SUPPORTING STATEMENT
FOR 
INFORMATION COLLECTION EFFORT FOR FACILITIES WITH COMBUSTION UNITS

Sector Policies and Programs Division
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 31711

PART A OF THE SUPPORTING STATEMENT 
INFORMATION COLLECTION EFFORT FOR FACILITIES WITH COMBUSTION UNITS
1.	Identification of the Information Collection
(a)	Title of the Information Collection 
“Information Collection Effort for Facilities with Combustion Units.” This is the second phase of the existing approved ICR (ICR number 2286.01, OMB Control Number 2060-0616. The ICR number for the second phase is 2286.02.
(b)	Short Characterization 
This information collection is being conducted by EPA’s Office of Air and Radiation (OAR) pursuant to section 114 of the Clean Air Act, as amended (“CAA” or “the Act”), to assist the Administrator of EPA in developing emissions standards for boilers/process heaters and commercial and industrial solid waste incineration units (collectively, “combustion units”) pursuant to sections 112(d) and 129 of the Act.  Section 114(a) states, in pertinent part:
For the purpose...(iii) carrying out any provision of this Chapter...(1) the Administrator may require any person who owns or operates any emission source...to-. . .(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.. .(G) provide such other information as the Administrator may reasonably require...

This information would also be made available to the public.
 	
This is the second component of the information collection. The first component of this ICR was approved by OMB on August 1, 2008 and the collection of survey data is complete. 
The second component will consist of requiring, if deemed necessary, the owners/operators of up to a total of 310 combustion units to conduct emission testing for hazardous air pollutants (HAP) and HAP surrogates, as well as pollutants identified in section 129(a)(4).  The Agency has analyzed the results of the survey to determine if sufficient data exist to develop emission standards under sections 112(d) and 129 of the Act for all types of combustor units and all types of materials combusted and these tests are requested from units where the Agency has identified data gaps. The Agency has submitted to stakeholders a preliminary list of candidates testing sites and it has received initial comments on the appropriateness and feasibility of testing the selected sites. Appendix 1 and 2 to Part B of the Supporting Statement provide a revised list of units to be tested. 
The sites selected will conduct an outlet stack test in accordance with EPA-approved protocols, for any or all of the following pollutants: 

•	If you operate a boiler or process heater, the test plan asks for an emission test for all or only a portion of the following pollutants: Carbon monoxide (CO), total hydrocarbons (THC), formaldehyde, dioxins/furans (D/F), hydrogen chloride (HCl), hydrogen fluoride (HF), mercury (Hg), metals (antimony (Sb), arsenic (As), beryllium (Be), cadmium (Cd), chromium (Cr), cobalt (Co), lead (Pb), manganese (Mn), nickel (Ni), phosphorus (P) and selenium (Se)), particulate matter (PM10, PM2.5, and condensible particulate), oxides of nitrogen (NOx), and sulfur dioxide (SO2).  Refer to the test plan for your particular combustion unit to see which pollutants you are performing a test for.  

•	If you operate a CISWI unit, you must perform an emission test for all or only a portion of the following pollutants:  CO, Hg, D/F, HCl, HF, Sb, As, Be, Cd, Cr, Co, Pb, Mn, Ni, P, Se, NOx, PM10, PM2.5, condensible PM and SO2.  You may have submitted test data for some of these pollutants already.  Refer to the test plan for your particular combustion unit to see which pollutants you are performing a test for.
The number and types of stack tests or CEM data collection activities required at each test site depends on the types of data gaps identified for each subcategory. The testing will consist of three runs at each sampling location, and is to be in accordance with a specified testing method.  The owner/operator of each selected combustion unit will also be required to collect and analyze, in accordance with an acceptable procedure, a statistically appropriate number of samples for analysis from the material(s) fed to the combustion unit during each stack test.  The results of the stack tests and the analyses of materials combusted will be required to be submitted to the Agency. In addition to outlet stack testing, 139 boilers and process heaters were selected for 10-sample fuel variability analysis for mercury, chlorine, fluorine, and select metallic HAP. Further, eight of the best performing boilers and process heaters were selected to continuously monitor emissions of CO and THC for a 30 day period.
The total one-time reporting and recordkeeping burden for the stack testing component of the data gathering effort is estimated to be no more than 26,025 hours and $18,748,554 total over the three years. 
The owner/operator of each selected combustion unit required to conduct stack testing and concurrent sampling and analysis of materials combusted will be required to keep records: i) documenting that material samples taken during each stack test run were obtained in accordance with an approved sampling protocol; ii) establishing proper chain of custody for each material sample; iii) describing the QA/QC procedures followed in preparing each material sample for analysis and performing the required analysis; iv) setting forth the results of the analyses performed on each material sample; v) documenting that each stack test, analysis, or monitoring activity was conducted in accordance with an approved testing protocol; vi) describing the QA/QC procedures followed in preparing for each stack test, analysis, or monitoring activity; and, vii) setting forth the results of each stack test, analysis, or monitoring activity.

