SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Industrial-Commercial-Institutional Steam Generating Units (40
CFR Part 60, Subpart Db) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Industrial-Commercial-Institutional Steam Generating Units (40
CFR Part 60, Subpart Db)

1(b)  Short Characterization/Abstract

	The New Source Performance Standards (NSPS) for the regulations
published at 40 CFR part 60, subpart Db for the pollutant sulfur dioxide
(SO2) were proposed on June 19, 1986, and promulgated on December 16,
1987.  These regulations apply to industrial-commercial-institutional
steam generating units (boilers) that commenced construction,
modification, or reconstruction after June 19, 1984, and that have a
heat input capacity from fuels combusted in the unit of greater than 29
MW (100 million Btu/hour).  The regulations were amended on February 27,
2006 (71 FR 9865), June 13, 2007 (72 FR 32710), and on January 28, 2009
(74 FR 5086).  This ICR is updated to reflect changes due to the 2007
and 2009 amendments.  The 2007 amendments added compliance alternatives,
revised certain recordkeeping and reporting requirements, corrected
technical and editorial errors, and updated the grammatical style of the
four D subparts.  The 2009 amendments clarified the intent for applying
and implementing specific rule requirements, provided additional
compliance alternatives, and corrected unintentional technical omissions
and editorial errors.  This information is being collected to assure
compliance with 40 CFR part 60, subpart Db.

	In general, all NSPS standards require initial notifications,
performance tests, and periodic reports.  Owners or operators 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 sources subject to NSPS.

	Any owner or 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 United States Environmental Protection
Agency (EPA) regional office.

Size of the Regulated Community

	In a study from 1979, EPA modeled the total capacity of United States
(U.S.) industrial/commercial boilers for 1980, 1985 and 2000, for
boilers with capacities greater than 29 MW (100 million BTU/hour)
(“Population and Characteristics of Industrial/Commercial Boilers in
the United States from 1979"; EPA Number PB80 - 150881).  This model
shows an increase of 4,139 new industrial/commercial boilers between
1985 and 2000 with capacities greater than 29 MW (100 million BTU/hour),
and these would be subject to NSPS Db.  Therefore, according to this
model there should be approximately 4,139 steam generating units (or
boilers) currently subject to NSPS subpart Db.  Assuming one boiler per
facility, the number of facilities subject to NSPS subpart Db would be
4,139.

	However, during the nitrogen oxide (NOx) NSPS revision, information on
industrial boilers subject to NSPS Db was obtained from three sources: a
best available technology/ lowest achievable emission rate database
search; copies of permits obtained from EPA regional offices; and
telephone contacts with EPA regions, state agencies, and boiler vendors.
 Based on the information obtained, as of 1995, only 45 NSPS Db boilers
were identified.  Since NSPS Db was in effect for ten years in 1995, 45
boilers is probably a low number and model projects indicate that it may
be far from the true regulated universe for 1995.  The Information
Collection Request (ICR) approved in 2000 estimated 957 facilities
subject to NSPS Db.  

	During the NOx NSPS revision mentioned above, an analysis was conducted
to determine the projected growth of new industrial boilers over the
period from 1996 to 2000.  This analysis showed that the growth rate
would be 76 new industrial boilers per year.  Therefore, using the
estimate from the ICR approved in 2000 of 957 sources, assuming a growth
rate of 76 new industrial boilers per year over the three-year period
since the last ICR, and assuming one boiler per facility, the 2003 ICR
estimated 1,185 existing NSPS Db facilities.  The 2006 ICR renewal
assumed no change in the total estimate of 1,185 existing NSPS Db
facilities. 

Growth Rate for the Next Three Years

	In the Industrial Boiler   SEQ CHAPTER \h \r 1 Maximum Achievable
Control Technology (MACT) rulemaking, a projection of new industrial,
commercial, and institutional boilers was performed for economic
analysis in October 2002.  This analysis showed that 134 industrial,
commercial, and institutional boilers would become subject to NSPS
subpart Db over the next three years (or 45 per year).  This is the most
recent growth projection available for these facilities.

