2028ss09

14

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), EPA ICR Number 2028.09, OMB Control Number 2060-0551.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) were proposed on January 13, 2003, and promulgated on September 13, 2004. On June 19, 2007, the United States Court of Appeals for the District of Columbia Circuit vacated and remanded the Boilers NESHAP. On June 4, 2010 EPA issued a proposal in response to the vacatur, and in March 2011 EPA promulgated the rule in response to the vacatur. Also in March 2011, EPA issued a voluntary reconsideration of the final rule and then proposed its reconsideration of the rule in December 2011. The Boiler MACT reconsideration was finalized in January 2013. On January 21, 2015, EPA issued a proposal in response to certain issues raised in petitions of reconsideration on the January 13, 2013 final rule. EPA subsequently published a final rule and notice of action on reconsideration on November 20, 2015. The 2015 final rule did not increase any new recordkeeping and reporting burdens.

These regulations apply to existing and new industrial, commercial, and institutional boilers and process heaters located at major sources of HAP. There are 21 subcategories of boilers and in-direct fired process heaters: Pulverized coal/solid fossil fuel units; Stokers designed to burn coal/solid fossil fuel; Fluidized bed units designed to burn coal/solid fossil fuel; Fluidized bed units with an integrated heat exchanger designed to burn coal/solid fossil fuel; Stokers/sloped grate/other units designed to burn kiln dried biomass/bio-based solids; Stokers/sloped grate/other units designed to burn wet biomass/bio-based solids; Fluidized bed units designed to burn biomass/bio-based solids; Suspension burners designed to burn biomass/bio-based solids; Dutch ovens/pile burners designed to burn biomass/bio-based solids; Fuel Cells designed to burn biomass/bio-based solids; Hybrid suspension/grate burners designed to burn wet biomass/bio-based solids; Units designed to burn coal/solid fossil fuel; Units designed to burn solid fuel; Units designed to burn liquid fuel; Units designed to burn heavy liquid fuel; Units designed to burn light liquid fuel; Units designed to burn liquid fuel in non-continental States or territories; Units designed to burn natural gas, refinery gas or other gas 1 fuels; Units designed to burn gas 2 (other) gases; Metal process furnaces; and Limited-use boilers and process heaters. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart DDDDD.

In general, all NESHAP standards require initial notifications, performance tests, and periodic reports 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 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.

Any owner/operator subject to the provisions of this part shall maintain a file containing these documents, and retain the file for at least five years following the generation date of such 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 U.S. Environmental Protection Agency (EPA) regional office.

The “Affected Public” are owners and operators of boilers and in-direct fired process heaters that are subject to this NESHAP. The “burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal). The Federal Government’s burden is attributed entirely to work performed by either Federal employees or government contractors and can be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal).

Based on our consultations with industry representatives, there are multiple units at each plant site, the number of units varies depending on the subcategory of the boiler or process heaters. Each facility or plant site is counted as one respondent.

There are currently approximately 15,966 existing units at 1,856 facilities subject to these standards. We estimate an additional 615 new units at 78 facilities per year will become subject over the next three years. The number of facilities and units for each subcategory over the next three years may be found below in Table 3: Respondents and Units by Subcategory – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters. Approximately 6% (121 entities) of these facilities are owned by either state, local, tribal or the Federal government. The remaining 94% (1,891 entities) are owned and operated by privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries. This estimate is based on a 5-year industry projection conducted at the time of the final reconsideration, with adjustments for the shutdown and conversion of existing solid-fired (specifically coal-fired) units to gas-fired units since promulgation of the final rule. We assume a constant growth for all subcategories.

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. 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 industrial, commercial, and institutional boilers and process heaters either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were 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 these standards 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 these emission standards. Continuous emission monitors are used to ensure compliance with the standards 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 these standards 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, leaks are being detected and repaired, and that these standards are being met. The performance test may also be observed.

The required annual, biennial, five-year, and 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 DDDDD.

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, duplication does not exist.