2.	Need for and Use of the Collection 
(a)	Need/Authority for the Collection 
Industrial, commercial, and institutional boilers and process heaters were listed as a major source category of HAP on July 16, 1992 (57 FR 31576).  Major sources of HAP are those that have the potential to emit greater than 10 ton per year (tpy) of any one HAP or 25 tpy of any combination of HAP. 
Section 112(c)(2) of the Act requires that we establish a National Emission Standard for Hazardous Air Pollutants (NESHAP) for control of HAP from both existing and new major sources, based upon the criteria set out in the Act section 112(d).  The Act requires the NESHAP to reflect the maximum degree of reduction in emissions of HAP that is achievable, taking into consideration the cost of achieving the emission reduction, any non-air quality health and environmental impacts, and energy requirements.  This level of control is commonly referred to as the MACT.  The minimum control level allowed for NESHAP (the minimum level of stringency for MACT) is the ‘‘MACT floor,’’ as defined under section 112(d)(3) of the CAA.  The MACT floor for existing sources is the emission limitation achieved by the average of the best-performing 12 percent of existing sources for categories and subcategories with 30 or more sources, or the average of the best-performing five sources for categories or subcategories with fewer than 30 sources.  For new sources, the MACT floor cannot be less stringent than the emission control achieved in practice by the best-controlled similar source.
Section 129(a) of the Act requires EPA to promulgate emissions standards and other requirements for “each category of solid waste incineration units[,]” including “units combusting commercial and industrial waste.”   For each category, EPA must establish numerical emission limits for at least nine specified pollutants, and must set MACT-type standards for the category.  See sections 129(a)(2) and (a)(4).
A NESHAP for boilers and process heaters was promulgated at 40 CFR Part 63 Subpart DDDDD on September 2004 (see 69 FR 55218).  Emissions standards for CISWI units were promulgated at 40 CFR Part 60 Subpart CCCC on December 1, 2000 (see 65 FR 75338).  Separately, EPA promulgated a rule revising the definition of “commercial and industrial solid waste.”  (70 FR 55568).  The CISWI standards were remanded to EPA by the D.C. Circuit Court of Appeals, which granted EPA’s motion for voluntary remand of the standards on September 6, 2001.  Sierra Club V. EPA, No. 01-1048.  The boiler/process heater NESHAP was vacated by the D.C. Circuit Court of Appeals on June 8, 2007. NRDC V. EPA, 489 F.3d. 1250 (D.C. Cir. 2007).  The NRDC court remanded the NESHAP to EPA, requiring the Agency to revise the 2004 boiler standard and the associated MACT floors.  In the same decision, the court also vacated and remanded EPA’s CISWI definitions rule, in which the Agency had defined “commercial and industrial solid waste” to exclude combustion in units that burn materials for energy recovery.  The court held that the plain meaning of the statute required EPA to regulate under section 129 of the Act “any” facility which combusts “any” solid waste material.  Under section 129, “solid waste” is to have the meaning established by the Administrator under the Solid Waste Disposal Act.  Therefore, combustion units that combust any solid waste will be subject to emissions standards under section 129.  Combustion units that do not combust any solid waste will be subject to emissions standards under section 112.
After analyzing the results of the combustion survey, the Agency still identified data gaps for regulated pollutants and pollutant surrogates. Furthermore, there has been input by the regulated community on the appropriateness of certain surrogates that were used in the vacated Boiler standard. Furthermore, the Agency has also identified units in the CISWI list that do not have data for all the pollutants under section 129. 