	This ICR estimates the existing number of sources based on the 2003 ICR
estimate of 1,185 existing sources plus 270 new facilities over a
six-year period (assuming a growth rate of 45 facilities per year over
six years).  Therefore, this ICR is estimating that approximately 1,455
existing sources are currently subject to the regulation; and it is
estimated that an additional 45 new sources per year will become subject
to the regulation in the next three years.  

	The Office of Management and Budget (OMB) approved the currently active
ICR without any “Terms of Clearance.”

	The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost  - NSPS for
Industrial-Commercial-Institutional Steam Generating Units (40 CFR part
60, subpart Db).  The burden to the “Federal Government” is
attributed entirely to work performed by Federal employees or government
contractors; this burden may be found in Table 2: Average Annual EPA
Burden - NSPS for Industrial-Commercial-Institutional Steam Generating
Units (40 CFR part 60, subpart Db).

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, SO2, particulate matter (PM), and NOx
emissions from Industrial-Commercial-Institutional 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 Db.

2(b)  Practical Utility/Users of the Data

	The control of emissions of SO2, PM, and NOx from
Industrial-Commercial-Institutional Steam Generating units requires not
only the installation of properly designed equipment, but also the
operation and maintenance of that equipment.  Emissions of SO2, PM, and
NOx from Industrial-Commercial-Institutional Steam Generating units are
the result of operation of the affected facilities.  The subject
standards are achieved by the capture and/or reduction of SO2, PM, and
NOx emissions using control technologies such as sorbent injection
technologies and wet and dry scrubbers for SO2; cyclones, electrostatic
precipitators, and fabric filters for PM; and low NOx burners and
selective catalytic or noncatalytic reduction technologies for NOx.  

	The notifications required in the applicable regulations 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 the regulations are being met. 

	Performance test reports are needed as these are the Agency's record of
a source's initial capability to comply with the emission standards, and
serve as a record of the operating conditions under which compliance was
achieved.  Continuous emission monitors are used to ensure compliance
with the standards at all times.

	The information generated by the monitoring, recordkeeping and
reporting requirements described in this ICR is used by the Agency to
ensure that facilities affected by the NSPS continue to operate the
control equipment and achieve compliance with the regulation.  Adequate
monitoring, recordkeeping, and reporting are necessary to ensure
compliance with the applicable regulations, as required by the Clean Air
Act.  The collected information is also used for targeting inspections
and as evidence in legal proceedings.

The required quarterly or semiannual reports are used to determine
periods of excess emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

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

3(a)  Nonduplication

 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 (74 FR 38004) on July 30, 2009. 
No comments were received on the burden published in the Federal
Register. 

3(c)  Consultations

In determining the correct burden estimate associated with this ICR,
industry trade associations and other interested parties have been
provided an opportunity to comment on the burden associated with the
standard as it was being developed and in subsequent renewals of the
ICR.  It is our policy to review any comments received since the last
ICR renewal including those submitted in response to the first Federal
Register notice and respond appropriately.  EPA published an
announcement of a public comment period for the renewal of this ICR in
the Federal Register on July 30, 2009.  No comments were received on
respondent burden associated with the reporting and recordkeeping
requirements provided in this ICR.  

To determine the size of the regulated community and the rate of
industry growth, the EPA Office of Air Quality Planning and Standards
was consulted.  The Agency’s internal industry experts have been
consulted.  The Agency’s internal data sources and projections of
industry growth over the next three years also have been considered.

	Another source of information from the 2003 renewal was the information
provided by the industry.  Information provided in the industry reports
is located in the EPA’s AFS (Air Facility System) database.  In 2003,
approximately 1,230 respondents were subject to the regulation.

It should be noted that the 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.

For this renewal, EPA contacted a representative industry trade
organization to request a voluntary opinion as to the accuracy of the
burden estimates associated with this ICR and whether there is any way
to reduce the burden.  EPA contacted the Council of Industrial Boiler
Owners (CIBO, Bob Bessette, telephone: 703-530-9042); no comments were
received.

