SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 

63, Subpart JJJJJJ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, 

Subpart JJJJJJ) (Renewal), EPA ICR Number 2253.03, OMB Control Number 2060-0668.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Industrial, 

Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) were 

proposed on June 4, 2010, and promulgated on March 21, 2011. At promulgation, EPA 

announced it was reconsidering certain portions of the emission standards. EPA proposed a 

limited number of amendments and technical corrections to the final rule on December 23, 2011. 

On February 1, 2013, EPA finalized the standard by amending compliance dates and technical 

corrections to clarify definitions, references, applicability, and compliance issues raised by

petitioners and other stakeholders affected by the rule. None of these amendments affected the 

respondent burden associated with this information collection request (ICR).

 These regulations apply to existing and new boilers at major and area sources that are 

designed to burn biomass, coal, or liquid fuels. A major source emits or has the potential to emit 

10 tons per year (tpy) or more of any single hazardous air pollutant (HAP) or 25 tpy or more of 

any combination of HAPs. An area source is a HAP-emitting stationary source that is not a 

major source. New facilities include those that commenced construction, modification, or 

reconstruction after the date of proposal (i.e., June 4, 2010). This information is being collected 

to assure compliance with 40 CFR Part 63, Subpart JJJJJJ.

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 the NESHAP.

Any owner/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 U. S.

Environmental Protection Agency (EPA) regional office.
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 Based on our consultations with industry representatives, there is an average of two 

affected sources 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, an average of 191,710 existing units at 95,855 facilities will be 

subject to these standards. We estimate an additional 2,260 new units at 1,130 facilities per year 

will become subject to the standards. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any Terms of Clearance.

The “Affected Public” are owners and operators of new or existing industrial, 

commercial, or institutional boilers. The “burden” to the Affected Public may be found below

in:

 Table 1A: Annual Respondent Burden and Cost – : Annual Respondent Burden and Cost 

– Existing and New Large Solid Fuel Boilers, NESHAP for Industrial, Commercial, and 

Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal);

 Table 1B: Annual Respondent Burden and Cost – Existing and New Large Liquid Fuel 

Boilers, NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 

CFR Part 63, Subpart JJJJJJ) (Renewal);

 Table 1C: Annual Respondent Burden and Cost – Existing and New Small Solid Fuel 

Boilers, NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 

CFR Part 63, Subpart JJJJJJ) (Renewal); and

 Table 1D: Annual Respondent Burden and Cost – Existing and New Small Liquid Fuel 

Boilers, NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 

CFR Part 63, Subpart JJJJJJ) (Renewal).

The “burden” to the Federal Government is attributed entirely to work performed by 

either Federal employees or government contractors. This burden may be found below in Table 

2: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and 

Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal). 

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 
3

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, or 

institutional boilers 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 JJJJJJ.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensures 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.

The information will be used by EPA to: (1) identify new, modified, reconstructed and 

existing sources subject to the NESHAP; (2) ensure the NESHAP is being applied properly; (3) 

ensure compliance with the NESHAP; (4) ensure, on a continuous basis, that the operating 

parameters established during the initial performance test are not exceeded.

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.

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, that leaks are being detected and repaired, and that these standards are

being met. The performance test may also be observed.

The required annual and biennial reports are used to determine periods of excess 

emissions, identify problems at the facility, verify operation/maintenance procedures and for 

compliance determinations.

In addition, records and reports are necessary to enable EPA to identify facilities that may

not be in compliance. Based on reported information, EPA will decide which facilities should be 
4

inspected and what records or units should be inspected at the facilities. The records that 

facilities maintain will indicate to EPA whether facility personnel are properly operating and 

maintaining boilers, as well as associated control equipment.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart 

JJJJJJ.

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 (78 FR 35023) on June 11, 2013. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our research conducted in preparation of the final rule reconsideration. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standards as they were being developed and these

same standards have been reviewed previously 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. 
5

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

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 

the standards. EPA believes that the five-year records retention requirement is consistent 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 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 the standard 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 and 

operators of new or existing industrial, commercial, or institutional boilers. The NESHAP 

affects any industry, federal, state, local, or tribal government, or any institution (e.g., an 

university) using a boiler as defined in the regulations. This includes, but is not limited to, the 

following United States Standard Industrial Classification (SIC) codes and corresponding North 
6

American Industry Classification System (NAICS) codes in the following table:

40 CFR Part 63, Subpart JJJJJJ SIC Codes NAICS Codes

Wood product manufacturing 24 321

Food manufacturing 20 311

Nonmetallic mineral product 

manufacturing

32 327

Wholesale trade, nondurable goods 51 424

Real estate 65 531

Educational services 82 611

Religious, grant making, civic, 

professional, and similar organizations

86 813

Public administration 91-98 92

Food services and drinking places 58 722

Health care and social assistance 80, 83 62

Based on the distribution of facilities in the boiler inspector inventory for thirteen states, 

the EPA estimates that 49% of units are located in the private sector and 51 % of units are 

located in the public sector.