(b)	Use/Users of the Data 
The data collected will be used to revise the population of potentially affected combustion units under sections 112 and 129 of the Act, and update existing emission test data and material analysis information.  These data will be used by the Agency to develop a revised NESHAP for boilers and process heaters under sections 112 of the Act, and revised standards for incineration units covered by section 129 of the Act.  Specifically, the data will respond in part to the two research needs noted in Section 2(a), providing the Agency with updated information on the number of potentially affected units, available emission test data and fuel/material analysis data to address variability.  The data will be used to complete emission data gaps for calculating the MACT floors, setting emission limits, and evaluating the emission impacts of various regulatory options for these revised rulemakings.  All data collected will be added to existing emission test databases for boilers, process heaters, and when appropriate, incineration units, as long as the existing emission test data still represent operational units. The data will also be used to further evaluate the HAP emissions from these sources.  
3.	Non-duplication, Consultations, and Other Collection Criteria 
(a)	Non-duplication 
The Agency has focused its requests for testing, monitoring, and fuel analysis to where there are data gaps or additional data needed to assess variability.  To the extent that a test or variability data exists at the unit, but was not submitted to the Agency, a facility may submit this existing data instead of collecting new data

(b)	Public Notice Required Prior to ICR Submission to OMB 
The ICR was submitted for public review and comment on December 7, 2007 and May 14, 2008. EPA has considered public comments on the combustion unit test program in preparing this ICR. OMB approved the first phase of the ICR in August 2008 and indicated in the ICR Terms of Clearance that it would review the testing phase of this ICR separately. 
(c)	Consultations 
Significant input and information has been received on the costs of the test plan, types of items to be tested, and the number and types of units selected for testing. Comments were first received after the December 7, 2007 1st Federal Register requested public review and comment of the draft ICR. Eleven organizations listed below provided comments on this ICR:

–	Council of Industrial Boiler Owners (CIBO)
–	National Association of Clean Air Agencies (NACAA)
–	Natural Resources Defense Council (NDRC)
–	American Forest and Paper Association (AF&PA)
–	Occidental Chemical Corporation (OCC)
–	Alliance of Automobile Manufacturers (Alliance)
–	American Chemistry Council (ACC)
–	American Municipal Power – Ohio (AMP-Ohio)
–	Florida Sugar Industry (FSI)
–	Alexander & Baldwin – Hawaiian Commercial and Sugar Company (A&B)
–	National Council for Air and Stream Improvement (NCASI)

	In early 2008, the public provided comment on ten aspects of the combustion unit test program portion of the ICR: the schedule for the testing, the cost estimates associated with testing, criteria for selecting test sites, need for paired inlet and outlet testing, pollutants to be tested for, the population of units eligible for the test, the sample design, how to submit the data, and incentives and funding for testing. 
–	See section 5(d) of this supporting statement for a revised test schedule. 
–	Based on public comments on the cost estimates for testing, the Agency reviewed cost estimates of the 2005 OSWI rulemaking, to obtain a comparative estimate for the costs to conduct testing on section 129 pollutants. The Agency also consulted an emissions testing contractor to estimate the costs of renting CEM equipment and collecting CEM data for CO, O2, SO2, and NOx. See Attachment A for a revised cost estimate for the combustion unit test program.  
–	Several commenters expressed concern on the Agency’s plan to select test sites “at random.” Section 5(d) of this supporting statement addresses these concerns.  
–	Section 4(b) of this supporting statement discusses how the results of the emission tests will be submitted and which pollutants will be tested. 
–	Section 3(d) of this supporting statement discusses the Agency plans to remove the paired sampling requirement from the tests. 
–	Part B of this supporting statement addresses the public comments provided on the population of units eligible for the test, and the sample design. 
–	Several commenters indicated that the Agency should provide some type of enforcement, compliance, or financial incentive for the testing such as exemptions from performance testing, an EPA funded test program for small entities, or a method to spread the costs among all potential affected sources.  At this time the Agency does not have the resources to fund a test program, and a cost sharing program would be impractical to implement, especially in the time frame of these rulemakings. The EPA will take into account requests for compliance test waivers at the time of the rulemaking for the revised standard, as allowed under 40 CFR 63.7(h)(2).  

	Several commenters asked if EPA Regional offices will audit a sample of the stack tests, or if the Agency assumed that state inspectors will audit the tests.  EPA Regional Offices and the state authorities will be notified of the test request letters.  There is no requirement that the tests be audited.  However, the Agency has included in its burden estimate for the Federal government an assumption that five percent of the tests will be audited.

