2028ss03 (7)

15

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Industrial, Commercial and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Industrial, Commercial and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)

1(b) Short Characterization/Abstract

The NESHAP regulations published at 40 CFR part 63, subpart DDDDD were proposed on January 13, 2003, and promulgated on December 6, 2006. This regulation applies to new, reconstructed, or existing industrial, commercial and institutional boilers and process heaters that are a major source of hazardous air pollutants (HAP) emissions. A major source of HAP emissions is any stationary source or group of stationary sources located within a contiguous area and under common control 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.

In general, all NESHAP standards require initial notifications, performance tests, and periodic reports. Owners or operators 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. The information collection activities also includes, initial and annual stack tests, fuel analyses, and operating parameter monitoring. There are varying levels of requirements that apply to each subcategory. The Boilers NESHAP contains nine subcategories: large solid fuel-fired units, large liquid fuel-fired units, large gaseous fuel-fired units, limited use solid fuel-fired units, limited use liquid fuel-fired units, limited use gaseous fuel-fired units, small solid fuel-fired units, small liquid fuel-fired units, and small gaseous fuel-fired units. An industrial, commercial, or institutional boiler is an enclosed device using controlled flame combustion and having the primary purpose of recovering thermal energy in the form of steam or hot water. A process heater is an enclosed device using controlled flame with the unit’s primary purpose being to transfer heat indirectly to process steams (liquids, gases, or solids) instead of generating steam. This information is being collected to assure compliance with part 63, subpart DDDDD.

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

Over the next three years the number of respondents subject to the standard is estimated to be 2,625, with an additional increase of 289 new sources per year over the next three years of this ICR.

There are approximately 2,625 boilers and process heaters facilities in the United States, which are all publicly owned and operated by the industrial, commercial, and institutional boilers and process heaters industry. None of these facilities in the United States are owned by either state, local, tribal or the Federal Government, they are all owned and operated solely by privately owned for-profit businesses. You can find the burden to the “Affected Public” listed below in Table 1: Annual Industry Burden and Cost - NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD). The Federal Government burden does not include work performed by federal employees only work performed by contractors, which could be found listed below in Table 2: Average Annual EPA Burden - NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD).

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 standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants (HAP). These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner or 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 industrial, commercial, and institutional boilers and process heaters cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 63, subpart DDDDD.

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 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 tests 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 the standard 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. Nonduplication, Consultations, and Other Collection Criteria

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

3(a) Nonduplication

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 their 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 (71FR 58853) on October 5, 2006. No comments were received on the burden published in the Federal Register.

3(c) Consultations

Over the next three years, an average of 2,625 facilities per year will be subject to the standard, with an additional 289 new sources per year becoming subject to the standard. We have also determined that approximately 10 percent of the respondents are reporting electronically. In estimating the affected number of sources and the growth rate of industrial, commercial, and institutional boilers and process heaters facilities subject to this standard, EPA contacted Mr. Robert Bessette, at (703) 250-9042, from the Council of Industrial Boiler Owners Association (CIBO), Ms. Rhea Hale, at (202) 463-2709, from the American Forest and Paper, and Mr. Randy Rawson, at (703) 356-7172 from the American Boiler Manufacturers Association. We referenced the most recent ICR, consulted with the preparer of the active ICR, and used other resources to obtain the most recent data available. We reviewed information available from the Online Tracking Information System (OTIS) which is the primary source of information regarding the number of existing sources. OTIS data was used in conjunction with industry consultation to verify the number of sources and the industry growth rate. We also consulted with EPA’s Office of Air Quality Planning and Standards, Information Transfer and Program Integration Division.

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 likely.