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 Area Sources (40 CFR Part 63, Subpart JJJJJJ).

A source must make the following reports:

Reports/Notifications

Initial Notification that Source is Subject 63.11225(a)

Notification of Compliance Status 63.11225(a)

Initial Report on Results of Energy Audit 63.11210(j)

Annual Compliance Report 63.11225(b)

Biennial Compliance Report 63.11225(b)
7

Reports/Notifications

Performance Test Results 63.11225(e)

Notification of Intent to Commence or Recommence Combustion 

of Solid Waste

63.11225(f)

Notification of Switched Fuels or Physical Changes to Boiler 63.11225(g)

A source must keep the following records:

Recordkeeping

Records of Operating Parameter Values 63.11225(c)(7)

Records of Deviations 63.11225(c)(4) and (5)

Records of Stack Tests 63.11225(c)(1)

Records of Monitoring Device Calibrations 63.11225(c)(6)

Records of All Compliance Reports Submitted 63.11225(c)(1)

Records of Monthly Fuel Use 63.11225(c)(2)

Records of Biennial Tune-up 63.11225(c)(2)

Retain Records for Five Years 63.11225(d)

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.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate continuous monitoring system (CMS) for opacity for 

electrostatic precipitator systems (ESPs) and bag leak detection (BLD) systems.

Perform initial performance test, Reference EPA Methods 1, 2, 3A, 3B, 4, 5D, 10, 10A, 10B, 

17, 19, 29, 30A, 30B, or 101A, and repeat performance tests if necessary.

Write the notifications and reports listed above.
8

Respondent Activities

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 and reporting equipment that provide 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

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 Online Tracking Information System (OTIS). 

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 the emission standard, and to note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 
9

compliance and enforcement programs. The annual and biennial 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 the 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/operator for five 

years.

5(c) Small Entity Flexibility

The EPA expects the NESHAP to adversely affect small entities. In developing the 

regulation, small entity is defined as a small business. According to Small Business 

Administration’s size standards by the NAICS category of the owning entity, the small business 

size standard for manufacturing sectors in the expected industries potentially affected by this rule 

is less than 500 employees. For trade sectors, the size standard is: (1) less than 100 employees; 

(2) a small organization that is any not-for-profit enterprise that is independently-owned and -

operated and is not dominant in its field. For non-profit and service industries, the small 

business size range for potentially-affected sources is based on total sales of the entity, which 

range from sales less than $10 and up to $50 million dollars; (3) 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 individuals.

The EPA has determined that there are approximately 189,450 existing affected sources

at 94,725 facilities. Of these affected units, the EPA has reduced testing, monitoring, 

recordkeeping and reporting requirements for 175,635 units with design heat capacities less than 

10 MMBtu/hr because the Agency found it is impracticable to enforce the emission standards 

for these small units due to technical or economic limitations. Instead of requiring small sources 

to conduct and submit stack test reports, the final rule requires small units to comply with the 

rule by conducting a biennial tune-up and preparing a summary report of the procedures 

followed during the tune-up. Based on the definition for sectors potentially affected by this rule, 

EPA computed the overall share of small entities to the overall number of affected entities. The 

overall share of small entities from manufacturing, trading, service, not-for-profit, and state, 

local, and tribal governments is estimated to be 97 percent, or 183,767 existing units subject to 

recordkeeping and reporting requirements. By reducing the requirements for small sources, the 

EPA has substantially reduced the burden on small entities. Further, EPA is not requiring 

Maximum Achievable Control Technology (MACT) floor control for mercury from biomass and 

liquid units. This reduces the compliance, testing, monitoring, recordkeeping and reporting 

requirements on nearly all units. Mercury control testing and monitoring will be required at 573 

large coal-fired boilers out of the 189,450 total boilers, but will be achieving 95 percent 

reduction of the estimated mercury emissions from the entire source category. By not requiring 
10

MACT control for mercury from biomass and liquid-fired units, we are providing flexibility to 

over 99 percent of affected units, including the small entities.

The Area 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. The alternative work practice 

standards provide for enhanced compliance flexibility and reduced recordkeeping and reporting 

requirements for affected sources with small boilers.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Tables 1A through 1D.

