SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart D) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart D) (Renewal), 

EPA ICR Number 1052.10, OMB Control Number 2060-0026

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Fossil Fuel Fired Steam Generating 

Units (40 CFR Part 60, Subpart D) were proposed on August 17, 1971, promulgated on 

December 23, 1971, amended January 20, 2011, and most recently amended on February 16,

2012. The regulations apply to each fossil fuel fired steam generating unit with heat input rate of 

73 megawatts (MW) (250 MMbtu/hr) or more, which commenced construction, reconstruction, 

or modification after August 17, 1971. Subpart D regulations apply to both electric utility and 

industrial boilers. This regulation was supplanted by NSPS subpart Da for electric utility steam 

generating units in 1978, and for industrial-institutional-commercial boilers in 1986. This 

information is being collected to assure compliance with 40 CFR part 60, subpart D.

In general, all NSPS 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 NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least two 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, an average of 660 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. Electric 

utility boilers, constructed after September 1978, are subject to subpart Da, and industrial, 

commercial, and institutional boilers, constructed after June 19, 1986, are subject to subpart Db. 

Therefore, there have been no new subpart D units since 1986; and new units are not expected in 

the future.

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

without any Terms of Clearance.
2

The burden to the “Affected Public” may be found in Table 1: Annual Respondent 

Burden and Cost – NSPS for Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart 

D) (Renewal). The burden to the “Federal Government” burden is attributed entirely to work 

performed by federal employees or government contractors and may be found below in Table 2: 

Average Annual EPA Burden and Cost – NSPS for Fossil Fuel Fired Steam Generating Units (40 

CFR Part 60, Subpart D) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years.

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, sulfur dioxide (SO2), particulate matter (PM), and 

nitrogen oxides (NOx) emissions from fossil fuel fired steam generating units cause or contribute 

to air pollution that may reasonably be anticipated to endanger public health or welfare. 

Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart D.
3

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. The performance stack test usually requires 

three 1-hour test runs using the EPA reference test method to demonstrate compliance. Subpart 

D requires only one performance test (the initial compliance stack test). Continuous emission 

monitors are used to ensure compliance with the standard at all times.

The notifications required in the standard are used to inform the Agency or delegated 

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

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

installed and operated and if the standard is being met. The performance test may also be 

observed.

The required semiannual reports are used to determine periods of excess emissions, 

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

determinations.

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

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart D.

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 (77 FR 47631) on August 9, 2012. 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 
4

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 the EPA Office of Compliance. OTIS is the EPA database for the 

collection, maintenance, and retrieval of all compliance data. 

Consultations with industry representatives (i.e., respondents) were conducted to 

determine if there is any way for EPA to reduce the recordkeeping and reporting burden or 

improve the language in the standard to make it easier to comply. In developing this ICR, EPA 

contacted: 1) the Council of Industrial Boiler Owners, at (540) 349-9043; and 2) the American 

Boiler Manufacturers Association at (703) 356-7172.

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

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 with 

the Part 70 permit program and the five-year statute of limitations on which the permit program 

is based. The retention of records for five years allows EPA to establish the compliance history 

of a source, any pattern of non-compliance, and to determine the appropriate level of 

enforcement action. EPA has found that the most flagrant violators have violations extending 

beyond the five years. In addition, EPA would be prevented from pursuing the violators due to 

the destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 
5

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 fossil fuel fired 

steam generating units. The United States Standard Industrial Classification (SIC) codes, and 

their corresponding North American Industry Classification System (NAICS) codes, for fossil 

fuel fired steam generating units are provided in the following table.

