                  

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN)
(Renewal),    EPA ICR Number 2032.06, OMB Control Number 2060-0529 

	1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Hydrochloric Acid Production were proposed on September 18, 2001 (66
FR 48174), final rule on April 17, 2003 (68 FR 19076), amended on August
24, 2005 (70 FR 49530), and promulgated on April 7, 2006 (71 FR 17738). 
This subpart applies to each new, reconstructed, or existing affected
major source at a hydrochloric acid (HCI) production facility.  A major
source of hazardous air pollutants (HAP) is one that emits or has the
potential to emit any single HAP at a rate of 9.07 megagrams (10 tons)
or more per year, or any combination of HAP at a rate of 22.68 megagrams
(25 tons) or more per year.  The HAP identified as being emitted from
HCI production sources are hydrochloric acid (HCI) and chlorine (C12). 
All existing major sources must be in compliance with the requirements
of the HCI production by April 17, 2006.  All new or reconstructed
affected sources must be in compliance with the requirements of the HCI
production on the date of startup or the effected date of April 17,
2003, whichever is later.

	In general, all NESHAP standards require one-time only initial
notifications, compliance status reports, and performance tests 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 (SSM) 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.  Semiannual compliance reports are also required.

	Any owner/operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.     In the event that there is no such delegated authority,
the reports are sent directly to the United States Environmental
Protection Agency (EPA) regional office.

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

	There are approximately 75 respondents that will be subject to the
regulation over the period covered by this Information Collection
Request (ICR), and it is estimated that two 

additional respondents per year will become subject to the regulation in
the next three years.

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

2.  Need for and Use of the Collection

	2(a)  Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and shall require the maximum degree of emission reduction. 
In addition, section 114(a) states that the Administrator may require
any owner/operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports;   (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, HAP emissions from hydrochloric acid
production facilities cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP were promulgated for the 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 were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

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

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

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

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

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

	3(a)  Non-duplication

	If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

	3(b)  Public Notice Required Prior to ICR Submission to OMB

	An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

	3(c)  Consultations

	During the previous ICR renewal, EPA consulted with an industry
representative from the Chlorine Chemistry Council to find ways to
reduce the recordkeeping and reporting burden or to improve the language
in the standard, in order to facilitate compliance.  

	EPA reviewed information available from the United States Census
Bureau, the AIRS Facility Subsystem (AFS), which is the primary source
of information regarding the number of existing sources, and websites
covering hydrochloric acid production.

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 that emission limitations are met.  If the information
required by these standards was collected less frequently, the
likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.

	3(e)  General Guidelines

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

	These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the Part 70 permit program and the five-year statute of limitations
on which the permit program is based.  Also, the retention of records
for five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  If records were retained for less than five
years, EPA would be prevented from pursuing the worst violators due to
the destruction or nonexistence of records.

	3(f)  Confidentiality

	Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, Part 2, Subpart B -
Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

	3(g)  Sensitive Questions

	None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents, SICS and NAICS Codes

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

Standard (40 CFR part 63, subpart NNNNN)	SIC Codes	NAICS Codes

Industrial Inorganic Chemicals, Nonvulcanizable Elastomer Compounds
(NEC) (except activated carbon and charcoal, alumina, recovering sulfur
from natural gas, and inorganic dyes).	2819	325188

Plastics Materials, Synthetic and Resins, and Nonvulcanizable Elastomers
	2821	325211

Industrial Organic Chemicals, NEC (except aliphatics, carbon bisulfide,
ethyl alcohol, cyclopropane, diethylcyclohexane, naphthalene sulfoni).
2869	325199



	4(b)  Information Requested

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

		(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NESHAP for Hydrochloric Acid Production (40 CFR part 63, subpart NNNNN).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Initial notification	63.9(b)(2) & (4), and 63.9045(b)-(c)

Notification of intent to conduct performance test	63.7(b)-(c),
63.8(f)(4) & (6), 63.9(b)-(h), and 63.9045(a)

Notification of compliance status	63.9(h)(2), and 63.9045(e)-(f)

First compliance report	63.10(a), and 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), and 63.9050(d)



	A source must make the following reports:

Recordkeeping 

Initial notification or notification of compliance status
63.10(b)(2)(xiv), and 63.9055(a)

Record of startup, shutdown, and malfunctions	63.6(e)(3), and
63.9055(b)(1)

Conduct performance tests 	63.10(b)(2)(viii), and 63.9055(a)(2)

Record of continuous parameter monitoring systems (CPMS) measurements 
63.10(b), and 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

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

	Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

		(ii)  Respondent Activities	

Respondent Activities

Read instructions.