6. Estimating the Burden and Cost of the Collection

Table 1 documents 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. Where 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 1,656,984 hours (Total Labor Hours from Tables

1A through 1D). 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

This ICR uses the following labor rates: 

Managerial $127.43 ($60.68 + 110%) 

Technical $99.16 ($47.22 + 110%)

Clerical $50.88 ($24.23 + 110%)
11

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2013, “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) (B) (C) (D) (E) (F) (G)

Continuous Monitoring 

Device

Capital/Startup 

Cost for One 

Respondent

Number of 

New

Respondents

Total 

Capital/Startup 

Cost, (B X C)

Annual 

O&M Costs 

for One 

Respondent

Number of 

Respondents 

with O&M

Total O&M,

(E X F)

Large Solid Boilers

Initial Stack Test and 

Report (Hg) $5,000 0 $0 $0 0 $0

Triennial Stack Test 

and Report (Hg) $0 286.5 $0 $1,650 286.5 $472,725.000

Initial Stack Test and 

Report (CO) $6,000 0 $0 $0 0 $0

Triennial Stack Test 

and Report (CO) $0 286.5 $0 $1,980 286.5 $567,270.000

Initial Stack Test and 

Report (PM) $8,000 1.83 $14,640.000 $0 1.83 $0

Triennial Stack Test 

and Report (PM) $0 9.16 $0 $2,640 9.16 $24,182.400

Electrostatic 

Precipitator System $43,100 1.83 $78,873.000 $14,700 9.16 $134,652.000

Bag Leak Detection 

System $25,500 0 $0 $9,700 286.5 $2,779,050.000

Biennial Tune-Up $0 1,783 $0 $1,437.5 1,783 $2,563,062.500

Subtotal $93,513 $6,540,942

Large Liquid Boilers

Initial Stack Test and 

Report (PM) $8,000 81.17 $649,360 $0 81.17 $0

Triennial Stack Test 

and Report (PM) $0 405.84 $0 $2,640 405.84 $1,071,417.6

Electrostatic 

Precipitator System $43,100 81.17 $3,498,427 $14,700 405.84 $5,965,848
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Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A) (B) (C) (D) (E) (F) (G)

Continuous Monitoring 

Device

Capital/Startup 

Cost for One 

Respondent

Number of 

New

Respondents

Total 

Capital/Startup 

Cost, (B X C)

Annual 

O&M Costs 

for One 

Respondent

Number of 

Respondents 

with O&M

Total O&M,

(E X F)

Bag Leak Detection 

System $25,500 7.50 $191,250 $9,700 15 $145,500

Biennial Tune-Up $0 5,020.33 $0 $1,438 5,020.33 $7,216,724.38

Subtotal $4,339,037 $14,399,490

Small Solid Boilers

Biennial Tune-Up $0 5,560.33 $0 $1,114 5,560.33 $6,194,207.62

Subtotal $0 $6,194,208

Small Liquid Boilers

Biennial Tune-Up $0 84,334.5 $0 $1,114 84,334.5 $93,948,633

Subtotal $0 $93,948,633

Total $4,432,550 $121,083,273

The total capital/startup costs for this ICR are $4,432,550. This is the total of column D 

in the above table. 

The total operation and maintenance (O&M) costs for this ICR are $121,083,273. 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 $125,515,823.

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

$6,821,798.

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 
13

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 Area Sources (40 CFR Part 63, Subpart JJJJJJ) 

(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

95,855 existing respondents will be subject to the standard. It is estimated that an additional

1,130 respondents per year will become subject. The overall average number of respondents, as 

shown in the table below, is 96,985 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(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 Boilers

1 10 2,049.5 0 0 2,059.5

2 10 2,059.5 0 0 2,069.5

3 10 2,069.5 0 0 2,079.5

Average 10 2,060 0 0 2,070

Large Liquid Boilers

1 81.17 4,858 0 0 4,939.17

2 81.17 4,939.17 0 0 5,020.34

3 81.17 5,020.34 0 0 5,101.51

Average 81 4,939 0 0 5,020
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Number of Respondents

Small Solid Boilers

1 49.17 5,462 0 0 5,511.17

2 49.17 5,511.17 0 0 5,560.34

3 49.17 5,560.34 0 0 5,609.51

Average 49 5,511 0 0 5,560

Small Liquid Boilers

1 989.5 82,355.5 0 0 83,345

2 989.5 83,345 0 0 84,334.5

3 989.5 84,334.5 0 0 85,324

Average 990 83,345 0 0 84,335

Total 1,130 95,855 0 0 96,985

1

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

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 96,985. 

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

Large Solid Boilers

Initial Notification 10 1 0 10

Notification of Compliance Status 10 1 0 10

Annual Compliance Report 2,069.5 1 0 2,069.5

Biennial Compliance Report 1,783 0.5 0 891.5

Subtotal 2,981

Large Liquid Boilers

Initial Notification 81.17 1 0 81.17
15

Total Annual Responses

Notification of Compliance Status 81.17 1 0 81.17

Annual Compliance Report 405.84 1 0 405.84

Biennial Compliance Report 5,020.33 0.5 0 2,510.17

Subtotal 3,078

Small Solid Boilers

Initial Notification 49.17 1 0 49.17

Notification of Compliance Status 49.17 1 0 49.17

Biennial Compliance Report 5,560.33 0.5 0 2,780.17

Subtotal 2,879

Small Liquid Boilers

Initial Notification 989.5 1 0 989.5

Notification of Compliance Status 989.5 1 0 989.5

Biennial Compliance Report 84,334.5 0.5 0 42,167.25

Subtotal 44,146

Total 53,084

The number of Total Annual Responses is 53,084.