Standard (40 CFR Part 60, Subpart D)

SIC 

Codes

NAICS 

Codes

Oil and Gas Extraction 13 211

Utilities 49 221

Fossil Fuel Electric Power Generation 49 221112

Electric Power Transmission, Control, and Distribution 491 22112

Leather and Allied Product Manufacturing 31 316

Wood Product Manufacturing 24 321

Paper Manufacturing 26 322

Petroleum and Coal Products Manufacturing 29 324

Chemical Manufacturing 28 325

Plastics and Rubber Products Manufacturing 30 326

Primary Metal Manufacturing 33 331

Fabricated Metal Product Manufacturing 34 332

Transportation Equipment Manufacturing 37 336

Miscellaneous Manufacturing 39 339

Educational services 82 611

Hospitals 806 622

American Indian and Alaska Native Tribal Governments 8423 921150
6

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Fossil 

Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart D). 

A source must make the following notifications/reports:

Notifications/Reports

Construction/reconstruction date 60.7(a)(1) 

Actual startup date 60.7(a)(3) 

Initial performance test results 60.8 (a)

Initial performance test 60.8(d)

Demonstration of continuous monitoring system 60.7(a)(5)

Opacity test notification 60.7(a)(6)

Physical or operational change 60.7(a)(4)

Excess emissions and monitoring system performance semiannual 

report 60.7(c), 60.45(g)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, malfunctions, periods where the continuous 

monitoring system is inoperative

60.7(b)

Maintain records for two years 60.7(f)

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 
7

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, certify, maintain, and operate continuous monitoring systems (CMS) for opacity, SO2, 

NOx (or, alternatively, a CO continuous emissions monitoring systems (CEMS) rather than 

continuous opacity monitoring system (COMS)), and either O2 or CO2 or a fuel sampling and 

analysis system.

Perform initial performance test to demonstrate compliance.

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.

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.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., a 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.
8

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests.

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 two

years.

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses) affected by this regulation.
9

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Fossil Fuel Fired 

Steam Generating Units (40 CFR Part 60, Subpart D) (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. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 70,777 (Total Labor Hours from Table 1 below). 

These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the NSPS 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 $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

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

2012, “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 standards are both labor costs which are addressed elsewhere in this ICR and the costs 
10

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 monitor(s) 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)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

SO2, PM, 

and NOx

$200,000 0 $0 $15,000 660 $9,900,000

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table.

The total operation and maintenance (O&M) costs for this ICR are $9,900,000. This is 

the total of column G. 

 The average annual cost for both capital/startup and operation and maintenance 

costs to industry over the next three years of the ICR is estimated to be $9,900,000. These 

are the recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as 

the examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$89,138.

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), 2012 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 
11

based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Fossil Fuel 

Fired Steam Generating Units (40 CFR Part 60, Subpart D) (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

660 existing respondents will be subject to the standards. It is estimated that no additional 

respondents per year will become subject. This is because electric utility boilers constructed 

after September 1978 are subject to subpart Da, while industrial, commercial, and institutional 

boilers constructed after June 19, 1986 are subject to subpart Db. Therefore, there have been no 

new subpart D units since 1986; and new units are not expected in the future. The overall 

average number of respondents, as shown in the table below is 660 per year.

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

years covered by this ICR.

Number of Respondents

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)

1 0 660 0 0 660

2 0 660 0 0 660

3 0 660 0 0 660

Average 0 660 0 0 660

1

New respondent 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 660. 

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

Semiannual Report 660 2 N/A 1,320

Total 1,320

The number of Total Annual Responses is 1,320.

The total annual labor costs are $6,853,220. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Fossil Fuel Fired 

Steam Generating Units (40 CFR Part 60, Subpart D) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 70,777 at a cost of $6,853,220. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for 

Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart D) (Renewal).

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

information is estimated to average 54 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $9,900,000. 

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

Maintenance (O&M) Costs.

(ii) The Agency Tally

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

1,978 labor hours at a cost of $89,138. See below Table 2: Average Annual EPA Burden and 

Cost – NSPS for Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart D) 

(Renewal).

