1

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 2028.08, 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 (Boiler MACT/Boilers NESHAP)

were 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 then finalized in December 2012 and published 

in January 2013. 

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 noncontinental 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 
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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 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.

Over the next three years, approximately 14,140 existing units at 1,700 facilities will be 

subject to the standard. We estimate an additional 618 new units at 78 facilities per year will 

become subject. This estimate is based on a 5-year industry projection conducted at the time of 

the final reconsideration; we assume a constant growth for all subcategories. 

The active (previous) ICR had the following Terms of Clearance (TOC): 

OMB is withholding approval at this time. Prior to publication of the final 

rule, the agency should provide a summary of any comments related to the 

information collection and their response, including any changes made to 

the ICR as a result of comments. In addition, the agency must enter the 

correct burden estimates. This action has no effect on any current 

approvals.

We have reviewed public comments on the reconsideration proposal and have revised our 

inventory of affected units in response to comments received. Further, in response to public 

comments and petitions for reconsideration, we have adopted several changes to the compliance 

requirements in the proposed reconsideration notice to minimize the burden on affected entities. 

All comments were reviewed and responded to prior to the publication of the final rule on 

January 31, 2013. In addition, we have consulted with industry on the burden related to the 

information collection.

The ‘Affected Public’ are owners and operators of boilers and in-direct fired process 

heaters that are subject to the NESHAP. The ‘burden’ to the “Affected Public” may be found in 

Tables 1.A.-12.C.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, 

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

attached below. The Federal Government ‘burden’ is attributed entirely to work performed by 

either Federal employees or government contractors and may be found in Tables 13.A.-13.C.: 

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

Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal), attached below.

2. Need for and Use of the Collection
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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 the standard ensure compliance with the 

applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance 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 the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed, operated, leaks are being detected and repaired, and the standards are being met. The 

performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 
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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, no 

duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (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 standard as it was being developed and the standard 

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. 

3(d) Effects of Less Frequent Collection

For sources with applicable emission limits, the Boilers NESHAP provides the option of 

demonstrating compliance through initial and periodic fuel analysis (for sources that burn fuels 
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with pollutant contents lower than the emission limits), through initial and annual stack testing, 

or through CEMS monitoring for CO. If a source can demonstrate that the fuel(s) burned in the 

boiler or process heater has a pollutant content that is less than the applicable emission limit, 

then the Boilers NESHAP requires that the source conduct initial fuel analyses, periodic fuel 

analysis, and initial and semiannual reporting. Sources that demonstrate compliance through 

performance testing must continuously monitor operating parameters and conduct periodic fuel 

analyses, and complete initial and semiannual reporting. The EPA chose the frequency of these 

activities to provide an adequate margin of assurance that affected facilities will not operate for 

extended periods in violation of the regulations.

The annual performance testing, where applicable, will ensure that the air pollution 

control device is operating properly and its performance has not deteriorated on an ongoing 

basis.

During the initial stack tests (for particulate matter (or total selected metals), mercury, 

hydrogen chloride, and carbon monoxide), the owner or operator must establish maximum or 

minimum values for each applicable operating parameter. Thereafter, the owner or operator 

must, in some cases, conduct annual stack tests for particulate matter (or total selected metals), 

mercury, hydrogen chloride, and carbon monoxide and must always continuously monitor the 

operating parameters. The activities associated with setting these site-specific operating limits 

include monitoring of the parameters during the performance test, reviewing and averaging the 

monitoring data, and, if necessary, calculating average values for fuel pollutant content. 

Although continuous monitoring of operating parameters cannot provide a direct measurement of 

emissions, it is less expensive than CEMS and the collected information can ensure that the 

boiler or process heater and associated air pollution control equipment are operated properly. 

Some facilities may also choose to comply with the alternative CO CEMS limit, whereby their 

CO emissions are continuously monitored. This information assures EPA and the public that the 

reductions envisioned by the Boilers NESHAP are being achieved. Less frequent monitoring 

would not ensure continuous compliance. In addition to demonstrating compliance with these 

emission limits, all large boilers and process heaters must conduct annual tune-ups as a work 

practice for controlling dioxin/furan emissions. They must report the findings of the tune-up in 

the semi-annual compliance report covering the period when the tune-up was conducted. 