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

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.

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

Transmit, or otherwise disclose the information.



	Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources still need
to evaluate the data, this type of monitoring equipment has
significantly reduced the burden associated with monitoring and
recordkeeping.

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

	5(a)  Agency Activities

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

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

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 AIRS Facility Subsystem (AFS).



	5(b)  Collection Methodology and Management

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

	Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS 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 AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA regional offices
and EPA headquarters.  EPA and its delegated Authorities can edit,
store, retrieve and analyze the data.

	The records required by this regulation must be retained by the
owner/operator for five years.

	5(c)  Small Entity Flexibility

	A majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these requirements the minimum
needed to ensure compliance and, therefore, cannot reduce them further
for small entities.  To the extent that larger businesses can use
economies of scale to reduce their burden, the overall burden will be
reduced.  According to the Economic Impact Analysis of the Hydrochloric
Acid Production NESHAP, 13 percent of the parent companies affected by
proposed action were estimated to be small entities as defined by the
Small Business Administration. The Agency assumes that 13 percent of the
75 facilities affected by this ICR, or 10 facilities, are small
entities.

	5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart
NNNNN) (Renewal).

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.  The Agency may not conduct
or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB Control Number.

	6(a)  Estimating Respondent Burden

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 94,104
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
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	$100.99 ($48.09 + 110%)

		Technical	$87.97   ($41.89 + 110%)

		Clerical	$43.81   ($20.86 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December, 2005, “Table 2. Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

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

	The types of industry costs associated with the information collection
activities in the subject standard are 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 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	75	$53,500	$8,473	71 (existing)
$601,583

CMS



$16,385	2 (new)	$32,770



The total capital/startup costs for this ICR are $53,500.  This is the
total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are
$634,353.

The total respondent costs have been calculated as the addition of the
capital/startup costs, and the annual operation and maintenance costs. 
The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $687,853.  

	6(c)  Estimating Agency Burden and Cost

	The only costs to the Agency are those costs associated with analysis
of the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $15,996.  This cost is based on the average hourly labor
rate as follows:

		Managerial	$57.20   (GS-13, Step 5, $35.75 x 1.6)

		Technical	$42.45   (GS-12, Step 1, $26.53 x 1.6)

		Clerical	$22.96   (GS-6, Step 3, $14.35 1.6)

These rates are from the Office of Personnel Management (OPM) “2006
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden - NESHAP for Hydrochloric Acid Production (40 CFR Part 63,
Subpart NNNNN) (Renewal).

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

	Based on our research for this ICR, on average over the next three
years, approximately 75 existing respondents will be subject to the
standard.  It is estimated that two additional respondent per year will
become subject.  The overall average number of respondents, as shown in
the table below is 75 per year.

	The number of respondents is calculated using the following table which
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	(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	71	0	0	73

2	2	73	0	0	75

3	2	75	0	0	77

Average	2	73	0	0	75



	To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 75.

 

	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	73	2	0	146

Subsequent performance test report	0	1	0	0

Startup, shutdown, malfunction report	2	10	0	20



	Total	174



	The number of Total Annual Responses is 174.

	6(e)  Bottom Line Burden Hours Burden 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 costs are $7,959,759.  Details regarding this
cost and the Total Hours Requested may be found below in Table 1: Annual
Respondent Burden and Cost - NESHAP for Hydrochloric Acid Production (40
CFR Part 63, Subpart NNNNN) (Renewal).  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 541 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $687,853.      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 the next three years is
estimated to be 386 labor hours at a cost of $15,996.  See below Table
2: Annual EPA Burden and Cost - NESHAP for Hydrochloric Acid Production
(40 CFR Part 63, Subpart NNNNN) (Renewal).

	

	6(f)  Reasons for Change in Burden

	There is no increase in burden hours from the most recently approved
ICR.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 541 hours per
response.  Burden means the total time, effort, or financial resources
expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency.  This includes the time
needed to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2008-0434. An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 

Constitution Ave., NW, Washington, DC.  The EPA Docket Center Public
Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday,
excluding legal holidays.  The telephone number for the Reading Room is
(202) 566-1744, and the telephone number for the Enforcement and
Compliance Docket and Information Center Docket is (202) 566-1752. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Office for EPA. Please include the
EPA Docket ID Number EPA-HQ-OECA-2008-0434 and OMB Control Number
2060-0529 in any correspondence.

