June 7, 2010

MEMORANDUM

SUBJECT:	Inadvertent Error in the Preamble to the Proposed National
Emission Standards for Hazardous Air Pollutants for Area Sources: 
Industrial, Commercial, and Institutional Boilers

FROM:	Mary K. Johnson

Project Lead

Office of Air and Radiation 

TO:		Docket ID No.  EPA-HQ-OAR-2006-0790

We have identified an inadvertent error in the burden estimates for the
proposed National Emission Standards for Hazardous Air Pollutants for
Area Sources:  Industrial, Commercial, and Institutional Boilers, which
was signed on April 29, 1010.  Specifically, the burden estimates
included in the Paperwork Reduction Act section of the preamble (75 Fed.
Reg. 31896) were preliminary estimates, and the preamble does not
reflect the updated burden estimates.  The current burden estimates
associated with the information collection activities of the proposed
rule are set forth in the Supporting Statement (see docket item
EPA-HQ-OAR-2006-0790-0031).  

The attached redline/strike-out version of the affected preamble section
(i.e., page 31918) identifies the errors and shows the corrected
estimates. 

cc:  Robert J. Wayland

Attachment

The annual monitoring, reporting, and recordkeeping burden for this
collection (averaged over the first 3 years after the effective date of
the standards) is estimated to be $523 551 million.  This includes 3.6
million labor hours per year at a cost of $336 million and total
non-labor capital costs of $186 215 million per year.  This estimate
includes initial and annual performance tests, conducting and
documenting an energy assessment, conducting and documenting a tune-up,
semiannual excess emission reports, maintenance inspections, developing
a monitoring plan, notifications, and recordkeeping.  Monitoring,
testing, tune-up and energy assessment costs were also included in the
cost estimates presented in the control costs impacts estimates in
section VI.B of this preamble.  The total burden for the Federal
government (averaged over the first 3 years after the effective date of
the standard) is estimated to be 767,403 hours per year at a total labor
cost of $37.6 million per year.  