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. 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 that the most flagrant violators have violations extending beyond the 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 (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/SIC Codes

The respondents to the recordkeeping and reporting requirements are industrial, commercial, and institutional boilers and process heaters. The United States Standard Industrial Classification (SIC) codes which correspond to the North American Industry Classification System (NAICS) code could be found in the following table:

40 CFR part 63, subpart DDDDD	SIC Codes	NAICS Codes
Crude Petroleum and Natural Gas Extraction	1311	211111
Manufacturers of Lumber and Wood Products	2421	321999
Pulp and Paper Mills	2611	322121
Chemical Manufacturers	2819	325188
Petroleum Refineries, and Manufacturers of Coal Products	2999	324199
Manufacturers of Rubber and Miscellaneous Plastic Products	3021	316211
	3052	326220
	3053	339991
Steel Works, Blast Furnaces	3312	331111
Electroplating, Plating, Polishing, Anodizing, and Coloring	3471	332813
Manufacturers of Motor Vehicle Parts and Accessories.	3714	336399
Electric, Gas, and Sanitary services	4931	221122
Health Services	8062	622110
Educational Services	8299	611710

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

In this ICR, all the data recorded or reported is required by National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, Institutional Boilers, and Process Heaters (40 CFR Part 63, Subpart DDDDD).

A source must make the following reports:

Notifications
Initial notification for existing sources	63.9(b)(2), 63.7545(b)
Notification of intent to construct	63.9(b)
Notification of start of construction	63.9(b)
Notification of anticipated startup date	63.9(b)
Notification of actual startup date	63.9(b)
Notification of compliance status	63.9(h), 63.7545(e)
Notification of performance test	63.9(e), 63.7545(d)

Reports
Semiannual compliance report	63.7550
Startup, shutdown, and malfunction plan	63.10(d)(5)(i), 63.7505(e)
Site-specific compliance monitoring plan	63.7505(c)
Site-specific fuel analysis plan	63.7521(b)

A source must keep the following records:

Recordkeeping
Documentation supporting any initial notification or notification of compliance status or semiannual compliance report	63.7555(a)(1)
Startup, shutdown, malfunction plan	63.6(e)(3)(iii)-(v), 63.7555(a)(2)
Records of performance tests or other compliance demonstrations, performance evaluations, and opacity observations	63.10(b)(2)(viii), 63.7555(a)(3)
Records for continuous emissions monitoring systems, continuous parameter monitoring systems, and opacity observations	63.10(b)(2)(vi) –(xi), 63.7555(b)(1)
Records of operating limits	63.7555(c)-(d)
Records of fuel use and hours of operation	63.7555(d)
Maintain records for 5 years	63.10(b)(1), 63.7560(b)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a 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.

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply pressure for control device.

Perform initial performance test, Reference Method 5, 17, 19, 26 26A and 29 tests, and repeat performance tests if necessary.

Write the notification 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 monitoring equipment that provides parameter data in an automated way e.g., continuous parameter monitoring system. Although personnel at the source 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, excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

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 operational. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved. Data and records 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.

Information contained in the reports is entered into OTIS which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses OTIS 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 or operator for five years.

5(c) Small Entity Flexibility

The 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 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 use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in Table 1: Annual Industry Burden for NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD).

6. Estimating the Burden and Cost of the Collection

Table 1 document 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. Wherever 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 513,995 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents 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

Managerial $105.86 ($50.41 + 110%)

Technical $92.61 ($44.10 + 110%)

Clerical $45.32 ($21.58 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2006, “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.

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

New respondents have capital costs associated with the purchase of the equipment necessary for compliance, as well as operation and maintenance (O&M) costs associated with the installed equipment. Existing respondents do not have capital/startup costs because the equipment is in place, however, they do have annual O&M costs. Annual O&M costs are the ongoing costs to maintain the monitor and include miscellaneous expenses 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)
Opacity monitors	$29,200	145	$4,234,000	$800	2,336	$1,868,800
CO monitoring	$37,800	145	$5,481,000	$2,500	2,336	$5,840,000
Bag leak detection	$20,000	17	$340,000	$4,000	2,336	$9,344,000
Parametric Monitoring	$5,000	145	$725,000	$500	2,336	$1,168,000
Totals			$10,780,000			$18,220,800

The total capital/startup costs to new respondents for this ICR are $10,780,000. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for all continuous monitoring devices is $18,220,800. This is the total of column G.