The total annual labor costs are $159,386,705. Details regarding these estimates may be 

found below in Tables 1A through 1D.

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 below in Tables 1A through 1D and 2 below, respectively, and summarized 

below. 

(i) Respondent Tally

The total annual labor hours are 1,656,984 hours. Details regarding these estimates may

be found below in Tables 1A through 1D.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 31 hours per response.
16

The total annual capital/startup and O&M costs to the regulated entity are $125,515,823. 

The cost calculations are detailed above 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 

149,141 labor hours at a cost of $6,821,798. See below Table 2: Average Annual EPA Burden 

and Cost –NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR 

Part 63, Subpart JJJJJJ) (Renewal).

6(f) Reasons for Change in Burden

There is a decrease in the total estimated burden as currently identified in the OMB 

Inventory of Approved Burdens. This decrease is not due to any program changes. The change 

in burden and cost estimates occurred because the standards have been in effect for more than 

three years and the requirements are different during initial compliance (new facilities), as 

compared to the on-going compliance, which is reflected in this estimates for this ICR. The 

previous ICR reflected those burdens and costs associated with initial activities for subject 

facilities. This includes purchasing monitoring equipment and conducting performance tests. 

This ICR, by in large, reflects the on-going burden and costs for existing facilities. The overall 

result is a decrease in burden hours and costs.

There is also a decrease in total annual capital/startup and O&M costs as compared to the 

previous ICR. This decrease is attributed to the fact that initial compliance with the standard 

occurred during the period of the previous ICR (e.g., monitors were purchased). For the next 

three years, fewer monitors will be purchased; however, existing CEM monitors will have ongoing O&M costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 31 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 regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.
17

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-2013-0298. 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-2013-0298 and OMB Control Number 2060-0668 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
18

Table 1A: Annual Respondent Burden and Cost – Existing and New Large Solid Fuel Boilers, NESHAP for Industrial, 

Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal)

Burden Item

A B C D E F G H

Technical 

PersonHours per 

Occurrence

Occurrences 

per 

Respondent

per Year

Technical 

Person-Hours 

per Respondent 

per Year 

(C=AxB)

Respondents 

per Year a

Technical 

Hours 

per Year 

(E=CxD)

Clerical 

Hours 

per Year 

(F=Ex0.10)

Management 

Hours 

per Year 

(G=Ex0.05)

Total Cost 

per Year 

($) b

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

 A. Read and Understand Rule Requirementsc40 1 40 10 400 40 20 $44,248

 B. Required Activities

 1) Conduct Energy Audit

 a) Industriald, e 20 1 20 0 0 0 0 $0

 b) Commerciald, e 20 1 20 0 0 0 0 $0

 2) Initial Stack Test (Hg)f, g 12 1 12 0 0 0 0 $0

 3) Initial Stack Test (CO)f12 1 12 0 0 0 0 $0

 4) Initial Stack Test (PM)f, h 12 1 12 1.83 21.96 2.2 1.1 $2,429.66

 5) Triennial Stack Test (Hg)f12 0.33 3.96 286.5 1,134.54 113.45 56.73 $125,502.43

 6) Triennial Stack Test (CO)f12 0.33 3.96 286.5 1,134.54 113.45 56.73 $125,502.43

 7) Triennial Stack Test (PM)f, h 12 0.33 3.96 9.16 36.27 3.63 1.81 $4,011.88

 8) Initial Fuel Analysis for Hg Contentg5 1 5 0 0 0 0.00 $0

 9) Monthly Fuel Analysis for Hg Contentg5 12 60 0 0 0 0 $0

 10) Continuous Parameter Monitoring

 a) Establish Site-Specific Monitoring Plan

 (Hg, CO, and PM)f, i 40 1 40 10 400 40 20 $44,247.80

 b) Opacity (All Sources with ESPs)

 i) Initialj10 1 10 1.83 $18.3 $1.83 $0.92 $2,025

 ii) Annualj10 1 10 9.16 $91.6 $9.16 $4.58 $10,132.75

 c) BLD System Operation (All Sources

 with Fabric Filters)

 i) Initialk10 1 10 0 0 0 0 $0

 ii) Annualk10 1 10 286.5 2,865 287 143 $316,924.87

 11) Biennial Tune-Upl12 0.5 6 1,783 10,698 1,070 535 $1,183,407.41

 C. Create Information N/A
19

Burden Item

A B C D E F G H

Technical 

PersonHours per 

Occurrence

Occurrences 

per 

Respondent

per Year

Technical 

Person-Hours 

per Respondent 

per Year 

(C=AxB)

Respondents 

per Year a

Technical 

Hours 

per Year 

(E=CxD)

Clerical 

Hours 

per Year 

(F=Ex0.10)

Management 

Hours 

per Year 

(G=Ex0.05)