6(f) Reasons for Change in Burden

There is an increase in respondent burden from the most recently approved ICR due to an 
13

adjustment of respondent labor hours. The previous ICR assumed that labor hours accounted for 

all technical, managerial, and clerical hours. To be consistent with the estimation methodology

used in other ICRs, this ICR assumes that labor hours account for technical hours only. Clerical 

and managerial hours require additional time, and equal 10 and 5 percent of technical hours, 

respectively. This ICR updates these labor hours and their associated labor rates, resulting in an 

increase to total labor cost.

There is a decrease in Agency burden from the most recently approved ICR. This 

situation is due to adjustments to the number of respondents and to the frequency of the 

Agency’s review of sulfur dioxide compliance reports. The previous ICR estimated an Agency

burden for 732 respondents, which was inconsistent with its estimate of respondent universe of 

660 sources. This ICR adjusts the number of respondents so that it is consistent with the 

estimated number of respondents (i.e., 660). Also, the previous ICR assumed quarterly review of 

sulfur dioxide compliance reports. This situation is inconsistent with subpart D reporting 

requirements, and resulted in an estimated number of annual responses that was inconsistent with 

the previous ICR’s estimate of 1,320 responses per year. This ICR corrects the review frequency

associated with sulfur dioxide compliance reports from quarterly to semiannually, such that it is 

consistent with the estimated number of annual responses (i.e., 1,320).

6(g) Burden Statement

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

is estimated to average 54 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.

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-2012-0497. 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 
14

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA 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-2012-0497 and OMB Control Number 2060-0026 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost –NSPS for Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart

 D) (Renewal)

Burden Item

A B C D E F G H

Person 

hours per 

occurrence

Number of 

occurrences 

per 

respondent 

per year

Person 

hours per 

respondent 

per year 

(C=AxB)

Respondents 

per year

a

Technical 

personhours per 

year 

(E=CxD)

Management 

person hours 

per year 

(Ex0.05)

Clerical 

person 

hours per 

year (Ex0.1)

Total costs 

per year

($) b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Read instructions c

N/A

 B. Required activities

 Initial performance test c

N/A

 C. Create information c

N/A

 D. Gather Existing Information

Included in 

3E

 E. Write report

 Notification of construction/ reconstruction c

N/A

 Notification of anticipated/actual startup c

N/A

 Notify of emission test c N/A

 Report of initial emission test c

N/A

 Excess emissions report d

1 2 2 660 1,320 66 132 $146,985.96

Subtotal Reporting Requirements 1,518

4. Recordkeeping Requirements

 A. Read instructions

Included in 

3A

 B. Plan activities

Included in 

4C

 C. Implement activities

Included in 

3B
16

Burden Item

A B C D E F G H

Person 

hours per 

occurrence

Number of 

occurrences 

per 

respondent 

per year

Person 

hours per 

respondent 

per year 

(C=AxB)

Respondents 

per year

a

Technical 

personhours per 

year 

(E=CxD)

Management 

person hours 

per year 

(Ex0.05)

Clerical 

person 

hours per 

year (Ex0.1)

Total costs 

per year

($) b

 D. Develop record system N/A

 E. Time to check computer system and calibrate 

continuous monitors e

0.25 365 91.25 660 60,225 3,011.25 6,022.5 $6,706,234.43

 F. Time to Train Personnel N/A

 G. Time For Audits N/A

Subtotal Recordkeeping Requirements 69,258.75

TOTAL LABOR BURDEN AND COST

(rounded)

70,777 $6,853,220

Note: Subpart D was most recently amended on January 20, 2011. The regulations included alternate testing and monitoring methods, but no additional 

recordkeeping or reporting requirements were added. The amendment revised testing requirements for owners/operators of steam generating units that 

elect to install particulate matter continuous emissions monitoring systems, and revised the opacity monitoring requirements for owners/operators subject 

to an opacity standard that are exempt from the requirement to install a continuous opacity monitoring system. 

Assumptions:

a.