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 $29,000,800.

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 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 $4,059,365.

This cost is based on the average hourly labor rate as follows:

Managerial $58.18 (GS-13, Step 5, $36.36 + 60%)

Technical $43.17 (GS-12, Step 1, $26.98 + 60%)

Clerical $23.36 (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) A2007 General Schedule@ which excludes locality rates of pay. The rates have been increased by 60% to account for the benefit packages available to government employees. Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden, NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD), below.

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 2,625 existing respondents will be subject to the standard. It is estimated that an additional four respondents per year will become subject. The overall average number of respondents, as shown in the table below is 2,625 per year.

The number of respondents is calculated using the following table which addresses the three years covered by this ICR.

Number of Respondents
Subgroup Description	Existing	New	Annual Average Over Three yeas
Large Solid Fuel	1,756	15	1,771
Large Liquid Fuel	28	7	35
Large Gaseous Fuel	352	88	440
Limited Use Solid Fuel	64	1	65
Limited Use Liquid Fuel	16	4	20
Limited Use Gaseous Fuel	64	16	80
Small Solid Fuel	8	2	10
Small Liquid Fuel	48	12	60
Small Gaseous Fuel	0	144 1	144 1
Totals	2,336	289	2,625

¹ Only initial reports are submitted. There are no on-going recordkeeping and reporting activities.

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 2,625.

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
Notification of construction/siting analysis	145	1	0	145
Initial startup report	289	1	0	289
Initial notification that sources are subject	289	1	0	289
Notification of initial stack test	145	1	0	145
Notification of compliance status	289	1	0	289
Startup, shutdown, malfunction plan	145	1	0	145
Semiannual compliance report	2,336	2	0	4,672
			Total	5,974

The number of Total Annual Responses is 5,974.

The total annual labor costs are $45,783,461. Details regarding these estimates may be found in Table 1: Annual Industry Burden and Cost - NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD).

6(e) Bottom Line Burden Hours 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 costs are $45,783,461. Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost: NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD), below. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 86 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $29,000,800. 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 96,426 labor hours at a cost of $4,059,365. See Table 2. Annual Agency Burden and Cost: NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD), below.

6(f) Reasons for Change in Burden

The number of respondents subject to the standard is estimated to be 2,625. The number in the previous ICR was 18,788. During the initial compliance period a large number of facilities were required to determine whether they were subject to the standard. Most were not subject and no additional reporting is required, therefore, a large reduction in the number of affected facilities occurred. There is an adjustment decrease of 636,250 hours in the total estimated burden hours as currently identified in the OMB Inventory of Approved ICR Burdens. This decrease is not due to any program changes. The change in the burden has occurred because the initial performance tests and the initial reports for existing sources have been completed and submitted to the Agency. The relatively small number of new sources causes a small increase in burden hours. However, the net overall effect is a decrease in the number of burden hours.