Total Cost 

per Year 

($) b

 D. Gather Information N/A

 E. Report Preparation

 1) Initial Notification that Source is Subject 2 1 2 10 20 2 1 $2,212.39

 2) Notification of Compliance Status 8 1 8 10 80 8 4 $8,849.56

 3) Initial Report on Results of Energy Auditd5 1 5 0 0 0 0 $0

 4) Annual Compliance Report 30 1 30 2,069.5 62,085 6,209 3,104 $6,867,811.66

 5) Bennial Compliance Reportl5 0.5 2.5 1,783 4,457.5 445.75 222.88 $493,087.06

 6) Affirmative Defensem30 1 30 0 0 0 0 $0

Subtotal for Reporting Requirements 95,959 $9,230,393

4. Recordkeeping Requirements

 A. Read Instructions See 3A

 B. Implement Activities N/A

 C. Develop Record Systemn N/A

 D. Record Information

 1) Records of Operating Parameter Valuesf20 1 20 295.7 5,913 591 295.7 $654,137.35

 2) Records of Deviationsf15 1 15 295.7 4,435.1 443.51 221.75 $490,602.95

 3) Records of Stack Testsf2 1 2 295.7 591 59.1 29.57 $65,413.91

 4) Records of Monitoring Device Calibrationsf2 1 2 295.7 591 59.1 29.57 $65,413.91

 5) Records of All Compliance Reports

 Submittedf2 2 4 2,069.5 8,278 827.8 413.9 $915,708.22

 6) Records of Monthly Fuel Usef0.5 12 6 295.7 1,774 177.4 88.700 $196,240.98

 7) Records of Biennial Tune-Up 0.5 0.5 0.25 1,783 445.750 44.580 22.290 $49,309.22

 E. Personnel Training N/A

 F. Time for Audits N/A

Subtotal for Recordkeeping Requirements 25,333 $2,436,827

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 121,292 $11,667,220

Notes:

N/A – Not Applicable

a On average, over the 3-year period of this ICR, we estimate 4,119 existing large solid boilers (i.e., biomass- and coal-fired boilers >10 MMBtu/hr) at 2,059.5 

facilities will be subject to the rule. We also estimate 20 new boilers at 10 facilities per year, all of which are biomass-fired, for a total of 4,139 boilers at 2,069.5 
20

facilities.

b This ICR uses the following labor rates: $99.16 for technical, $127.43 for managerial, and $50.88 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, December 2013, “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 This burden applies to new sources only. The burden on existing sources to read and understand rule requirements and submit an initial notifications was 

incurred during a previous ICR period.

d This burden applies to existing large solid fuel boilers only. All existing sources were required to complete the energy audit by the conclusion of the previous 

ICR period; therefore, no new or existing sources will incur this burden over the next three years.

e Cost per occurrence for certified energy audit professionals includes a phone screening to discuss the facility prior to a visit, a 2- to 4-hour site visit, and an 

additional 2 to 4 hours to prepare a follow-up report on recommendations and findings. Cost depends on whether the source is industrial or commercial. It is 

assumed that 10% of sources will be industrial and 90% will be commercial.

f Only existing and new large coal boilers are subject to numerical mercury (Hg) and carbon monoxide (CO) limits, while new large coal and biomass boilers are 

subject to particulate matter (PM) limits.

g All projected large solid fuel boilers are expected to comply through stack testing instead of the fuel testing compliance option.

h Only boilers <30 MMBtu/hr that are not subject to limits under the NSPS (40 CFR Part 60 Subparts Db, Dc) will incur additional testing, monitoring, 

recordkeeping and reporting costs under this rule. It is estimated that 11 boilers (5.5 facilities, assuming 2 boilers per facility) will be subject to additional 

testing.

i

Sources demonstrating compliance with any applicable emission limits through stack testing must develop a site-specific monitoring plan. All new large solid 

fuel units are expected to develop this plan.

j All new biomass boilers >10 MMBtu/hr are expected to meet PM limits with an electrostatic precipitator (ESP); therefore, those sources will install opacity 

monitors.

k All new coal boilers >10 MMBtu/hr are expected to install fabric filters equipped with bag leak detection (BLD) systems instead of opacity monitors. No new

large coal boilers are projected over the three-year ICR period.

l Only existing large biomass boilers are subject to biennial tune-ups.

m

It is assumed that no affirmative defense claims will be filed over the three-year ICR period.

n

It is assumed that facilities must already maintain records on boiler insurance and/or maintenance scheduling; therefore, no new record system would be 

required.
21

Table 1B: Annual Respondent Burden and Cost – Existing and New Large Liquid Fuel Boilers, NESHAP for Industrial, 

Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal)

Burden Item

A B C D E F G H

Technical 

PersonHours per 

Occurrence

Occurrences 

per 

Respondent 

per Year

Technical 

Person-Hours 

per Respondent 

per Year 

(C=AxB)

Respondents 

per Year a

Technical 

Hours 

per Year 

(E=CxD)