 We have assumed that the average number of respondents that will be subject to the rule will be 660. There will be no additional new sources that will become 

subject to the rule over the three-year period of this ICR.

b.

 This ICR uses the following labor rates: Managerial $121.44 ($57.83+ 110%); Technical $100.23 ($47.73 + 110%); and Clerical $50.51 ($24.05 + 110%).

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “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. This ICR assumes that Managerial hours are 5% of Technical hours, and Clerical hours are 10% of Technical hours.

c.

 There have been no new subpart D units since 1986, and new units are not expected over the three-year period of this ICR; therefore, this burden item is not

applicable.

d.

 We assume that each source will submit a semiannual report due to excess emission and monitoring systems performance over the three-year period.

e.

 We assume that respondents conduct this activity on a daily basis, and that plant operations occur 365 days per year.
17

Table 2: Average Annual EPA Burden and Cost – NSPS for Fossil Fuel Fired Steam Generating Units (40 CFR Part 60,

Subpart D) (Renewal)

Burden Item

A B C D E F G H

EPA Hours 

per 

Occurrence

Number of 

occurrences 

per plant per 

year

EPA 

Person 

hour per 

year

Plants per 

year

a

Technical 

hours per 

year

Management 

hours per 

year

Clerical 

hours per 

year

Total cost 

per year

($) b

( A x B) (E = CxD) (F = Ex0.05) (G= Ex0.10)

Report Review

 Notification of construction N/A

 Notification of anticipated startup N/A

 Notification of actual startup N/A

Notification of Initial Test

 Sulfur dioxide c

N/A

 Particulate matter c N/A

 Nitrogen oxides c

N/A

Review Initial Test Results

 Sulfur dioxide c

N/A

 Particulate matter c

N/A

 Nitrogen oxides c N/A

Review Notification of CMS Demonstration

 Sulfur dioxide c N/A

 Particulate matter c

N/A

 Nitrogen oxides c N/A

Review CMS Performance Demonstration

 Sulfur dioxide c

N/A

 Particulate matter c N/A

 Nitrogen oxides N/A

Review excess emission reports d1 2 2 460 920 46 92 $47,678.54
18

Burden Item

A B C D E F G H

EPA Hours 

per 

Occurrence

Number of 

occurrences 

per plant per 

year

EPA 

Person 

hour per 

year

Plants per 

year

a

Technical 

hours per 

year

Management 

hours per 

year

Clerical 

hours per 

year

Total cost 

per year

($) b

( A x B) (E = CxD) (F = Ex0.05) (G= Ex0.10)

Review sulfur dioxide compliance reports d, e

 Coal-Fired units 2 2 4 133 532 26.6 53.2 $27,570.63

 Oil-Fired units 2 2 4 67 268 13.4 26.8 $13,888.97

Travel expenses N/A

TOTAL ANNUAL BURDEN AND COST 

(rounded) 1,978

$89,138

Assumptions:

.a.

 We have assumed that the average number of respondents that will be subject to the rule will be 660. There will be no additional new sources that will become 

subject to the rule over the three-year period of this ICR.

b.

 This ICR uses the following labor rates: Managerial $62.27 (GS-13, Step 5, $38.92 + 60%); Technical $46.21 (GS-12, Step 1, $28.88 + 60%); and Clerical 

$25.01 (GS-6, Step 3, $15.63 + 60%). These rates are from the Office of Personnel Management (OPM), 2012 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. This ICR assumes that Managerial 

hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.

c.

 There have been no new subpart D units since 1986, and new units are not expected over the three-year period of this ICR; therefore, this burden item is not

applicable.

d.

 We assume that approximately 70 percent of the sources monitor via CEM and that approximately 30 percent use fuel sampling and analysis.

e.

 Units using fuel sampling and analysis submit sulfur dioxide compliance reports instead of excess emission reports, which are based on CEM data. The figures

used in this category are based on research performed during regulation revision.