Further, in December 2008 and January 2009, the Agency received several additional comments on its draft testing list. The Agency updated its testing list to reflect stakeholder comments on fuels burned, corrections to control devices or emission data, and an update on the status of any units that are no longer operating.  The Agency also sponsored a stakeholder meeting on March 14, 2008 to discuss the draft test plan.

(d)	Effects of Less Frequent Collection 
For the stack testing component of this information collection, one of the most important requirements in sample design is that of determining how large a sample is needed for the estimates obtained in those selected samples (or units) to be reliable enough to meet the objectives of the study.  In the determination of sample sizes for studies where virtual certainty (i.e., a high level of reliability) is needed, a level of 95 percent confidence is established to assure the objectives of the study will be met.  For this particular collection effort, a maximum of 310 units will be requested to test, monitor, or collect fuel analysis data. Each stack test will be comprised of 3 outlet test runs.  Several commenters indicated that paired sampling is unnecessary and overly burdensome. Additionally, they indicated that the duct configuration and number of sampling ports at some units make paired sampling unfeasible.  Commenters also stated that the costs and technical feasibility of paired sampling will limit the potential test sites. Since MACT standards and the CISWI rule are based on outlet rates, the Agency has revised its test plan to allow for outlet-only testing.  A smaller subset of boilers and process heaters will be asked to collect fuel analysis data or conduct continuous monitoring of CO and THC.
(e)	General Guidelines 
This ICR will adhere to the guidelines for Federal data requestors, as provided at 5 CFR 1320.6.
(f)	Confidentiality 
(i)	Confidentiality.  Respondents will be required to respond under the authority of section 114 of the Act.  If a respondent believes that disclosure of certain information requested would compromise a trade secret, it should be clearly identified as such and will be treated as confidential until and unless it is determined in accordance with established EPA procedure as set forth in 40 CFR Part 2 not to be entitled to confidential treatment.  All 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 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).  Any information subsequently determined to constitute a trade secret will be protected under 18 U.S.C. 1905.  If no claim of confidentiality accompanies the information when it is received by the EPA, it may be made available to the public without further notice (40 CFR 2.203, September 1, 1976).  Because section 114(c) of the Act exempts emission data from claims of confidentiality, the emission data provided may be made available to the public.  Therefore, emissions data should not be marked confidential.  A definition of what the EPA considers emissions data is provided in 40 CFR 2.301(a)(2)(i).
(ii)	Sensitive questions. This section is not applicable because this ICR will not involve matters of a sensitive nature.
4.	The Respondents and the Information Requested
(a)	Respondents/NAICS Codes 
Respondents affected by this action are owners/operators of industrial, commercial, and institutional boilers and process heaters as defined under the vacated boiler and process heater NESHAP: 
Boiler means an enclosed device using controlled flame combustion and having the primary purpose of recovering thermal energy in the form of steam or hot water.  Waste heat boilers are excluded from this definition.

Process heater means an enclosed device using controlled flame, that is not a boiler, and the unit’s primary purpose is to transfer heat indirectly to a process material (liquid, gas, or solid) or to a heat transfer material for use in a process unit, instead of generating steam. Process heaters are devices in which the combustion gases do not directly come into contact with process materials.  Process heaters do not include units used for comfort heat or space heat, food preparation for on-site consumption, or autoclaves.

and owners/operators of commercial and industrial solid waste incineration units as defined under 40 CFR Part 60 Subpart CCCC:

Commercial and industrial solid waste incineration (CISWI) unit means any combustion device that combusts commercial and industrial solid waste.

The definitions above are not intended to indicate the definitions of each category that will be used in developing the revised boiler and process heater NESHAP and the revised CISWI standards.  Rather, the definitions are taken from the 2004 NESHAP and the 2000 CISWI standards in order to ensure that the scope of respondents includes all sources expected to be subject to one or the other set of revised standards. 

Table 1 below presents some examples of potentially affected entities according to NAICS code. This list is not exhaustive. Boilers and process heaters are located at a large variety of NAICS codes.