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 (82 FR 28552) on June 29, 2017. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The Agency also reviewed compliance data submitted through EPA’s WebFIRE, which contains reports submitted to the EPA using the Compliance and Emissions Data Reporting Interface (CEDRI), to identify changes to units following the November 20, 2015 rule. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts and it accounts for shutdowns of coal-fired boilers and fuel switching from coal to natural gas, which has adjusted some of the subcategory counts. Approximately 2,012 respondents, on average, will be subject to these standards over the three-year period covered by this ICR.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Council of Industrial Boiler Owners, at (540) 349-9043, and the American Forest & Paper Association, at (202) 463-2588.

It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.

3(d) Effects of Less-Frequent Collection

Less-frequent information collection would decrease the margin of assurance that facilities are continuing to meet these 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

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 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 these 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 five years. In addition, EPA would be prevented from pursuing the violators due to either 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 (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

The reporting or recordkeeping requirements in these standards do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators of new and existing industrial, commercial, or institutional boilers and process heaters. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards and the corresponding North American Industry Classification System (NAICS) codes are listed below.

Standard (40 CFR Part 63, Subpart DDDDD)	SIC Codes	NAICS Codes
Extractors of crude petroleum or natural gas.	1311/3121/2819	211
Wood product manufacturing.	2421/2426/2429/2491/2435/2436/ 2439/2493/2431/2441/2448/ 2449/2499/2451/2452/3131	321
Pulp and paper mills.	2611/2621/2631/2653/2679/2657/2652/2655/2656/2671/2672/2679/2673/2674/3497/2675/2677/2678/2676/3842	322
Chemical manufacturers.	2865/2869/2813/2879/2851/2899/2891/2844/2893/2892	325
Petroleum refineries and manufacturers of coal products.	2911	324
Manufacturers of rubber and miscellaneous plastic products.	3111/3999/3083/3086/3085/3052/3949/3069/3993	316/326/339
Steel works, blast furnaces.	3317	331
Electroplating, plating, polishing, anodizing, and coloring.	3443/3559/3429/3499/3599	332
Manufacturers of motor vehicle parts and accessories.	3711/3714/3292/2396/2399/ 2531/3499/3465/3531/3743	336
Electric, gas, and sanitary services.	4923/4924/4925/4931/4932/4939/4941/4971/4952/4961	221
Health services.	8062/8069/8063	622
Educational services	8211/8222/8221/8244/8243/8299/7231/7241/8249/7911/7999/8748	611

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD).

A source must make the following reports:

Notifications
Initial Notification that Source is Subject	§63.7545
Notification of Compliance Status	§63.7545
Notification of Alternative Fuel Use	§63.7545

Reports
Initial Report on results of Energy Audit	§§63.7530, 63.7545
Annual Compliance Report	§63.7550
Semi-annual Compliance Report	§63.7550

A source must keep the following records:

Recordkeeping
Records of Startup, Shutdown, Malfunction	§63.7555
Records of Performance Tests	§63.7555
Records of Monitoring Device Calibrations	§63.7525
Records of All Annual Compliance Reports Submitted	§63.7555
Records of All Semi-Annual Compliance Reports Submitted	§63.7555
Records of Monthly Fuel Use	§63.7555
Records of Annual Tune-up	§63.7540

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. Most emissions and monitoring information in the reports are reported in an electronic format using the Electronic Reporting Tool (ERT). The data will be extracted from the ERT files and can be viewed through EPA’s Central Data Exchange. At this time, it is estimated that approximately 100 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pH, pressure drop and liquid supply pressure for each scrubber, fabric filter, electrostatic precipitator, carbon injection control, or other add-on air control device.

Perform initial performance test, Reference Method 1, 2, 2F, 2G, 3A, 3B, 4, 5, 10, 17, 19, 26, 26A, 29, 30A, or 30B 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.

