FR 2025-03345

The Environmental Protection Agency (EPA) is inviting public comments on a proposal to extend the Information Collection Request (ICR) related to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Hydrochloric Acid Production. This measure targets facilities that emit substantial levels of pollutants such as hydrochloric acid and chlorine. As part of regulatory compliance, these facilities must follow specific procedures to report emissions, conduct performance tests, and maintain records.

General Summary

This notice, published by the EPA, solicits public input on extending an existing information collection initiative aimed at ensuring hydrochloric acid production facilities comply with national air quality standards. The deadline for public comments is March 31, 2025. The EPA projects that the annual compliance process will demand approximately 21,900 hours of effort and incur costs totaling around $2,980,000. This includes operating expenses and the costs of ensuring pollution control measures are effectively implemented.

Significant Issues and Concerns

There are several notable issues within the document that warrant attention:

• Cost Details: The document does not thoroughly explain how the estimated annual cost of $2,980,000 is distributed across various activities. This lack of transparency might lead to concerns about potential inefficiencies or misallocation of resources.

• Complex Language: The document is laden with technical jargon related to regulatory compliance standards (e.g., "40 CFR part 63, subpart NNNNN"), which might prove challenging for individuals without a legal or environmental background to understand.

• Unclear Adjustments: References to cost increases due to a "CEPCI adjustment" do not clarify what CEPCI represents or its implications, potentially confusing readers.

• Respondent Details: Although the estimated number of affected entities is provided (19 in total), the document does not specify their identities or the scale of their operations. This omission creates uncertainty about whether smaller businesses could face disproportionate financial burdens.

Impact on the Public

For the general public, this document underscores the ongoing efforts by the EPA to regulate air emissions and enhance air quality. Its ultimate goal is environmental protection and public health improvement. Nevertheless, the document's complexity might restrict public participation in the comments process, given the potentially limited comprehension of the technical language and cost structures presented.

Impact on Specific Stakeholders

For companies within the hydrochloric acid production industry, compliance with these regulations is mandatory. The renewal of the ICR involves continued obligations related to reporting and monitoring, which could pressure smaller facilities both financially and operationally. However, by maintaining established pollution control standards, these facilities contribute to better air quality, benefiting communities near production sites.

In summary, while the EPA's notice demonstrates a commitment to environmental compliance, clearer communication might enhance understanding and broader public engagement. Including specific respondent details and elucidating cost adjustments could also help stakeholders better comprehend their roles and potential impacts associated with the proposed extension.

In this document, the Environmental Protection Agency (EPA) details an information collection request related to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Hydrochloric Acid Production. The financial elements of the document provide an overview of the costs associated with compliance and data collection.

Summary of Financial Allocations

The document specifies a total estimated cost of $2,980,000 per year, which is associated with the implementation and compliance of the NESHAP for Hydrochloric Acid Production. This figure includes $216,000 earmarked for annualized capital or operation and maintenance costs. These costs are expected to cover activities such as initial notifications, performance tests, and the submission of periodic reports by the affected facilities.

Relating Financial Allocations to Identified Issues

A notable issue within the financial references is the lack of a detailed breakdown of the total estimated costs. Without a clear allocation, it is difficult to determine if the spending includes potential inefficiencies or areas where financial resources might not be optimally used. Stakeholders, especially smaller entities among the 19 affected respondents, may face challenges in understanding how these costs translate into specific compliance activities.

Furthermore, the document states a slight increase in costs attributed to a "CEPCI adjustment," which is not explained. This could lead to confusion among entities trying to understand the specifics of cost fluctuations or budgeting needs. Clarity regarding such financial adjustments would facilitate a better comprehension of ongoing financial commitments.

Lastly, while the document mentions 19 respondents, it does not specify who they are. This omission raises concerns about whether the costs and the compliance requirements might disproportionately affect smaller entities. A clear delineation of the types of respondents could provide more insight into whether smaller producers disproportionately bear the financial burden of compliance.

In conclusion, while the document provides an overview of the expected costs, more detailed information regarding the allocation and impact of these expenditures would be beneficial for stakeholders, particularly those with limited resources to absorb compliance costs.