Category	NAICS code	Example of Potentially Affected Entities	
Any industry using a combustion unit as defined
in either rulemaking.	211	Extractors of crude petroleum and natural gas	
	321	Manufacturers of lumber and wood products	
	322	Pulp and paper mills	
	325	Chemical manufacturers	
	324	Petroleum refineries, and manufacturers of coal
Products	
	316	Manufacturers of rubber and miscellaneous plastic
Products	
	331	Steel works, blast furnaces	
	332	Electroplating, plating, polishing, anodizing, and
Coloring	
	336	Manufacturers of motor vehicle parts and accessories	
	221	Electric, gas, and sanitary services	
	622	Health services	
	611	Educational services	
According to the distribution of boiler and process heaters selected for testing, 11 units are in the public sector, and 176 units are in the private sector. Four of the private sector units are not-for-profit.
All 123 of the CISWI units selected for testing are at the private sector. Two of the private sector units are not-for-profit.
. 
(b)	Information Requested
(i)	Data items, including recordkeeping requirements.  
Stack testing will require three outlet runs according to an EPA-approved test method.  The pollutants to be tested for during the stack tests are expected to be some subset of the pollutants discussed in Section 1(b) above.  The Agency will provide a guidance document to outline the approved methods, sampling intervals, and QA/QC activities for any requested stack test, monitoring activity, or fuel analysis. 
(ii)	Respondent activities. The activities a respondent will undertake to fulfill the
requirements of the information collection are presented in Attachments A.  These include: i) secure stack test contractor and review proposal (if one of the units selected); ii) conduct fuel/material sampling (if one of the units selected for fuel analysis); iii) conduct stack testing (if one of the units selected); iv) conduct monitoring activities (if selected for monitoring); v) monitor and record process parameters during testing; vi) supervise testing/monitoring/analysis activities (if one of the units selected); vii) review stack sampling data for accuracy and completeness (if one of the units selected); and viii) submit stack sampling data (if one of the units selected).
5.	The Information Collected--Agency Activities, Collection Methodology, and
Information Management
(a)	Agency Activities 
A list of activities that will be required of EPA is provided in Attachment B. These include: i) develop generic testing, monitoring, and fuel analysis guidance; ii) review and analyze responses; iii) determine sites to be emission tested; iv) answer respondent questions; v) audit stack tests; vi) review stack sampling data for accuracy and completeness; vii) analyze fuel sampling data; viii) analyze stack sampling data; and ix) analyze requests for confidentiality.
(b)	Collection Methodology and Management
The Agency prefers each respondent to submit electronic copies of the test reports, monitoring data, and fuel analysis results. Specific details on how to report this data is contained in the Agency guidance document for conducting these activities. 
Small Entity Flexibility 
All respondents required to comply with the combustion unit data gathering effort will be subject to the same requirements.  The EPA expects that a portion of the respondents may be small entities; however, the Agency has limited the number of small entities it has selected for testing and if another similar unit that was not located at a small entity could be tested, the Agency would not select the small entity. 
Based on information provided in the survey, this ICR estimates the following:
•	Two of the 11 state/local/tribal sector boiler/process heater units selected for testing are small entities
•	21 of the 176 private sector boiler/process heater units selected for testing are small entities 
•	19 of the 127 CISWI units selected for testing are at small entities. All CISWI units are located in the private sector. 
 
(d)	Collection Schedule 
The EPA anticipates issuing the test request letters by May 2009.  These section 114 letters would require the owner/operator of each selected facility secure a testing contractor, commence stack testing, including concurrent fuel/material sampling and analysis, review stack testing for accuracy and completeness, and submit stack testing results to EPA within 120 days of receipt of the section 114 letter.  
6.	Estimating the Burden and Cost of the Collection 
(a)	Estimating Respondent Burden 
The one-time burden estimate for reporting and recordkeeping requirements are presented in Attachment A.  These numbers were derived from estimates based on the EPA’s experience with other emission test programs, specifically the “Information Collection Request for Electric Utility Steam Generating Unit Mercury Emissions Information Collection Effort” September 3, 1998, ICR number: 1858.01 (ICR shown in Docket A-92-55), and recent consultations with emission testing professionals.  These estimates represent the one-time burden that will be incurred by the recipients.  These estimates are based on a maximum number of 310 emission test units. The site-specific test estimates for the cost of contracting out the testing services are presented in Appendix 1 and Appendix 2. 
(b)	Estimating Respondent Costs 
Attachment A presents estimated costs for the required recordkeeping and reporting activities.  Labor rates were based on May 2008 raw labor rates for the Manufacturing Sector (NAICS 31 thru 34), loaded using an overhead factor of 110%, and indexed to December 2008 using the Employment Cost Index for manufacturing jobs.  The resulting rates are $120.96 for management personnel, $82.31 for technical personnel, and $31.38 for clerical personnel.  These values were taken from the Bureau of Labor Statistics Occupational Employment Statistics Survey Web site and reflect the latest values available (May 2008).  The Employment Cost Index is located at: http://www.bls.gov/news.release/eci.t02.htm
(c)	Estimating Agency Burden and Cost
The costs the Federal Government would incur are presented in Attachment B. Labor rates and associated costs are based on the estimated 2008 loaded hourly rates (labor rate plus 60% for overhead) of $82.88 for management personnel (GS- 15, step 5); $50.14 for technical personnel (GS- 12, step 5); and $28.27 for clerical personnel (GS-7, step 5).
(d)	Estimating the Respondent Universe and Total Burden and Costs 
Based on a review of the combustion survey results the Agency has estimated the population of CISWI units and major source boilers and process heaters in the table below:

Combustion Unit Category	Number of Facilities	Number of Combustion Units	
Major Source Boilers and Process Heaters	1,548	13,052	
CISWI Units	148	202	

Appendices 1 and 2 and Part B of the supporting statement discuss the details of the burden estimate. 
 (e)	Bottom Line Burden Hours and Costs Tables 
(i)	Respondent tally. The total industry burden hours and costs, presented in Attachment A, are calculated by summing the person-hours column and by summing the cost column.  The total burden and cost to the industry over the three years is 26,025 hours and $18,748,554, which includes $16,678,000 in O&M costs to cover contracting services for fuel/material analyses, stack testing, and temporary CO CEM and THC analyzer devices. This is a one-time burden, so the annual burden during the 3-year ICR period is 8,675 hours and $5,559,333 in O&M costs.
Agency tally. The total line Agency burden and cost, presented in Attachment B is calculated in the same manner as the industry burden and cost.  The estimated total burden and cost over the three years are 8,857 hours and $439,769, which includes $1550 in O&M costs to send certified section 114 letters to all respondents with electronic return receipt.
(ii)	The complex collection. This ICR is a simple collection; therefore this section does not apply.
(iii)	Variations in the annual bottom line. This section does not apply as this is a one time collection.
(f)	Reasons for Change in Burden 
	The changes in burden from the previously approved ICR 2286.01 are due to two items:
First, the survey portion of the ICR that was approved by OMB in August 2008 is now complete and there are no costs associated with collecting or compiling the survey results in this ICR. Second, the universe of units the Agency is requesting to test has decreased from an estimated 350 units to 310 units. Further, the extent of the tests required at these 310 units does not cover all pollutants at all units as was previously estimated. The Agency has included an estimate of actual data gaps that exist and is only requested the number and types of tests necessary to complete these gaps. Finally, the Agency is using fuel analysis when appropriate in order to reduce the costs related to stack testing and investigate emission variability.
(g)	Burden Statement
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 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.
This is a one-time burden so the annual reporting and recordkeeping burden spread across the 3-year ICR period for this data gathering effort is estimated to be 8,675 hours and $5,559,333 in O&M costs (28 hours and $17,933 in O&M on average per respondent for 310 respondents).  This ICR does not include any requirements that would cause the respondents to incur either capital or start-up costs.  The Agency will work with industry to avoid testing at sites that would need to install test ports in order to conduct the test.  The EPA has assumed that all respondents will contract (i.e., purchase services/operation and maintenance costs) for the fuel analyses, stack testing, and preparation of the stack test report. In addition, there will be a small O&M costs to mail a hard copy of the actual emission test report (when requested by the Agency).  These costs have been included in the burden estimate above.  
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 docket for this ICR under Docket ID EPA-HQ-OAR-2002-0058, which is available for online viewing at www.regulations.gov, or in hard copy at EPA Docket, EPA/DC, EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA/DC Public Reading Room is open from 8 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 Air and Radiation Docket Center is 202-566-1742.
	An electronic version of the public docket is available at www.regulations.gov.  This site can be used to submit or view public comments, access the index listing of the contents of the public 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 above. 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 EPA Docket ID No. EPA-HQ-OAR-2002-0058 and OMB Control Number 2060-NEW in any correspondence.
List of Attachments

Attachment A:		Industry Burden and Cost 
Attachment B: 	Agency Burden and Cost