3(d)  Effects of Less Frequent Collection

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

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 (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

	Industrial-commercial-institutional boilers (also known as steam
generating units) are classified by type, fuel, and method of
construction.  The three main types are cast iron, fire tube, and water
tube.  These three categories of boilers are designed and manufactured
to meet specific applications and site requirements.  Unit size, design
pressure and temperature all depend on boiler application.  Each boiler
type may burn coal, oil, or natural gas, and increasingly are being
designed to burn more than one fuel type.

	All boilers subject to NSPS subpart Db are water tube boilers.  Water
tube boilers are used in a variety of applications ranging from
supplying large amounts of process steam to providing space heat for
industrial facilities, or commercial buildings.  Water tube boilers are
fueled by coal, 25 percent; oil, 32 percent, and natural gas, 43
percent.  Process steam accounts for the largest use of fuel to fire
boilers, using about one-third of all industrial fuel.

	The following industries use water tube boilers with capacities greater
than 29 MW (100 mmBtu/hr).  In EPA studies, energy usage was used to
estimate the potential for industry boiler usage.  The chemical and
paper industries use the most energy accounting for about a third of all
U.S. industrial fuel usage.  Petroleum refineries, steel and aluminum
manufacturers, and food processing industries use most of the remainder
of industrial fuel.  Other industries using smaller, but significant
amounts of fuel are the textiles, lumber, and rubber manufacturers, and
metal fabrication and transportation industries.  The other two
industries that would be expected to have boilers large enough to be
subject to NSPS subpart Db are office and shopping center heating and
boiler rentals.

	The respondents to the recordkeeping and reporting requirements are
facilities subject to NSPS subpart Db that commenced construction,
modification, or reconstruction after June 19, 1984, and that have a
heat input capacity from fuels combusted in the steam generating unit of
greater than 29 MW (100 mmBtu/hr).

Regulation	SIC Codes	NAICS Codes

40 CFR part 60, subpart Db	1531	23332

	2033	311421

	Major Group 22	Major Group 313

	Major Group 24	Major Group 321

	2611	322110

	Major Group 28	Major Group 325

	2911	324110

	Major Group 30	Major Group 326

	Major Group 33	Major Group 331

	Major Group 34	Major Group 332

	Major Group 37	Major Group 336

	7299	81299



4(b)  Information Requested

(i)  Data Items

	In this ICR, all the data that is recorded or reported is required by
NSPS for Industrial-Commercial-Institutional Steam Generating Units (40
CFR part 60, subpart Db).

	A source must make the following reports:

Reports for 40 CFR part 60, subpart Db 

Construction/reconstruction	60.7(a)(1)

Actual startup	60.7(a)(3), 60.49b(a)

Initial performance test results	60.8 (a), 60.49b(b)

Initial performance test	60.8(d)

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

Physical or operational change	60.7(a)(4)

Operating conditions for compliance with NOx standard	60.49b(c)

Monitoring results	60.49b(i)-(m) 

Annual Capacity Factor, Fuel Nitrogen Content, NOx Emission Tests
60.49b(q)

Fuel-based Compliance Alternative Report	60.49b(r)

Removal efficiency by fuel pretreatment and associated documentation
60.49b(n)

Excess emissions (semiannual)	60.7(c), 60.49b(h), 60.49b(w)

Quarterly reporting for Cytec Industries Fortier Plant’s C.AOG
incinerator, Westwego, Louisiana	60.49b(s)

Quarterly reporting for Rohm and Haas Kentucky Incorporated’s Boiler
Number 100, Louisville, Kentucky	60.49b(t)

Quarterly reporting for Merck & Co., Inc.’s Stonewall Plant, Elkton,
Virginia	60.49b(u)

Quarterly reporting for Weyerhaeuser Company’s No. 2 Power Boiler, New
Bern, North Carolina	60.49(x)

Quarterly reporting for INEOS USA’s AOGI, Lima, Ohio	60.49b(y)

Quarterly reporting (electronic)	60.49b(v)

	

	A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart Db

Startups, shutdowns, malfunctions, and periods when the continuous
monitoring system is inoperative.	60.7(b)

Fuel Monitoring	60.49b(d), 60.49b(r)

Nitrogen content of residual oil combusted	60.49b(e)

Opacity	60.49b(f)

Nitrogen oxide emission rates	60.49b(g)

Records are required to be retained at the facility for two years.
60.7(f), 60.49b(o)

Steam load	60.49b(p)

Fuel Receipts	60.49b(r)



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 20 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, certify, and operate Continuous Emission
Monitoring Systems for NOx, SO2, and opacity or alternative monitoring
methods (e.g., CO CEMS in place of using a COMS).