The semiannual reporting requirement allows the submittal of required information and 

data on established operating parameters so that any potential problems can be identified in a 

timely fashion.

New and existing small (less than 10 mmBtu/hr) boilers firing solid, liquid, or gaseous 

fuels and all limited use (operates less than 876 hr/yr) boilers demonstrate compliance with the 

rule by conducting a biennial tune-up. Certain small units firing gaseous or light liquid fuels that 

have a design capacity of less than 5 mmBtu/hr are subject to tune-ups on a 5-year frequency. 

Similarly, limited use boilers which operate less than 100 hours per year qualify for tune-ups 

every five years. Since these frequencies are less than the semi-annual compliance report 

frequency typically required from sources in this source category, a biennial or five-year
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compliance report is required. These tune-up reports can be requested by the Administrator, but 

are otherwise not required to be submitted.

New and existing large Gas 1 boilers demonstrate compliance by conducting an annual 

tune-up. These boilers are thus required to submit annual compliance reports. Units firing 

gaseous fuels other than natural gas and refinery gas or other MACT regulated gas streams must 

demonstrate that those fuels meet the specification for Hg contained in the proposal in order to 

qualify under the Gas 1 subcategory. If the content of these constituents are not going to exceed 

the specifications, these units may conduct an initial testing and include a statement that the gas 

will not exceed the specification in the initial Notification of Compliance Status. If the gaseous 

fuel constituents will vary, the unit is required to conduct monthly testing and maintain records 

to demonstrate that the gaseous fuels meet the specifications. Monthly testing and recordkeeping 

at units with variable gas quality ensures continuous compliance.

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 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 typically 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 

and accepted, 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
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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. 2865/2869/2813/2869/2879/

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
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(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 63.7520

Notification of Compliance Status 63.7530

Initial Report on results of Energy Audit 63.7530

Annual Compliance Report 63.7550

Semi-annual Compliance Report 63.6650

Notification of Alternative Fuel Use 63.7545

A source must keep the following records:

Recordkeeping

Records of Operating Parameter Values 63.7555

Records of Startup, Shutdown, Malfunction 63.7555

Records of Stack 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.
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(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

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

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.

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.
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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. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The semiannual reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses 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 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.
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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, 

the EPA has determined that 151 of the 1,701 facilities with existing boilers or process heaters, 

or 9 percent of the total, affected by the regulation may be small entities.

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, 35 of the 

151 small entities have only small or limited use boilers and process heaters installed at the 

facilities. 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.

5(d) Collection Schedule

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

shown below in Table 1.A.-12.C.: 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 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 492,702 hours (Total Labor Hours from Tables

1.A-12.C.) below. 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
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(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%)

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.

(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 131 $27,002,675 $29,645,694 $56,648,368

New Large Solid Units 3 $2,005,198 $2,809,343 $4,814,541

Existing Small and Limited 

Use Solid Units 5 $0 $83,959 $83,959

New Small Solid Units 1 $0 $5,941 $5,941

Existing Large Liquid Units 67 $7,928,856 $5,484,851 $13,413,707

New Large Liquid Units 0 $0 $0 $0

Existing Small and Limited 

Use Liquid Units 46 $0 $817,455 $817,455

New Small Liquid Units 0 $0 $0 $0

Existing Large Gaseous 

Units 548 $207,903 $16,003,113 $16,211,016
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Capital/Startup vs. Operation and Maintenance (O&M) Costs

New Large Gaseous Units 33 $0 $2,256,875 $2,256,875

Existing Small and Limited 

Use Gaseous Units 903 $0 $12,778,737 $12,778,737

New Small Gaseous Units 41 $0 $1,204,605 $1,204,605

Total 1,778 $37,144,632 $71,090,573 $108,235,205

The total capital/startup costs for this ICR are $37,144,632. This is the total of column C

in the above table. 