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

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 Enforcement and Compliance History Online (ECHO) and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could 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 these emission standards. 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 reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS 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

The EPA expects that the NESHAP will have a substantial impact on a significant number of small entities. In developing the regulation, small entity is defined as: (1) a small business according to Small Business Administration size standards by the North American Industry Classification System (NAICS) category of the owning entity. The range of small business size standards for the 45 affected 3-digit NAICS industries ranges from 500 to 1,000 employees, except for petroleum refining and electric utilities. In these latter two industries, the size standard is 1,500 employees and a mass throughput of 75,000 barrels/day or less or 4 million kilowatt-hours of production or less, respectively; (2) a small governmental jurisdiction that is a government of a city, county, town, school district or special district with a population of less than 50,000; and (3) a small organization that is any not-for-profit enterprise that is independently owned and operated and is not dominant in its field.

The EPA has previously determined that approximately 9 percent of the total facilities affected by the regulation may be small entities.¹ The Boilers NESHAP does not contain any provisions reserved exclusively for the benefit of small entities. However, the regulation does contain several provisions that reduce the impact on all regulated entities, which include small entities. For instance, operating parameter monitoring is required instead of CEMS. The rule provides an option to demonstrate compliance with fuel analysis in lieu of stack testing for boilers combusting fuels with mercury, TSM8, or chlorine contents less than their associated emission limit. In addition, providing a work practice standard for small and limited use boilers and process heaters firing all fuel types and for boilers of all sizes firing natural gas, refinery gas, or other gas 1 fuels, the EPA has substantially reduced the burden of the rule, including reducing the burden on small entities. For example, for small entities with only small or limited use boilers and process heaters installed, the option to demonstrate compliance using an annual, biennial, or every five-year tune-up is a substantial savings compared with the requiring stack testing, parameter monitoring, and add-on air pollution control devices. Additionally, compliance flexibilities exist for boilers and process heaters burning ultra-low sulfur liquid fuels, by reducing the requirement for subsequent performance tests.

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

6. Estimating the Burden and Cost of the Collection

Table 1 documents the summary 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 neither conduct nor 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 597,000 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of these regulations, 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 $149.35 ($71.12 + 110%)

Technical $112.98 ($53.80 + 110%)

Clerical $54.81 ($26.10 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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 type of industry costs associated with the information collection activities in the subject standard are both 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 monitors 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) Boiler Type	(B) Number of Respondents per Year (facilities)	(C) Annual Capital/Startup Cost	(D) Annual O&M Costs	(E) Annual O&M and Annualized Capital Costs per year
Existing Large Solid Units	121	$0	$74,866,304	$74,866,304
New Large Solid Units	3	$2,005,198	$1,218,750	$3,223,948
Existing Small and Limited Use Solid Units	5	$0	$98,032	$98,032
New Small Solid Units	1	$0	$4,456	$4,456
Existing Large Liquid Units	66	$0	$17,695,826	$17,695,826
New Large Liquid Units	0	$0	$0	$0
Existing Small and Limited Use Liquid Units	45	$0	$857,780	$857,780
New Small Liquid Units	0	$0	$0	$0
Existing Large Gaseous Units	669	$0	$18,867,183	$19,012,791
New Large Gaseous Units	33	$0	$750,375	$750,375
Existing Small and Limited Use Gaseous Units	1,027	$0	$13,921,380	$13,921,380
New Small Gaseous Units	41	$0	$726,328	$726,328
Total	2,012	$2,000,000	$129,000,000	$131,000,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $2,000,000. This is the total of column C in the above table.

The total operation and maintenance (O&M) costs for this ICR are $129,000,000. This is the total of column D.

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 $131,000,000. These are recordkeeping costs.

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 $1,490,000.

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

Managerial $64.80 (GS-13, Step 5, $40.50 + 60%)

Technical $48.08 (GS-12, Step 1, $30.05 + 60%)

Clerical $26.02 (GS-6, Step 3, $16.26 + 60%)

These rates are from the Office of Personnel Management (OPM), 2017 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. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (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 1,934 existing respondents will be subject to these standards. Also, it is estimated that an additional 78 respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 2,012 per year.

The number of respondents is calculated using the following tables that address the three years covered by this ICR:

Number of Respondents - All
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents2	(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	78	1,856	0	0	1,934
2	78	1,934	0	0	2,012
3	78	2,012	0	0	2,090
Average	78	1,934	0	0	2,012

¹ New respondents include sources with constructed, reconstructed and modified affected facilities.