Clerical 

Hours 

per Year 

(F=Ex0.10)

Management 

Hours 

per Year 

(G=Ex0.05)

Total Cost 

per Year 

($) b

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

 A. Read and Understand Rule Requirementsc40 1 40 81.17 3,247 325 162 $359,159.39

 B. Required Activities

 1) Conduct Energy Audit

 a) Industriald, e 20 1 20 0 0 0 0 $0

 b) Commerciald, e 20 1 20 0 0 0 0 $0

 2) Initial Stack Test and Report (PM)f12 1 12 81.17 974.04 97.4 48.7 $107,747.36

 3) Triennial Stack Test and Report (PM)f12 0.33 3.96 405.84 1,607.13 160.71 80.4 $177,780.21

 4) Continuous Parameter Monitoring

 a) Establish Site-specific monitoring plang40 1 40 81.17 3,246.80 324.68 162.3 $359,159.39

 b) Opacity (All Sources with ESPs)

 i) Initial 10 1 10 81.17 811.70 81.17 40.6 $89,790.49

 ii) Annual 10 1 10 405.84 4,058.40 405.84 202.9 $448,938.18

 c) BLD System Operation (All Sources with

 Fabric Filters)

 i) Initial 10 1 10 7.5 75 7.5 3.75 $8,296.46

 ii) Annual 10 1 10 15 150 15 7.5 $16,592.93

 5) Biennial Tune-Up 12 0.5 6 5,020.3 30,122 3,012.2 1,506.10 $3,332,078.6

 C. Create Information N/A

 D. Gather Information N/A

 E. Report Preparation

 1) Initial Notification that Source is Subject 2 1 2 81.17 162.34 16.23 8.12 $17,958.15

 2) Notification of Compliance Status 8 1 8 81.17 649.36 64.94 32.47 $71,832.34

 3) Initial Report on Results of Energy Auditd5 1 5 0 0 0 0 $0

 4) Annual Compliance Report 30 1 30 405.84 12,175.2 1,217.52 608.76 $1,346,814.54
22

Burden Item

A B C D E F G H

Technical 

PersonHours per 

Occurrence

Occurrences 

per 

Respondent 

per Year

Technical 

Person-Hours 

per Respondent 

per Year 

(C=AxB)

Respondents 

per Year a

Technical 

Hours 

per Year 

(E=CxD)

Clerical 

Hours 

per Year 

(F=Ex0.10)

Management 

Hours 

per Year 

(G=Ex0.05)

Total Cost 

per Year 

($) b

 5) Biennial Compliance Report 5 0.5 2.5 5,020.3 12,550.83 1,255.08 627.54 $1,388,366.20

 6) Affirmative Defenseh30 1 30 0 0 0 0 $0

Subtotal for Reporting Requirements 80,304 $7,724,514

4. Recordkeeping Requirements

 A. Read Instructions See 3A

 B. Implement Activities N/A

 C. Develop Record Systemi N/A

 D. Record Information

 1) Records of Operating Parameter Values 20 1 20 5,020.33 100,406.6 10,040.66 5,020.33 $11,106,927.89

 2) Records of Deviations 15 1 15 5,020.33 75,304.95 7,530.5 3,765.25 $8,330,196.49

 3) Records of Stack Tests 2 1 2 5,020.33 10,040.66 1,004.07 502.03 $1,110,692.61

 4) Records of Monitoring Device Calibrations 2 1 2 5,020.33 10,040.66 1,004.07 502.03 $1,110,692.61

 5) Records of All Compliance Reports Submitted 2 2 4 5,020.33 20,081.32 2,008.13 1,004.07 $2,221,385.99

 6) Records of Monthly Fuel Use 0.5 12 6 5,020.33 30,121.98 3,012.2 1,506.1 $3,332,078.60

 7) Records of Biennial Tune-Up 0.5 0.5 0.25 5,020.33 1,255.08 125.51 62.75 $138,835.91

 E. Personnel Training N/A .

 F. Time for Audits N/A

Subtotal for Recordkeeping Requirements 284,339 $27,350,810

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 364,643 $35,075,324

Notes:

N/A – Not Applicable

a On average, over the 3-year period of this ICR, we estimate 9,878 existing large liquid boilers (i.e., units >10 MMBtu/hr) at 4,939 facilities will be subject to the 

rule. We also estimate 162 new boilers at 81 facilities per year, for a total of 10,040 boilers at 5,020 facilities.

b This ICR uses the following labor rates: $99.16 for technical, $127.43 for managerial, and $50.88 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, December 2013, “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 This burden applies to new sources only. The burden on existing sources to read and understand rule requirements and submit an initial notifications was 

incurred during a previous ICR period.

d This burden applies to existing large liquid fuel boilers only. All existing sources were required to complete the energy audit by the conclusion of the previous 

ICR period; therefore, no new or existing sources will incur this burden over the next three years.

