1
SUPPORTING
STATEMENT
NESHAP
FOR
COAL­
AND
OIL­
FIRED
ELECTRIC
UTILITY
STEAM
GENERATING
UNITS:
PROPOSED
RULE
(
40
CFR
Part
63,
Subpart
UUUUU)

PART
A
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
NESHAP
for
Coal­
and
Oil­
Fired
Electric
Utility
Steam
Generating
Units:
Proposed
Rule
(
40
CFR
Part
63,
Subpart
UUUUU)."

This
is
a
new
information
collection
request
(
ICR)
that
has
been
assigned
Environmental
Protection
Agency
(
EPA)
ICR
number
2137.01.

(
b)
Short
Characterization.

Potential
respondents
are
owners
or
operators
of
new
or
existing
coal­
or
oil­
fired
electric
utility
steam
generating
units.
The
proposed
national
emission
standard
for
hazardous
air
pollutants
(
NESHAP)
would
set
emission
limits
for
mercury
(
Hg)

emissions
from
coal­
fired
electric
utility
steam
generating
units
and
for
nickel
(
Ni)
emissions
from
oil­
fired
electric
utility
steam
generating
units.
For
oil­
fired
units,
respondents
could
elect
as
an
alternative
to
meeting
the
Ni
emissions
limit
to
burn
distillate
fuel
oil
full­
time.
Operating
limits
for
the
air
pollution
control
devices
(
most
likely
electrostatic
precipitators
(
ESP))
used
to
meet
the
Ni
emissions
limit
for
oil­
fired
units
also
would
apply.

Respondents
operating
multiple
coal­
fired
units
at
their
power
plant
would
be
allowed
to
comply
with
the
Hg
emissions
limits
on
either
an
individual
unit
basis
or
by
averaging
the
Hg
emissions
2
from
all
of
the
affected
coal­
fired
units
located
at
the
plant.

Respondents
operating
coal­
fired
units
would
demonstrate
compliance
with
the
applicable
Hg
emissions
limit
using
a
continuous
emission
monitoring
system
(
CEMS)
or
appropriate
extended
sampling
method.
Performance
Specification
12A
for
Hg
CEMS
and
new
EPA
Method
324
for
Hg
sampling
are
proposed
as
part
of
this
rulemaking.
Compliance
with
the
applicable
Hg
emissions
limit
would
be
based
on
a
12­
month
rolling
average
procedure.

Respondents
operating
oil­
fired
units
would
demonstrate
initial
compliance
with
the
Ni
emissions
limit
by
conducting
performance
tests
using
EPA
Method
29
and
compliance
certifications;
continuous
compliance
would
be
demonstrated
through
annual
repeat
performance
tests.

The
proposed
rule
would
require
all
respondents
to
prepare
a
unit­
specific
monitoring
plan
and
comply
with
its
requirements.

Consistent
with
the
NESHAP
General
Provisions,
respondents
also
must
prepare
and
follow
a
startup,
shutdown,
and
malfunction
plan
and
submit
one­
time
notifications
with
semiannual
reports
of
rule
deviations;
and
maintain
records
of
specific
information
ensure
that
the
rule
requirements
are
being
achieved.
An
immediate
report
would
be
required
if
actions
taken
in
response
to
a
startup,

shutdown,
or
malfunction
were
not
consistent
with
the
startup,

shutdown,
and
malfunction
plan.
These
requirements
are
listed
in
Attachment
1.
3
2.0
Need
for
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

Section
112
of
the
Clean
Air
Act
(
CAA)
requires
that
the
EPA
promulgate
regulations
for
the
control
of
hazardous
air
pollutants
(
HAP)
from
listed
categories
of
sources.
Based
on
the
Administrator's
regulatory
finding
(
65
FR
79285,
December
20,

2000),
the
EPA
added
coal­
and
oil­
fired
electric
utility
steam
generating
units
to
the
list
of
source
categories
for
regulation
(
67
FR
6521,
February
12,
2002).
The
NESHAP
developed
under
section
112
must
reflect:

...
the
maximum
degree
of
reduction
in
emissions
of
[
HAP]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
emission
reduction,
any
nonair
quality
health
and
environmental
reduction,
and
energy
requirements.
[
section
112(
d)(
2)]

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).