Part B of the Supporting Statement

	This part is not applicable because no statistical methods were used in
collecting this information.



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

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $  b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting Requirements









   A.  Read instructions c	4	1	4	2	8	0.4	0.8	$779.13

   B.  Gather information c	4	1	4	2	8	0.4	0.8	$779.13

   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	$389.68

      Notification of intent to conduct               performance test 
2	1	2	2	4	0.2	0.4	$389.68

      Notification of compliance status c	19.5	1	19.5	2	39	1.95	3.9
$3,798.62

      First compliance report c, d	8.5	1	8.5	2	17	0.85	1.7	$1,655.81

      Semiannual compliance report e	4.5	2	9	73	657	32.85	65.7
$63,992.12

      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	$3,896.02

4.  Recordkeeping Requirements









    A.  Plan activities c, h	10	1	10	2	20	1	2	$1,948.01

    B.  Implement activities 









      Record startups, shutdown,                       malfunctions i	1
100	100	75	7,500	375	750	$720,763.70

      Conduct performance test	48.5	1	48.5	75	1,794.5	89.72	179.45
$174,766.74

      Record CPMS measurements j	1	365	365	75	27,010	1,350.5	2,701
$2,630,517.40

      CMPS calibration and maintenance k	3.9	50	195	75	14,430	721.5
1,443	$1,405,344.80

      Check for and repair leaks l	1	365	365	75	27,010	1,350.5	2,701
$2,630,517.40

    C.  Develop record system







 

      Startup, shutdown, malfunction plan c 	40	1	40	2	80	4	8	$7,791.24

      Site-specific monitoring plan c	20	1	20	2	40	2	4	$3,896.02

      Site-specific test plan c	20	1	20	2	40	2	4	$3,896.02

      Leak detection and repair plan c     	40	1	40	2	80	4	8	$7,791.24

    D.  Time to train personnel









      CPMS acquisition and installation c	20	1	20	2	40	2	4	$3,896.02

      CPMS inspection and monitoring c	4	1	4	2	8	0.4	0.8	$779.13

    E. Store, file, and maintain records m	20	1	20	75	1,500	75	150
$146,085.75

    F. Retrieve records/reports n	20	1	20	75	1,500	75	150	$146,085.75

Subtotals Labor Burden and cost  



	81,829.5	4,091.47	8.182.95	$7,959,759.41

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	94,104	$7,959,759



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 75.  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: $100.99 per hour for
Executive, Administrative, and Managerial labor; $87.97 per hour for
Technical labor, and $43.81 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2. Civilian Workers, by
Occupational

and Industry group.”  The rates are from column 1, “Total
Compensation.”  The rates have been increased by 110% to account for
the benefit packages available to those employed by private industry.

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

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

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

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

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

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

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

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

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

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

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

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

Table 2:  Average Annual EPA Burden - NESHAP for Hydrochloric Acid
Production (40 CFR Part 63, Subpart NNNNN) (Renewal)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

 per year	

(C)

EPA person

hours per

plant  per year

(C=AxB)	

(D)

Plants 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

   Review application for construction c	4	1	4	2	8	0.4	0.8	$380.85

   Review notification of intent to conduct    test d	4	1	4	2	8	0.4	0.8
$380.85

   Review notification of compliance           status c	20	1	20	2	40	2	4
$1,904.24

   Review compliance report e	20	2	40	2	80	4	8	$3,808.48

   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
$7,616.96

   Attend performance test	20	1	20	2	40	2	4	$1,904.24

Subtotals Labor Burden and cost



	336	16.8	33.6	$15,995.62

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	386

	$15,996





Assumptions:

    a  We have assumed that the average number of respondents that will
be subject to the rule will be 75.  There will be two additional new
sources per year that will become      subject to the rule over the
three-year period of this ICR. 

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $57.20 (GS-13, Step 5, $35.75 x 1.6),
Technical rate of $42.45 (GS-12, Step 1, $26.53 x 1.6), and Clerical
rate of $22.96 (GS-6, Step 3, $14.35 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2006 General Schedule” which
excludes locality rates of pay.

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

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

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

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

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

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

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