Perform initial performance test.

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.



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 Air Facility System (AFS).



5(b)  Collection Methodology and Management

	Following notification of startup, the reviewing authority might
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 the AFS which is
operated and maintained by the EPA Office of Compliance.  AFS 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 AFS 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 

According to the 2005 Economic Impacts Analysis for the Proposed NSPS
amendments in 2005 (see Docket ID: EPA-HQ-OAR-2005-0031-0059) 2 of the
17 or 12 percent of the projected new biomass units were expected to be
small entities.  Applying this percent to the respondent universe for
this ICR results in approximately 180 small entities impacted by this
ICR..

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 Industrial-Commercial-Institutional Steam Generating
Units (40 CFR part 60, subpart Db).

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
771,889 hours (Total Labor Hours from Table 1).  The recordkeeping hours
shown in Table 1 are 234,045.  The reporting requirement hours shown in
Table 1 are 537,844.  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	$114.77 ($54.65 + 110%)   

Technical	$97.59 ($46.47 + 110%)

Clerical	$48.26 ($22.98 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 2009, “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)

Continuous Monitoring Device	(B)

Startup Cost ($) for One Affected Facility	(C)

Number of New Affected Facilities to Startup	(D)

Total Startup 

(B X C)	(E)

Annual O&M Costs ($) for One Affected Facility	(F)

Number of Affected Facilities with O&M	(G)

Total O&M

(E X F)

SO2, PM, and NOx	$200,000	45	$9,000,000	$15,000	1,500	$22,500,000



The total capital/startup costs for this ICR are $9,000,000.  This is
the total of column D in the above table. 

The total operation and maintenance (O&M) costs for this ICR are
$22,500,000.  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 $31,500,000.  These are recordkeeping costs.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
estimated to be $27,885,868 (see Table 2).

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

	Managerial	$61.36 (GS-13, Step 5, $38.35 + 60%) 

	Technical	$45.52 (GS-12, Step 1, $28.45 + 60%)

	Clerical	$24.64 (GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personnel Management (OPM), 2009
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2: Annual Agency Burden and Cost - NSPS for
Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part
60, Subpart Db).

6(d)  Estimating the Respondent Universe and Total Burden and Costs

	Approximately 1,455 sources are currently subject to the regulation,
and it is estimated that an additional 45 sources per year will become
subject to the regulation in the next three years.

Respondent Universe and Number of Responses Per Year

Regulation Citation	(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Sources	(E)

Number of Respondents That Keep Records But Do Not Submit Reports	(F)

Total Annual Responses =

(AxB)+(CxD)+ E

40 CFR 60.49b (w)	36	2	1,164	2	0	2,400

40 CFR 60.49b (v)	9	4	291	4	0	1,200

Total	45

1,455

	3,600



	The number of total respondents is 1,500.  This number is the sum of
column A and column C of the Respondent Universe and Number of Responses
Per Year table.  This represents the number of existing sources and the
number of new sources averaged over the three-year period (i.e., the
number of new respondents over the three-year period divided by three
years).

	The number of Total Annual Responses is 3,600.

	The total annual labor costs are $63,338,557.  Details upon which this
estimate is based appear in Table 1: Annual Respondent Burden and Cost -
NSPS for Industrial-Commercial-Institutional Steam Generating Units (40
CFR Part 60, Subpart Db).

	The total annual capital and O&M costs to the regulated entities are
$31,500,000.

6(e)  Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2 below,
respectively, and summarized below.  

(i) Respondent Tally

The total annual labor hours are 771,889.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost -
NSPS for Industrial-Commercial-Institutional Steam Generating Units (40
CFR Part 60, Subpart Db) (below).  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 214 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $31,500,000.  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 777,014 labor hours at a cost of $27,885,868.  See Table
2: Annual Agency Burden and Cost - NSPS for
Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part
60, Subpart Db).