There is an increase in the capital/startup and operation and maintenance (O&M) cost compared to the previous ICR. The reason for this increase is due to the fact that this renewal ICR incurred O&M costs as compared with the active ICR that included primarily capital/startup costs. There is also an increase of 289 additional new sources per year over the next three years of this ICR. The net effect is an increase in cost to the subject facilities.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 86 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-2006-0778. 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 content of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search” than 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., N.W., 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) 566-1927. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2006-0778 and OMB Control Number 2060-0551 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 Industrial, Commercial and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD)
		(A)	(B)	(C)	(D)	(E)	(F)		(G)		(H)
Burden item	Notes	Person- hours per occurrence	No. of occurrences per respondent per year	Person- hours per respondent per year (C=AxB)	Respondents per year (a)	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)		Clerical person- hours per year (Ex0.1)		Cost, $ (b)
1. Applications		N/A
2. Survey and Studies		N/A
3. Reporting requirements
A. Read instructions	c	40	1	40	289	11,560	578		1,156		$ 1,184,147
B. Required activities
Initial stack test and report (new sources)	e	24	2	48	145	6,960	348		696		$ 712,947
Annual stack test and report (existing sources)	f	24	1	24	2,336	56,064	2,803		5,606		$ 5,742,907
Continuous parameter monitoring
Establish site-specific monitoring plan	g	40	1	40	145	5,800	290		580		$ 594,122
Opacity Monitoring
Large solid fuel units	d, h	10	1	10	1,771	17,710	886		1,771		$ 1,814,121
Limited use solid fuel	d, h	10	1	10	65	650	33		65		$ 66,583
Small solid fuel	d, h	10	1	10	10	100	5		10		$ 10,243
Large liquid fuel	d, h	10	1	10	35	350	18		35		$ 35,852
Limited use liquid fuel	d, h	10	1	10	20	200	10		20		$ 20,487
Small liquid fuel	d, h	10	1	10	60	600	30		60		$ 61,461
CO Monitoring	d, h	10	1	10	2,336	23,360	1,168		2,336		$ 2,392,878
Control device parameters	d, h	10	1	10	2,336	23,360	1,168		2,336		$ 2,392,878
C. Subsequent fuel analysis and calculations for metals, mercury or chlorine (new only)	i	8	2	16	145	2,320	116		232		$ 237,649
D. Create information		N/A
E. Gather information		N/A
F. Write Report
Report prior to construction/siting analysis	j	25	1	25	145	3,625	181		363		$ 371,326
Report prior to initial startup	k	10	1	10	289	2,890	145		289		$ 296,037
Initial notification that sources are subject	l	2	1	2	289	578	29		58		$ 59,207
Notification of initial stack test	m	8	1	8	145	1,160	58		116		$ 118,824
Report of initial stack test	n	8	1	8	145	1,160	58		116		$ 118,824
Report established values for site-specific operating parameters		10	1	10	145	1,450	73		145		$ 148,531
Notification of compliance status		40	1	40	145	5,800	290		580		$ 594,122
Startup, shutdown, malfunction plan		40	1	40	145	5,800	290		580		$ 594,122
Semiannual compliance report which includes:
Site-specific operating parameters		See Below
Emissions/parameters exceedances and malfunctions		See Below
Results of annual performance tests		See Below
Semiannual compliance report	o	24	2	48	2,336	112,128	5,606		11,213		$ 11,485,815
Subtotal						283,625	14,181		28,363		$ 29,053,084
A. Recordkeeping requirements
Read instructions		N/A
Implement Activities		N/A
Develop record system		N/A
Record information
Records of operating parameters	p	20	1	20	2,336	46,720	2,336		4,672		$ 4,785,756
Records of operating parameters (new sources)	p	5	1	5	145	725	36		73		$ 74,265
Records of CO monitoring	p	5	1	5	2,336	11,680	584		1,168		$ 1,196,439
Records of daily fuel use	p	20	1	20	2,336	46,720	2,336		4,672		$ 4,785,756
Records of monitoring device calibrations	p	3	1	3	2,336	7,008	350		701		$ 717,863
Records of startup, shutdown, malfunction	p	15	1	15	2,336	35,040	1,752		3,504		$ 3,589,317
Records of stack tests	p	2	1	2	2,481	4,962	248		496		$ 508,282
Records of all compliance reports submitted	p	2	1	2	2,336	4,672	234		467		$ 478,576
B. Personnel training	q	40	1	40	145	5,800	290		580		$ 594,122
C. Time for audits		N/A
Subtotals Labor Burden						163,327	8,166		16,333		$ 16,730,377
TOTAL ANNUAL BURDEN AND COST (rounded)						513,995					$ 45,783,461
Notes:
a. We have assumed that the average number of respondents that will be subject to the rule will be 2,625. This consists of 2,336 existing respondents per year. However, only 145 are subject to reporting AHa the initial compliance report.
b. This ICR uses the following labor rates: $105.86 per hour for Executive, Administrative, and Managerial labor; $92.61 per hour for Technical labor, and $45.32 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2006, "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.
c. We have assumed that it will take 40 hours for each source to read the rule.
d. We have assumed that it will take 10 hours for each source to read the rule.
e. We have assumed that each subject facility will take 24 hours to complete the initial stack test and report.
f. We have assumed that each new unit will take 24 hours to conduct a stack test.
g. We have assumed that each source will take 40 hours to establish their site-specific monitoring plan.
h. We have assumed that each subject facility will be engaged in monitoring opacity.
i. We have assumed that each new source will take 8 hours to set fuel input operating limits.
j. We have assumed that each new source will take 25 hours to complete the siting analysis report.
k. We have assumed that each new source will take 10 hours to complete the report prior to initial startup.
l. We have assumed that each source will take 2 hours to complete the initial notification report making sure that all sources are subject to the rule.
m. We have assumed that it will take each source 8 hours to complete the notification of the initial stack test.
n. We have assumed that each new source will take 20 hours to complete the semiannual compliance report.
o. It will take approximately 24 hours to completed each semiannual report.
p. Recordkeeping ranges from 2 to 20 hours for each listed activity.
q. It is estimated to take 40 hours to train personnel.