The total operation and maintenance (O&M) costs for this ICR are $71,090,573. 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 $108,235,205. 

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 

$5,301,811. 

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 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Tables 13.A.-13.C.: 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

1,700 existing respondents (facilities) will be subject to the standard. It is estimated that an 
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additional 78 respondents per year will become subject. The overall average number of 

respondents, as shown in the table below, is 1,778 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

Subcategory

(A)

Number of New 

Respondents

(Facilities) per 

Year 1

(B)

Number of 

Existing 

Respondents

(Facilities) 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 3 131 0 0 134

Large Liquid 

Units 0 67 0 0 67

Large Gas 

Units 33 548 0 0 581

Small Solid 

Units 3 1 5 0 0 6

Small Liquid 

Units 0 46 0 0 46

Small Gas 

Units 41 903 0 0 944

TOTAL 78 1,700 0 0 1,778

1

New respondents include sources with constructed, reconstructed and modified affected facilities. The 78 new

facilities include includes 26 large solid units, 262 large gas units, 4 small solid units, and 326 small gas units per 

year.

2 This estimate represents the number of existing respondents at time of final rule promulgation. We assume all 

existing respondents will comply by Year 2 of this ICR. The 1,700 existing facilities include 1,091 large solid 

units, 570 large liquid units, 4,551 large gas units, 36 small solid units, 385 small liquid units, and 7,507 small gas 

units. 

3 We estimate only 1 new facility over the 3-year ICR period for this subcategory. 

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 1,778. 

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A) (B) (C) (D) (E)
15

Total Annual Responses

Boiler Type Number of 

Respondents

Number of 

Responses

(Average)

Number of Existing 

Respondents That 

Keep Records But Do

Not Submit Reports

Total Annual Responses

E=(BxC)+D

Existing Large Solid Units 131 2 0 262

New Large Solid Units 3 8 0 24

Existing Small Solid Units 5 1 0 5

New Small Solid Units 1 1 0 1

Existing Large Liquid Units 67 2.7 0 179

New Large Liquid Units 0 0 0 0

Existing Small Liquid Units 46 1 0 46

New Small Liquid Units 0 0 0 0

Existing Large Gaseous Units 548 2.2 0 1,208

New Large Gaseous Units 33 5 0 165

Existing Small Gaseous Units 903 1 0 903

New Small Gaseous Units 41 2.8 0 116

Total 2,909

The number of Total Annual Responses is 2,909. 

The total annual labor costs are $47,393,473. Details regarding these estimates may be 

found below in Tables 1.A.-12.C.: 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.A.-13.C. and summarized in an attachment. 

(i) Respondent Tally

The total annual labor hours are 492,702 hours, at a cost of $47,393,473. Details 

regarding these estimates may be found in Tables 1.A.-12.C.: Annual Respondent Burden and 

Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 

CFR Part 63, subpart DDDDD) (Renewal) – Years 2-4.

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

information is estimated to average 169 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $108,235,205. 

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs.

(ii) The Agency Tally
16

The average annual Agency burden and cost over next three years is estimated to be 

100,786 labor hours at a cost of $5,301,811. See below Tables 13.A.-13.C.: Average Annual 

EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and 

Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in the respondent burden and a decrease in the Agency burden in this 

ICR compared to the previous ICR. The change in the burden and cost estimates occurred 

because the previous ICR estimated the burden for the proposed rule. This ICR updates the 

burden estimates to reflect the reporting and recordkeeping requirements of the 2013 final 

reconsideration, which has been in effect for one year. We estimate that a portion of the existing 

sources have already complied with the initial requirements of the rule, and that all existing 

sources will comply by Year 2 of this ICR period (i.e. 3 years after rule promulgation). 

Additionally, this ICR uses updated labor rates from the Bureau of Labor Statistics to calculate 

all burden costs.

6(g) Burden Statement

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

is estimated to average 169 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

either 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.

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, 
17

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.