6(f)  Reasons for Change in Burden

The increase in burden from the most recently approved ICR is due to
adjustment.  Growth rate in the number of existing sources since
previous approved ICRs has been taken into account, along with projected
growth rate for the three years covered by this ICR.  The total number
of respondents has increased from 1,185 to 1,500 which results in a
larger number of respondents, responses, and burden hours. 

The increase in burden is also related to calculation errors in the
previous ICR calculations in Table 1: Annual Respondent Burden and Cost
- NSPS for Industrial-Commercial-Institutional Steam Generating Units
(40 CFR Part 60, Subpart Db).  Corrections have been made to Table 1 of
this ICR.

	The respondent and Agency labor costs have also increased.  Also, while
the previous ICR used only a technical rate, Tables 1 and 2 of this ICR
reflect burden and cost calculations expanded to include managerial and
clerical labor rates. 

	

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 214 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-2009-0528.  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), EPA
West, Room 3334, 1301 Constitution Avenue, N.W., Washington, D.C.  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, N.W., Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2009-0528 and OMB Control Number 2060-0072 in any
correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.Table 1: Annual Respondent Burden and Cost
- NSPS for Industrial-Commercial-Institutional Steam Generating Units
(40 CFR Part 60, Subpart Db)

Reporting and recordkeeping requirements	A

Person hours per occurrence	B

Annual occurrences per respondent	C

Annual person hours per respondent

(A x B)	D

Total number of respondents	E

Technical person hours  a	F

Clerical person hours  a	G

Manage-ment person hours  a	H

Total annual person hours

(C x D)	I

Total annual cost

1. Applicants	N/A

 	 	 	 

 	 

2. Survey and Studies	N/A

 	 	 	 

 	 

3. Reporting Requirements  b	 

 	 	 	 

 	 

A. Read Instructions  c	see 4A	 	 	 	 	 	 	   =sum (below) 
12,770 	 

B. Required Activities	 

 	 	 	 

 	 

Initial Performance Test:	 

 	 	 	 

 	 

PM  b	330	1	330	19	5,452.17	545.22	272.61	6,270	$589,677

24 hour test for Gas Units  c	250	1	250	26	5,652.17	565.22	282.61	6,500
$611,308

Repeat of Performance Test:	 

 	 	 	 

 	 

PM  b,  d	330	1	330	4	1,147.83	114.78	57.39	1,320	$124,143

24 hour tests for Gas Units  c,  d	250	1	250	5	1,086.96	108.70	54.35
1,250	$117,559

Report of Initial Performance Test:  c	 

 	 	 	 

 	 

SO2	16	1	16	13	180.87	18.09	9.04	208	$19,562

PM	16	1	16	19	264.35	26.43	13.22	304	$28,590

NOx	16	1	16	45	626.09	62.61	31.30	720	$67,714

Notification of CEMS Demonstration  c	 

 	 	 	 

 	 

SO2	2	1	2	13	22.61	2.26	1.13	26	$2,445

PM	2	1	2	19	33.04	3.30	1.65	38	$3,574

NOx	2	1	2	45	78.26	7.83	3.91	90	$8,464

Demonstration of CEMS  c	 

 	 	 	 

 	 

SO2	150	1	150	13	1,695.65	169.57	84.78	1,950	$183,392

PM	100	1	100	19	1,652.17	165.22	82.61	1,900	$178,690

NOx	350	1	350	45	13,695.65	1,369.57	684.78	15,750	$1,481,246

Repeat Demonstration of CEMS  c,  d	 

 	 	 	 

 	 

SO2	150	1	150	3	391.30	39.13	19.57	450	$42,321

PM	100	1	100	4	347.83	34.78	17.39	400	$37,619

NOx	350	1	350	9	2,739.13	273.91	136.96	3,150	$296,249

Report of CEMS Demonstration  c	See 3B

 	 	 	 

 	 

Reports for SO2  e	 

 	 	 	 

 	 