e Cost per occurrence for certified energy audit professionals includes a phone screening to discuss the facility prior to a visit, a 2- to 4-hour site visit, and an 
23

additional 2 to 4 hours to prepare a follow-up report on recommendations and findings. Cost depends on whether the source is industrial or commercial. It is 

assumed that 10% of sources will be industrial and 90% will be commercial.

f All projected large liquid fuel boilers are expected to comply through stack testing instead of the fuel testing compliance option. Only units <30 MMBtu/hr that 

are not subject to PM limits under the NSPS (40 CFR Part 60 Subparts Db, Dc) will incur additional testing, monitoring, recordkeeping and reporting costs under 

this rule.

g

Sources demonstrating compliance with any applicable emission limits through stack testing must develop a site-specific monitoring plan. All new large liquid 

fuel units are expected to develop this plan.

h

It is assumed that no affirmative defense claims will be filed over the three-year ICR period.

i

It is assumed that facilities must already maintain records on boiler insurance and/or maintenance scheduling; therefore, no new record system would be required.
24

Table 1C: Annual Respondent Burden and Cost – Existing and New Small Solid Fuel Boilers, NESHAP for Industrial, 

Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal)

Burden Item

A B C D E F G H

Technical 

PersonHours per 

Occurrence

Occurrences 

per 

Respondent 

per Year

Technical 

Person-Hours 

per Respondent 

per Year (C=AxB)

Respondents 

per Year a

Technical 

Hours 

per Year 

(E=CxD)

Clerical 

Hours 

per Year 

(F=Ex0.10)

Management 

Hours 

per Year 

(G=Ex0.05)

Total Cost 

per Year 

($) b

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

 A. Read and Understand Rule Requirementsc40 1 40 49.17 1,966.8 196.68 98.34 $217,566.43

 B. Required Activities

 Biennial Tune-Up 12 0.5 6 5,560.33 33,361.98 3,336.20 1,668.1 $3,690,485.78

 C. Create Information N/A

 D. Gather Information N/A

 E. Report Preparation

 1) Initial Notification that Source is Subject 2 1 2 49.17 98.34 9.83 4.92 $10,878.50

 2) Notification of Compliance Status 8 1 8 49.17 393.36 39.34 19.67 $43,513.74

 3) Biennial Compliance Report 5 0.5 2.5 5,560.33 13,900.83 1,390.08 695.04 $1,537,702.52

Subtotal for Reporting Requirements 57,180 $5,500,147

4. Recordkeeping Requirements

 A. Read Instructions See 3A

 B. Implement Activities N/A

 C. Develop Record Systemd N/A

 D. Record Information

 1) Records of All Compliance Reports Submitted 2 1 2 5,560.33 11,120.66 1,112.07 556.03 $1,230,161.67

 2) Records of Biennial Tune-Up 0.5 0.5 0.25 5,560.33 1,390.08 139.01 69.5 $153,769.55

 E. Personnel Training N/A

 F. Time for Audits N/A

Subtotal for Recordkeeping Requirements 14,387 $1,383,931

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 71,567 $6,884,078

Notes:

N/A – Not Applicable

a On average, over the 3-year period of this ICR, we estimate 11,022 existing small solid boilers (i.e., units <10 MMBtu/hr) at 5,511 facilities will be subject to the 

rule. We also estimate 98 new boilers at 49 facilities per year, for a total of 11,120 boilers at 5,560 facilities.
25

b This ICR uses the following labor rates: $99.16 for technical, $127.43 for managerial, and $50.88 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, December 2013, “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 This burden applies to new sources only. The burden on existing sources to read and understand rule requirements and submit initial notifications was incurred 

during a previous ICR period.

d

It is assumed that facilities must already maintain records on boiler insurance and/or maintenance scheduling; therefore, no new record system would be 

required.
26

Table 1D: Annual Respondent Burden and Cost – Existing and New Small Liquid Fuel Boilers, NESHAP for Industrial, 

Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal)

Burden Item

A B C D E F G H

Technical 

PersonHours per 

Occurrence

Occurrences 

per 

Respondent 

per Year

Technical 

Person-Hours 

per Respondent 

per Year 

(C=AxB)

Respondents 

per Year a

Technical 

Hours 

per Year 

(E=CxD)

Clerical 

Hours 

per Year 

(F=Ex0.10)

Management 

Hours 

per Year 

(G=Ex0.05)

Total Cost

per Year

($) b

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

 A. Read and Understand Rule Requirementsc40 1 40 989.5 39,580 3,958 1,979 $4,378,320

 B. Required Activities

 Biennial Tune-Up 12 0.5 6 84,334.5 506,007 50,600.7 25,300.35 $55,974,241

 C. Create Information N/A

 D. Gather Information N/A

 E. Report Preparation

 1) Initial Notification that Source is Subject 2 1 2 989.5 1,979 197.9 98.95 $218,916

 2) Notification of Compliance Status 8 1 8 989.5 7,916 791.6 395.8 $875,664

 3) Biennial Compliance Report 5 0.5 2.5 84,334.5 210,836.25 21,083.63 10,541.81 $23,322,600

