Form 5900-598 63.9050(l) Compliance Report

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	480
Number of Respondents	19
Total Estimated Burden Hours	21,900
Total Estimated Costs	$2,980,000
Annualized Capital O&M	$216,000
Form Number	5900-598

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Sheet 2: Table 1

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
										Labor Rates
1. Applications	N/A									Management	$163.17
2. Survey and Studies	N/A									Technical	$130.28
3. Reporting Requirements										Clerical	$65.71
A. Familiarize with rule requirements c	4	1	4	19	76	3.8	7.6	$11,020.72
B. Gather information c	4	1	4	0	0	0	0	$0
C. Write reports
Initial notification c	2	1	2	0	0	0	0	$0
Application for construction c	2	1	2	0	0	0	0	$0
Notification of intent to conduct performance test	2	1	2	3.8	7.6	0.38	0.76	$1,102.07
Notification of compliance status c	19.5	1	19.5	0	0	0	0	$0
First compliance report c, d	8.5	1	8.5	0	0	0	0	$0
Semiannual compliance report e	4.5	2	9	19	171	8.55	17.1	$24,796.62
Subsequent performance test reports f	4	1	4	3.8	15.2	0.76	1.52	$2,204
Startup, shutdown, malfunction report g	2	10	20	0	0	0	0	$0
Subtotal for Reporting Requirements					310			$39,124
4. Recordkeeping Requirements
A. Plan activities c, h	10	1	10	0	0	0	0	$0.00
B. Implement activities
Record startups, shutdown, malfunctions i	1	10	10	19	190	9.5	19	$27,551.81
Conduct performance test	48.5	1	48.5	3.8	184.3	9.22	18.43	$26,725.25
Record CPMS measurements j	1	365	365	19	6,935	346.75	693.5	$1,005,640.88
CMPS calibration and maintenance k	3.9	50	195	19	3,705	185.25	370.5	$537,260.20
Check for and repair leaks l	1	365	365	19	6,935	346.75	693.5	$1,005,640.88
C. Develop record system
Startup, shutdown, malfunction plan c	40	1	40	0	0	0	0	$0
Site-specific monitoring plan c	20	1	20	0	0	0	0	$0
Site-specific test plan c	20	1	20	0	0	0	0	$0
Leak detection and repair plan c	40	1	40	0	0	0	0	$0
Record maintenance activities m	1	4	4	19	76	3.8	7.6	$11,020.72
D. Time to train personnel			0			0	0	$0
CPMS acquisition and installation c	20	1	20	0	0	0	0	$0
CPMS inspection and monitoring c	4	1	4	0	0	0	0	$0
E. Store, file, and maintain records m	20	1	20	19	380	19	38	$55,103.61
F. Retrieve records/reports o	20	1	20	19	380	19	38	$55,103.61
Subtotal for Recordkeeping Requirements					21,603			$2,724,047
TOTAL LABOR BURDEN AND COST (rounded)					21,900			$2,760,000		480	hr/response
Capital and O&M Costp								$216,000
Grand TOTALp								$2,980,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 19. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c This is a one-time only activity for each facility and only sources that started up prior to April 17, 2003 are required to submit initial notification.
d We have assumed that no 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 approximately 4 facilities will take 4 hours to perform tests after the initial compliance determination , by either bringing 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 10 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 CPMS calibration and maintenance activities 50 times per year.
l We have assumed that respondents are required to check for and repair leaks 365 times per-year.
m We have assumed respondents will average 4 maintenance activities per year based on comments submitted by industry. See EPA-HQ-OAR-2018-0417-0134 at pages 19-20.
n We have assumed that each respondent will take 20 hours once per-year to store, file and maintain records.
o We have assumed that it will take respondent 20 hours to retrieve records/reports once per-year.
p Totals have been rounded to 3 significant figures. Figures may not round exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart 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		Labor Rates
Review application for construction c	4	1	4	0	0	0	0	$0		Management	$73.46
Review notification of intent to conduct test d	4	1	4	3.8	15.2	0.76	1.52	$929		Technical	$54.51
Review notification of compliance status c	20	1	20	0	0	0	0	$0		Clerical	$29.50
Review first compliance report e	20	1	20	0	0	0	0	$0
Review semiannual compliance report e	20	2	40	19	760	38	76	$46,461
Review subsequent performance test report f	10	1	10	0	0	0	0	$0
Review startup, shutdown, malfunction report g	8	10	80	0	0	0	0	$0
Attend performance test	20	1	20	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded) h					891			$47,400
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 19. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR.
b The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $73.456 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.512 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.504 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c This is a one-time only activity for each facility and 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 it will take each respondent 20 hours to review compliance reports.
f We have assumed that no facilities will perform tests after the initial compliance determination.
g We have assumed that it will take each new respondents eight hours to review the SSM report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent a	Number of New Respondents b	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent a	Number of Respondents with O&M b	Total O&M, (E X F)		2019 CEPCI CE Index	607.5
Continuous monitoring systems (CMS)	$956	0	$0	$11,381	19 (existing)	$216,239		2022 CEPCI CE Index	816
	N/A	N/A	N/A	$22,008	0 (new)	$0
Totals (rounded) c			$0			$216,000		$216,000
a Capital/startup costs and O&M costs have been updated from 2019 dollars to 2022 dollars using the CEPCI CE Index. [2019 CEPCI = 607.5; 2022 CEPCI = 816]
b We have assumed that the average number of respondents that will be subject to the rule will be 19. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial notification	0	1	0	0
Application for construction	0	1	0	0
Notification of 5-year performance test/retest	3.8	1	0	3.8
Notification of compliance status	0	1	0	0
First compliance report	0	1	0	0
Semiannual compliance reports	19	2	0	38
Subsequent performance test report	3.8	1	0	3.8
Startup, shutdown, malfunction report	0	10	0	0
			Total	46
a We assume 3.8 respondents per year are re-testing based on each respondent conducting a performance test on a 5-year basis with their renewal.

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	19	0	0	19
2	0	19	0	0	19
3	0	19	0	0	19
Average	0	19	0	0	19
a New respondents include sources with constructed and reconstructed affected facilities.