Quarterly  f	16	4	64	148	8,236.52	823.65	411.83	9,472	$890,817

Semiannual	16	2	32	593	16,500.87	1,650.09	825.04	18,976	$1,784,643

Reports for PM  e,  g	 

 	 	 	 

 	 

Quarterly:  f	 

 	 	 	 

 	 

Excess	16	4	64	38	2,114.78	211.48	105.74	2,432	$228,723

No Excess	8	4	32	152	4,229.57	422.96	211.48	4,864	$457,447

Semiannual:	 

 	 	 	 

 	 

Excess	16	2	32	177	4,925.22	492.52	246.26	5,664	$532,684

No Excess	8	2	16	570	7,930.43	793.04	396.52	9,120	$857,712

Reports for NOx  e,  g	 

 	 	 	 

 	 

Quarterly:  f	 

 	 	 	 

 	 

CEMS Compliance	16	4	64	162	9,015.65	901.57	450.78	10,368	$975,083

Excess	16	4	64	33	1,836.52	183.65	91.83	2,112	$198,628

No Excess	8	4	32	129	3,589.57	358.96	179.48	4,128	$388,228

Semiannual:	 

 	 	 	 

 	 

CEMS Compliance	16	2	32	647	18,003.48	1,800.35	900.17	20,704	$1,947,157

Excess	16	2	32	129	3,589.57	358.96	179.48	4,128	$388,228

No Excess	8	2	16	518	7,206.96	720.70	360.35	8,288	$779,465

Appendix F Report  e,  h	 

 	 	 	 

 	 

Quarterly:  f	 

 	 	 	 

 	 

SO2	11	4	44	130	4,973.91	497.39	248.70	5,720	$537,951

NOx	11	4	44	171	6,542.61	654.26	327.13	7,524	$707,613

Semiannual:	 

 	 	 	 

 	 

SO2	11	2	22	514	9,833.04	983.30	491.65	11,308	$1,063,488

NOx	11	2	22	685	13,104.35	1,310.43	655.22	15,070	$1,417,294

Annual Compliance Tests for NOx  e	250	1	250	372	80,869.57	8,086.96
4,043.48	93,000	$8,746,407

Appendix F Annual Accuracy Test:  e, h	 

 	 	 	 

 	 

SO2	36	1	36	856	26,796.52	2,679.65	1,339.83	30,816	$2,898,164

NOx	36	1	36	644	20,160.00	2,016.00	1,008.00	23,184	$2,180,395

Appendix F Audits  e,  i,  j	 

 	 	 	 

 	 

Quarterly	 

 	 	 	 

 	 

SO2 - In Situ	125	4	500	33	16,500.00	0.00	0.00	16,500	$825,000

SO2 – Extractive	36	4	144	97	13,968.00	0.00	0.00	13,968	$698,400

Semiannual	 

 	 	 	 

 	 

SO2 - In Situ	125	2	250	129	32,250.00	0.00	0.00	32,250	$1,612,500

SO2 - Extractive	36	2	72	385	27,720.00	0.00	0.00	27,720	$1,386,000

Quarterly	 

 	 	 	 

 	 

NOx - In Situ	125	4	500	43	21,500.00	0.00	0.00	21,500	$1,075,000

NOx - Extractive	36	4	144	128	18,432.00	0.00	0.00	18,432	$921,600

Semiannual	 

 	 	 	 

 	 

NOx - In Situ	125	2	250	171	42,750.00	0.00	0.00	42,750	$2,137,500

NOx - Extractive	36	2	72	514	37,008.00	0.00	0.00	37,008	$1,850,400

C. Create Information  c	Included in 3B

 	 	 	 

 	 

D. Gather Existing Information	Included in 3B

 	 	 	 

 	 

E. Write Report	 

 	 	 	 

 	 

Notify of Construction/                                       
Reconstruction  c	2	1	2	45	78.26	7.83	3.91	90	$8,464

Notify of Anticipated Startupc	2	1	2	45	78.26	7.83	3.91	90	$8,464

Notify of Actual Startup  c	2	1	2	45	78.26	7.83	3.91	90	$8,464

Monitoring Plan  c	4	1	4	22	76.52	7.65	3.83	88	$8,276

Notification of Initial Performance Test  c	 

 	 	 	 