Table 2: Annual Agency Burden and Cost: NESHAP for Industrial, Commercial and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD)
		(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
Activity	Notes	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person hours per plant per year (C=AxB)	Plants per year (a)	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person- hours per year (Ex0.1)	Cost, $ (b)
A. Read instructions	c	40	1	40	50	2,000	100	200	$ 96,826
B. Enter and update information into agency recordkeeping system	d	4	1	4	289	1,156	58	116	$ 55,965
C. Required activities for sources with add-on control devices
Review notification for new major sources		2	1	2	145	290	15	29	$ 14,040
Notification of intent to construct and application to construct.	f	5	1	5	145	725	36	73	$ 35,099
Start of construction	g	2	1	2	145	290	15	29	$ 14,040
Anticipated startup date	g	2	1	2	145	290	15	29	$ 14,040
Actual startup date	g	2	1	2	145	290	15	29	$ 14,040
Review request for compliance extension		n/a
Review special compliance requirements		n/a
Review initial performance test and test plan	h	20	1	20	145	2,900	145	290	$ 140,397
E. Review compliance status	i	4	1	4	289	1,156	58	116	$ 55,965
F. Area sources not subject to the standard		n/a
G. Review waiver application		n/a
D. Reporting requirements
Semiannual compliance reports for all Sources	j	4	2	8	2,336	18,688	934	1,869	$ 904,738
Review additional reports		n/a
Control device performance test report and operating range	k	20	1	20	2,336	46,720	2,336	4,672	$ 2,261,846
Review startup, shutdown malfunction reports	l	4	1	4	2,336	9,344	467	934	$ 452,369
TOTAL ANNUAL BURDEN AND COST (rounded)						83,849	4,192	8,385	$ 4,059,365
						96,426
Assumptions:
a. We have assumed that the average number of respondents that will be subject to the rule will be 19,938. There will be an additional 575 new sources 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 rates of $58.18 (GS-13, Step 5, $36.36 x 1.6), Technical rate of $43.17 (GS-12, Step 1, $26.96 x 1.6), and Clerical rate of $23.36 (GS-6, Step 3, $14.60 x 1.6). These rates are from the Office of Personnel Management (OPM) "2007 General Schedule" which excludes locality rates of pay.
c. We have assumed that the number of sources per year are the number of states where affected sources will exist (all 50 states).
d. We have assumed that plants per year is based on the total number of affected and existing sources.
e. We have assumed that each new source will take two hours to review initial notification.
f. We have assumed that it will take each new source five hours to review notifications.
g. We have assumed that it will take each new source two hours each to review notifications.
h. We have assumed that it will take each new source 20 hours to review initial performance tests and test plan.
i. We have assumed that it will take each new source four hours to review the compliance status report.
j. We have assumed that each source will take 4 hours to review compliance report.
k. We have assumed that each source will take 20 hours to review the control device performance test report and operating range.
l. We have assumed that each source will take four hours to review the startup, shutdown, malfunction reports.