² Existing respondents are calculated based on the number of existing respondents at the time of final rule promulgation (ICR 2029.08) and assuming constant growth (78 new respondents per year over 3 years) since the final rule was promulgated in November 2015.

The number of respondents per subcategory is calculated using the following table that addresses the three years covered by this ICR:

Number of Respondents – By Subcategory
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Boiler Subcategory	(A) Number of New Respondents Per Year1	(B) Number of Existing Respondents Per Year (Average)2	(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)
Large Solid Units	3	121	0	0	124
Large Liquid Units	0	66	0	0	66
Large Gas Units	33	669	0	0	702
Small Solid Units 3	1	5	0	0	6
Small Liquid Units	0	45	0	0	45
Small Gas Units	41	1,027	0	0	1,068
Total	78	1,934	0	0	2,012

¹ The 78 new facilities (respondents) include 26 large solid units, 261 large gas units, 1 small solid units, and 326 small gas units per year. See Table 3: Respondents and Units by Subcategory – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters.

² Average existing respondents per year based on the number of existing respondents at the time of final rule promulgation (ICR 2029.08) and assuming constant growth (78 new respondents per year over 3 years) since the final rule was promulgated in November 2015.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 2,012.

The total number of annual responses per year are shown in the following table:

Total Annual Responses
(A) Boiler Type	(B) Number of Respondents (Average)	(C) Number of Responses (Average)	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses
Existing Large Solid Units	121	2	0	242
New Large Solid Units	3	4	0	12
Existing Small Solid Units	5	0.56	0	3
New Small Solid Units	1	3.00	0	3
Existing Large Liquid Units	66	2	0	132
New Large Liquid Units	0	0	0	0
Existing Small Liquid Units	45	0.51	0	23
New Small Liquid Units	0	0	0	0
Existing Large Gaseous Units	669	2.3	0	1,530
New Large Gaseous Units	33	2.97	0	99
Existing Small Gaseous Units	1,027	0.50	0	514
New Small Gaseous Units	41	2.50	0	103
			Total	2,661

The number of Total Annual Responses is 2,661.

The total annual labor costs are $65,400,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal).

6(e) Bottom Line 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 below, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 597,000 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks, because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 224 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $131,000,000. 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 27,300 labor hours at a cost of $1,490,000; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes. The change in burden and cost estimates occurred because there is continued growth for certain subcategories of equipment subject to these standards. In addition, these same standards have been in effect for more than three years, and the requirements are different during initial compliance (new facilities) as compared to on-going compliance (existing facilities). The previous ICR reflected those burdens and costs associated with the initial activities for subject facilities and provided for the timeframe for existing facilities to come into compliance prior to January 31, 2016. This included purchasing monitoring equipment, conducting initial performance tests, and establishing recordkeeping systems. This ICR reflects the on-going burden and costs for existing facilities. Activities for existing sources include annual testing, continuous monitoring of pollutants, and the submission of semiannual, biennial, or five-year reports, as determined for each subcategory.

There is an adjustment decrease in the number of responses as compared with the previous ICR. This decrease is a result of removing some of the one-time response requirements for existing sources that have already met the initial compliance requirements. There is an overall increase in the total capital/startup and annual operation and maintenance costs compared with the previous ICR. These changes assume all existing sources have met the initial requirements of the rule. In addition, there are a small number of new facilities that are in the initial compliance phase described above.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 224 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 neither conduct nor 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 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-2013-0352. 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), WJC 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 docket center 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 Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2013-0352 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.

1 This estimate is based on responses to the 2008 survey “Information Collection Effort for Facilities with Combustion Units (ICR No. 2286.01)”, as well as follow-up information submitted to the docket during the 2013 final rule, which indicated 151 of 1,701 facilities (9%) were small entities. The number of facilities has changed since the 2013 final rule, but this ICR renewal estimates the same percentage of facilities, or now 181 (9% of 2,012 average facilities per year) are small entities.