
and
$
20.80
for
administrative/
clerical
staff.
To
derive
hourly
estimates,
we
divided
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work
year.
We
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
12
factor
of
1.6
for
60
percent
overhead
expenses.
The
federal
burden
and
cost
are
detailed
in
Table
4a
through
4f
and
summarized
in
Table
5.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
To
calculate
the
total
burden
for
respondents,
we
estimated
the
number
of
respondents
(
the
respondent
universe)
to
complete
each
activity.
The
burden
for
each
activity
was
calculated
by
multiplying
the
per­
respondent
burden
per
activity
by
the
number
of
respondents.

The
respondent
universe
varies
among
the
activities
listed
in
Tables
2a
through
2f,
because
not
all
respondents
must
complete
each
activity
each
year.
The
total
burden
and
costs
are
summarized
in
Table
3.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Tables
6(
e)(
i)
Respondent
tally
The
bottom
line
respondent
burden
hours
and
costs
are
summarized
in
Table
3.
The
estimated
total
nationwide
burden
for
existing
sources
in
the
first
three
years
after
promulgation
of
the
HCl
Production
NESHAP
are
an
estimated
131,387
total
labor
hours
and
$
6,714,309.
The
burden
cost
estimate
includes
labor,
capital
and
O&
M
costs.
Because
we
anticipate
construction
of
six
new
major
sources
subject
to
the
standards
under
the
HCl
Production
NESHAP
in
the
first
three
years
following
promulgation,
our
estimated
burden
for
new
sources
is
16,570
total
labor
hours
and
$
877,125
for
the
first
three
years
after
promulgation.
The
total
estimated
annual
labor
hour
reporting
and
recordkeeping
burden
for
the
first
three
years
is
49,319
labor
hours.

The
total
estimated
annualized
capital
and
startup
costs
and
annual
operating
and
maintenance
(
O&
M)
costs
to
comply
with
the
final
standards
were
estimated
to
be
$
247,410
for
existing
and
new
sources.
Table
3
includes
summarized
annualized
capital
and
startup
costs
and
annual
O&
M
costs.
The
total
annualized
capital
and
startup
costs
reflect
the
estimated
capital
costs
of
equipment
to
comply
with
MIRR
activities
associated
with
the
final
standards.
The
total
annual
O&
M
costs
reflect
costs
that
are
associated
with
the
MIRR
equipment
but
that
are
not
included
in
the
labor
hour
burden
estimate.

The
total
capital
and
O&
M
costs
for
existing
major
sources
are
estimated
to
be
$
632,175
for
the
first
three
years
after
promulgation.
For
new
major
sources,
capital
and
annual
O&
M
costs
are
estimated
to
be
$
110,055
for
the
first
three
years
after
promulgation.

6(
e)(
ii)
The
EPA
tally
13
The
bottom
line
Federal
government
burden
hours
and
costs
that
would
result
from
this
ICR
in
the
first
three
years
following
promulgation
of
the
HCl
Production
NESHAP
are
presented
in
Tables
4a
through
4c
for
existing
major
sources
and
in
Tables
4d
through
4f
for
new
major
sources.
Estimated
hours
and
costs
for
existing
sources
are
3,276
total
labor
hours
and
$
144,949
for
the
first
three
years
after
promulgation.
Estimated
hours
and
costs
for
new
sources
are
1,688
total
labor
hours
and
$
74,704
for
the
first
three
years
after
promulgation.
Table
5
summarizes
the
Federal
government
burden
hours
and
costs
for
the
HCl
Production
NESHAP
over
the
first
three
years.

6(
e)(
iii)
Variations
in
the
annual
bottom
line
Variations
in
the
annual
bottom
line
for
this
regulation
may
occur
over
the
three
years
following
promulgation
of
this
rule
because
(
1)
certain
one­
time
activities
would
typically
occur
prior
to
the
source's
compliance
date
and
(
2)
it
is
not
until
the
end
of
the
third
year
following
promulgation
that
all
sources
must
be
in
compliance
and
therefore
subject
to
recurring
recordkeeping
and
reporting
requirements.

6(
f)
Reasons
for
Change
in
Burden
Table
2
lists
the
proposed
amendments
to
the
HCl
NESHAP
and
their
effect
on
the
burden.

TABLE
2.
CHANGES
TO
BURDEN
RESULTING
FROM
PROPOSED
AMENDEMENTS
TO
HCL
NESHAP.

Proposed
Amendment
Effect
on
Burden
Statement
Subject
sources
that
are
subject
to
subpart
EEE
of
40
CFR
part
63
or
subpart
H
of
40
CFR
part
266
and
that
meet
the
applicability
requirements
of
subpart
NNNNN
to
the
storage
tank,
transfer
operation,
and
leaking
equipment
standards
of
the
HCl
NESHAP.
Theoretically,
this
would
increase
the
burden
because
more
sources
would
be
subject
to
the
HCl
NESHAP.
In
reality,
it
is
not
anticipated
that
any
sources
will
be
covered
under
this
provision.
14
Exempt
individual
emission
streams
that
are
routed
to
subpart
EEE
hazardous
waste
combustors.
It
is
expected
that
this
change
would
not
affect
the
number
of
sources,
but
would
lower
the
number
of
affected
emission
streams
at
a
small
number
of
the
affected
sources.
Because
only
one
NOCS
is
required
per
source,
the
number
of
reports
submitted
would
not
change.
However,
the
amount
of
time
that
a
few
impacted
sources
spend
on
reporting
and
recordkeeping
activities
would
decrease.
Assuming
that
10
percent
of
the
sources
would
have
a
decrease
of
approximately
25%
in
the
relevant
activities,
the
overall
average
effort
for
each
line
item
listed
below
would
decrease
by
the
amount
shown
(
per
occurrence):
(
1)
"
notification
of
compliance
status"
by
0.5
hours,
(
2)
"
notification
of
intent
to
conduct
a
performance
test"
by
0.05
hours,
(
3)
"
conduct
performance
tests"
by
1.5
hours,
(
4)
"
record
CPMS
measurements"
by
0.03
hours,
and
(
5)
"
CPMS
calibration
and
maintenance"
by
0.1
hours.