Subtotal for Reporting Requirements 881,266 $84,769,742

4. Recordkeeping Requirements

 A. Read Instructions See 3A

 B. Implement Activities N/A

 C. Develop Record Systemd N/A

 D. Record Information

 1) Records of All Compliance Reports Submitted 2 1 2 84,335 168,669 16,866.9 8,433.45 $18,658,080

 2) Records of Biennial Tune-Up 0.5 0.5 0.25 84,335 21,083.63 2,108.36 1,054.18 $2,332,260

 E. Personnel Training N/A

 F. Time for Audits N/A

Subtotal for Recordkeeping Requirements 218,216 $20,990,341

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 1,099,482 $105,760,083

Notes:

N/A – Not Applicable

a On average, over the 3-year period of this ICR, we estimate 166,690 existing small liquid boilers (i.e., units <10 MMBtu/hr) at 83,345 facilities will be subject to 

the rule. We also estimate 1,979 new boilers at 989.5 facilities per year, for a total of 168,669 boilers at 84,334.5 facilities.
27

b This ICR uses the following labor rates: $99.16 for technical, $127.43 for managerial, and $50.88 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, December 2013, “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 This burden applies to new sources only. The burden on existing sources to read and understand rule requirements and submit initial notifications was incurred 

during a previous ICR period.

d

It is assumed that facilities must already maintain records on boiler insurance and/or maintenance scheduling; therefore, no new record system would be 

required.
28

Table 2: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources 

(40 CFR Part 63, Subpart JJJJJJ) (Renewal).

Burden Item

A B C D E F G

Technical 

PersonHours per 

Occurrence

Occurrences 

per Year

Technical PersonHours 

per Respondent 

per Year (C=AxB)

Technical 

Hours per 

Year (D=C)

Management 

Hours 

per Year 

(E=Dx0.05)

Clerical 

Hours 

per Year 

(F=Dx0.10)

Total Cost

per Year 

($) a

1. Read and Understand Rule Requirementsb40 0 0 0 0 0 $0

2. Enter and Update Information into Agency Recordkeeping Systemc2 1,129.84 2,259.68 2,259.68 112.98 225.97 $117,106.59

3. Required Activities

 a) Observe Initial Stack/Performance Testd40 83 3,320 3,320 166 332 $172,057.34

 b) Observe Repeat Performance Teste40 8.3 332 332 16.6 33.2 $17,205.73

 c) Review Operating Parametersf2 83 166 166 8.3 16.6 $8,602.87

 d) Review Continuous Parameter Monitoringg2 5,316 10,632 10,632 531.6 1,063.2 $550,998.08

4. Excess Emissions Enforcement Activities and Inspectionsh24 8.30 199.2 199.2 9.96 19.92 $10,323.44

5. Notification Requirements

 a) Review Initial Notification that Sources are Subject to the Standardc2 1,129.84 2,259.68 2,259.68 112.98 225.97 $117,106.59

 b) Review Notification of Initial Performance Tests and Review Test Planf20 83 1,660 1,660 83 166 $86,028.67

 c) Review Notification of Compliance Statusc2 1,129.84 2,259.68 2,259.68 112.98 225.97 $117,106.59

6. Reporting Requirements 0

 a) Review Annual Compliance Report 4 2,475.34 9,901.36 9,901.36 495.07 990.14 $513,133.26

 b) Review Biennial Compliance Report 2 48,349.08 96,698.16 96,698.16 4,834.91 9,669.82 $5,011,334.

02

 c) Review Initial Report on Energy Audit Resultsi2 0 0 0 0 0 $0

7. Travel Expenses for Performance Tests Observedj$100,795.2

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 149,141 $6,821,798

Notes:

N/A – Not Applicable

a This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel 

Management (OPM) 2013 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.

b No burden will be incurred over the three-year ICR period, as this was a one-time requirement during the previous ICR period.

c All new sources must submit initial notifications and notifications of compliance status, regardless of subcategory.

d

It is assumed that EPA will observe 20% of initial performance tests.

e

It is assumed that 10% of initial performance tests will be repeated, which will be observed by EPA.

f The number of occurrences is based on the number of new facilities that will test and set/submit operating limits. All new sources must submit operating limits, 
29

regardless of subcategory.

g The number of occurrences is based on the number of facilities maintaining records of control device parameters.

h

It is assumed that 10% of new facilities will have exceedances, requiring EPA enforcement.

i All existing sources at the time of promulgation of the standard were required to complete the energy audit by the conclusion of the previous ICR period; 

therefore, no new or existing sources will incur this burden over the next three years.

j The total cost is based on the number of performance tests observed by EPA multiplied by the cost of each trip. Based on EPA experience with other 

rulemakings, each trip is estimated to be 3 days x ($110 hotel + $58 meals/incidentals) + ($600 round trip) = $1,104 per trip.