 	 

SO2	2	1	2	13	22.61	2.26	1.13	26	$2,445

PM	2	1	2	19	33.04	3.30	1.65	38	$3,574

NOx	2	1	2	45	78.26	7.83	3.91	90	$8,464

Total Reporting Burden	 

 	 	 	 

537,844	$41,327,235

4. RECORDKEEPING REQUIREMENTS	 

 	 	 	 

 	 

A. Read Instructions  c	1	1	1	45	39.13	3.91	1.96	45	$4,232

B. Plan Activities	N/A

 	 	 	 

 	 

C. Implement Activities	N/A

 	 	 	 

 	 

D. Develop Record System	N/A

 	 	 	 

 	 

E. Time to Enter Information 	 

 	 	 	 

 	 

F. Records of Startup, Shutdown,                            Malfunction
1.5	52	78	1,500	101,739.13	10,173.91	5,086.96	117,000	$11,003,545

G. Records of All Measurements	1.5	52	78	1,500	101,739.13	10,173.91
5,086.96	117,000	$11,003,545

Total Recordkeeping Burden	 	 	 	 	 	 	 	234,045	22,011,322

TOTAL ANNUAL BURDEN	 	 	 	 	 	 	 	771,889	63,338,557



Footnotes:

a) This ICR uses the following labor rates: Managerial $114.77 ($54.65 +
110%); Technical $97.59 ($46.47 + 110%); and Clerical $48.26 ($22.98 +
110%).  These rates are from the United States Department of Labor,
Bureau of Labor Statistics, March 2009, 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 percent of
Technical hours, and Clerical hours are 10 percent of Technical hours.

b) EPA estimates that there will be 26 new gas-fired steam generating
units per year (which require NOx controls), 13 new coal-fired
generating units per year (which require SO2, NOx, and PM controls), and
6 new biomass/wood (which require NOx and PM controls).

c) One-time only costs associated with the anticipated 45 new sources
per year over the next three years.  According to the 2003 ICR renewal,
approximately half of all new sources will submit a monitoring plan.

d) Assume 20 percent of initial performance tests and CEMS
demonstrations are repeated due to failures.

e) According to the 2003 ICR renewal, there are 640 sources that must
report SO2 emissions,  622 sources that must report PM emissions, and
1322 sources that must report NOx emissions.  Because these existing
source estimates were from 2003, this ICR renewal adds 270 additional
existing sources since the 2003 ICR renewal (45 sources times six years)
to update the total number of existing sources reported each type of
pollutant.  These 270 sources are split out according to the same
distribution of gas, coal, and biomass units listed in note (b) above. 
To estimate the total number of respondents for each type of pollutant
reporting, the existing sources subject to each type of pollutant
reporting were added to the 45 new sources per year and these new
sources were distributed according to note (b). 

f) Assume that 20 percent of respondents will choose to report
quarterly.

g) Assume the 20 percent of units are found to be in excess of emission
standard, 80 percent are found to be in no excess.

h) According to the 2003 ICR renewal, 57 percent of all sources submit
an Appendix F Report for SO2, and the remaining 43 percent submit an
Appendix F Report for NOx.

i) Appendix F audit costs are based on contractor costs of $50.00 per
hour.

j) Assume that 25 percent of units have in situ CEMS and 75 percent have
extractive CEMS.

Table 2: Annual Agency Burden and Cost - NSPS for
Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part
60, Subpart Db)

Activity	A

EPA hours per occurrence	B

Occurrences per plant per year	C

EPA hours per plant per year

(A x B)	D

Plants per year	E

Technical person hours  a	F

Clerical person hours  a	G

Management person hours  a	H

EPA hours per year

(C x D)	I

Total annual cost

Report Review For Construction, Anticipated Startup, Actual Startup  b
116	1	116	45	4,539	454	227	5,220	$231,732 

Review Notification of Initial Test:

 

 	 	 	 	 	 

SO2  c	70	1	70	13	791	79	40	910	$40,398 

PM  c	72	1	72	19	1,190	119	59	1,368	$60,730 

NOx  c	104	1	104	45	4,070	407	203	4,680	$207,759 

Review Initial Test Results:

 

 	 	 	 	 	 

SO2  c	280	1	280	13	3,165	317	158	3,640	$161,591 

PM  c	288	1	288	19	4,758	476	238	5,472	$242,919 

NOx  c	416	1	416	45	16,278	1,628	814	18,720	$831,038 

Review Notification of CMS Demonstration:

 

 	 	 	 	 	 

SO2  c	56	1	56	13	633	63	32	728	$32,318 

PM  c	82	1	82	19	1,355	135	68	1558	$69,164 

NOx  c	42	1	42	45	1,643	164	82	1,890	$83,903 

Review CMS Performance Demonstration:

 

 	 	 	 	 	 

SO2  c	448	1	448	13	5,064	506	253	5,824	$258,545 

PM  c	656	1	656	19	10,838	1,084	542	12,464	$553,315 

NOx  c	336	1	336	45	13,148	1,315	657	15,120	$671,223 

Review Monitoring Plan  b	108	1	108	22	2,066	207	103	2,376	$105,478 

Review NOx Compliance Reports  d,  e

 

 	 	 	 	 	 

Quarterly	42	4	168	162	23,666	2,367	1,183	27,216	$1,208,201 

Semiannual	42	2	84	647	47,259	4,726	2,363	54,348	$2,412,673 

Review SO2 Compliance Reports  d,  e

 

 	0	0	0	 	 

Quarterly	70	4	280	148	36,035	3,603	1,802	41,440	$1,839,648 

Semiannual	70	2	140	593	72,191	7,219	3,610	83,020	$3,685,510 

Review Excess Emissions Reports:  d,  e

 

 	 	 	 	 	 

SO2:

 

 	 	 	 	 	 

Quarterly	130	4	520	148	36,035	3,603	1,802	41,440	$1,839,648 

Semiannual	130	2	260	593	72,191	7,219	3,610	83,020	$3,685,510 

NOx:

 

 	 	 	 	 	 

Quarterly	92	4	368	33	10,560	1,056	528	12,144	$539,109 

Semiannual	92	2	184	129	20,640	2,064	1,032	23,736	$1,053,713 

Review Appendix F QA Data Assessment Reports:  d

 

 	 	 	 	 	 

SO2	42	1	42	644	23,520	2,352	1,176	27,048	$1,200,743 

NOx	56	1	56	856	41,683	4,168	2,084	47,936	$2,128,025 

SUBTOTAL

 

 	 	 	 	462,638	$27,878,743 

Travel Expenses  f	 	 	 	 	 	 	 	 	$7,125 

TOTAL ANNUAL COST	 	 	 	 	 	 	 	 	$27,855,868 



Footnotes:

a) This ICR uses the following labor rates: Managerial $61.36 (GS-13,
Step 5, $38.35 + 60%); Technical $45.52 (GS-12, Step 1, $28.45 + 60%);
and Clerical $24.64 (GS-6, Step 3, $15.40 + 60%). 

These rates are from the Office of Personnel Management (OPM), 2009
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.

b) All new plants subject to the standard must provide reports of these
events as required by section 60.7.  These are one-time-only costs
associated with the anticipated 45 new sources per year over the next
three years.  According to the 2003 ICR renewal, approximately half of
all new sources will submit a monitoring plan.

c) EPA estimates that there will be 26 new gas-fired steam generating
units per year (which require NOx controls), 13 new coal-fired
generating units per year (which require SO2, NOx, and PM controls), and
6 new biomass/wood (which require NOx and PM controls).

d) The average number of new sources for each control for SO2, PM and
NOx have been determined according to assumption (b) in Table 1 above,
accounting for industry growth during the years since the ICR renewal of
the year 2003, and added to the number of existing sources required to
submit reports for each type of pollutant.  The estimates for the number
of existing sources are in note (e) of Table 1 above. 

e) We assume that 20 percent of respondents will choose to report
quarterly.

f) Travel expenses (1 person x 15/plants/yr x 3 days/plant x $75 per
diem) + ($250 round trip/plant x 15 plants/yr).

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