Remove
exemption
for
sources
subject
to
subpart
O.
This
change
was
made
because
the
exemption
could
not
possibly
apply
to
any
sources,
so
it
would
not
affect
the
burden.

Change
definition
of
"
equipment
in
HCl
service."
This
change
would
have
no
effect
on
the
burden
because
it
merely
clarifies
EPA's
original
intent
for
which
equipment
is
covered
by
the
HCl
NESHAP.

Clarify
that
sources
do
not
need
to
install
an
add­
on
control
device
in
order
to
comply
via
the
outlet
concentration
format
of
the
emission
limit.
This
change
would
have
no
effect
on
the
burden
because
it
merely
clarifies
EPA's
original
intent
and
is
not
a
substantive
change
from
the
final
rule.

Change
the
frequency
of
subsequent
performance
tests
for
sources
complying
without
the
use
of
an
addon
control
device.
Since
only
the
initial
performance
test
is
included
in
the
burden
estimate,
this
change
would
not
affect
the
number
of
test
reports
submitted
under
the
current
burden
estimate.

Addition
of
verification
statement
in
compliance
reports
for
sources
complying
without
the
use
of
a
control
device.
Sources
are
already
required
to
submit
semi­
annual
compliance
reports.
The
addition
of
one
statement
to
the
report
is
a
very
minimal
change,
so
the
burden
estimate
was
not
increased
to
reflect
this
proposed
amendment.
15
Allow
planned
routine
maintenance
of
storage
tanks
for
240
hours
per
year
without
emptying
the
tank.
Add
associated
recordkeeping
and
reporting
requirements.
This
proposed
amendment
would
increase
the
time
spent
preparing
compliance
reports
by
0.5
hours
per
compliance
report
for
all
sources.

Change
submission
date
of
NOCS
to
240
days
after
the
compliance
date
to
allow
one
NOCS
per
source.
This
change
would
not
affect
the
estimate
of
the
number
of
NOCS
submitted,
because
it
was
already
assumed
that
each
source
would
submit
only
one.

Require
submission
of
LDAR
and
sitespecific
monitoring
plans
with
semiannual
compliance
report
when
changes
are
made.
Since
sources
are
already
required
to
submit
revisions
to
these
plans,
this
proposed
amendment
would
not
change
the
burden.

Correct
omissions
and
typographical
errors.
These
would
not
affect
the
burden.

In
summary,
the
following
changes
have
been
made
to
Tables
2a
through
2f
(
all
changes
are
per
occurrence)
due
to
program
changes:

1.
c.
ii
Notification
of
intent
to
conduct
a
performance
test
­
0.05
hours
1.
c.
iii
Notification
of
compliance
status
­
0.5
hours
1.
c.
iv
First
compliance
report
+
0.5
hours
1.
c.
v
Semiannual
compliance
report
+
0.5
hours
2.
b.
ii
Conduct
performance
tests
­
1.5
hours
2.
b.
iii
Record
CPMS
measurements
­
0.03
hours
2.
b.
iv
CPMS
calibration
and
maintenance
­
0.1
hours
6(
g)
Burden
Statement
The
annual
average
burden
is
49,319
labor
hours.
The
respondent
universe
consists
of
71
facilities,
of
which
65
are
existing
sources
and
6
are
new
sources
expected
to
be
constructed
in
the
first
three
years
following
promulgation
of
the
HCl
Production
NESHAP.
The
total
burden
hours
and
costs,
respectively,
for
this
collection
are
presented
in
Table
3.

The
total
three­
year
monitoring,
recordkeeping,
and
reporting
burden
for
this
collection
is
estimated
at
147,957
labor
hours,
and
the
annual
average
burden
is
49,319
labor
hours.
The
annualized
capital
costs
for
monitoring
equipment
is
estimated
to
be
$
712
per
facility.
Annual
O&
M
costs
are
estimated
to
be
$
664,622
for
new
and
existing
sources
over
three
years,

averaging
$
221,541
per
year.
The
hour
burden
estimate
includes
time
to
read
the
rule,
write
and
16
submit
required
notifications
and
reports,
perform
recordkeeping
activities,
perform
performance
tests,
develop
plans
for
implementing
recordkeeping
requirements,
develop
record
systems,
train
personnel,
and
store,
file
and
retrieve
records.
The
cost
burden
estimate
includes
the
cost
of
labor
hours,
purchase
of
capital
equipment
necessary
to
generate
and
record
data
needed
to
meet
the
MIRR
requirements
in
the
rule,
postage
to
submit
notifications
and
reports,
and
performance
test
contractor
costs.
The
document
may
be
found
in
E­
Dockets
under
the
E­
docket
number
of
OAR­

2002­
0057.

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
purpose
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
respond
to
a
collection
of
information;
search
existing
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
17
PART
B
OF
THE
SUPPORTING
STATEMENT
Not
applicable.
No
sampling
or
other
methods
are
used
to
select
respondents
because
all
owners
or
operators
of
facilities
subject
to
the
HCl
production
NESHAP
are
required
to
collect
information.