Certain
records
and
reports
are
necessary
for
the
Administrator
to:
(
1)
confirm
the
compliance
status
of
affected
sources
and
identify
new
or
reconstructed
sources
subject
to
the
standards;
and
(
2)
ensure
that
the
MACT
standards
are
being
achieved.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.
7414)

and
set
out
and
set
out
in
the
NESHAP
General
Provisions
in
40
CFR
Part
63,
Subpart
A
4
(
b)
Use/
Users
of
the
Data.

The
information
required
by
the
proposed
rule
would
be
used
by
EPA
enforcement
personnel
to
ensure
that
the
emission
limitations
are
being
achieved.
Based
on
review
of
the
recorded
information
at
the
site
and
the
reported
information,
the
EPA
can
identify
facilities
that
may
not
be
in
compliance
and
decide
which
plants,

records,
or
processes
should
be
inspected.

3.0
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.

A
computer
search
of
the
Federal
Information
Locator
System
indicated
that
there
are
no
similar
information
requests
being
carried
out
by
the
Federal
government,
with
the
exception
of
the
new
source
performance
standards
for
electric
utilities
(
which
do
not
control
HAP
emissions).
A
similar
search
of
the
EPA's
ongoing
ICR's
revealed
no
duplication
of
information­
gathering
efforts.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
proposed
rule.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
information
that
would
be
required
in
the
semiannual
compliance
report.

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

This
section
is
not
applicable
because
this
is
a
rule­
related
ICR.
5
(
c)
Consultations.

The
proposed
rule
was
developed
in
consultation
with
the
Permits,
New
Source
Review,
and
Toxics
Subcommittee
Working
Group
of
the
Clean
Air
Act
Advisory
Committee,
industry
trade
associations
(
Electric
Power
Research
Institute
(
EPRI))
and
Utility
Regulatory
Advisory
Group
(
UARG),
and
the
Department
of
Energy
(
DOE).
For
example,
several
meetings
and
telephone
consultations
were
held
with
representatives
from
the
affected
plants
and
industry
trade
associations.
The
EPA
also
made
information
from
the
Working
Group
available
to
the
public
through
a
special
website.
Non­
EPA
persons
consulted
prior
to
proposal
are
identified
in
Table
1.

(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
were
collected
less
frequently,

the
EPA
would
not
be
reasonably
assured
that
an
electric
utility
steam
generating
unit
is
in
compliance
with
the
applicable
standards
under
the
rule.

(
e)
General
Guidelines.

None
of
the
guidelines
in
5
CFR
1320.6
are
being
exceeded.

(
f)
Confidentiality.

All
information
submitted
to
the
EPA
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
6
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
28,
7
TABLE
1.
PERSONS
CONSULTED
ON
THE
PROPOSED
INFORMATION
COLLECTION
ACTIVITIES
Contact
Organization
Phone
Number
John
Paul
RAPCA
937­
225­
4435
Patrick
Raher
Hogan
&
Hartson
202­
637­
5682
Praveen
Amar
NESCAUM
617­
367­
8540
Debra
Jezouit
Baker
Botts
202­
639­
7728
Marc
Brownstein
PSEG
973­
430­
7196
Dan
Cunningham
Con
Edison
212­
460­
2066
Larry
Monroe
Southern
Company
Generation
205­
257­
7772
Bill
O'Sullivan
New
Jersey
Dept.
of
Environmental
Protection
609­
984­
1484
Martha
Keating
CATF
919­
563­
3223
Ann
Berwick
M.
J.
Bradley
Associates
978­
369­
5533
Mike
Opalinski
Seminole
Electric
Coop
813­
693­
0094
Tom
Natan
National
Environmental
Trust
202­
887­
8828
Michael
Rossler
EEI
202­
289­
2398
David
Schanbacher
Texas
Natural
Resources
Conservation
Commission
512­
239­
1228
Sandra
Schubert
Earthjustice
202­
667­
4500
John
Shanahan
National
Mining
Association
202­
463­
9793
Michael
Shore
Environmental
Defense
828­
254­
7359
Patricio
Silva
Natural
Resources
Defense
Council
202­
289­
2398
Jeff
Smith
ICAC
202­
457­
0911
Felice
Stadler
National
Wildlife
Federation
202­
797­
6692
Mike
Geers
Cinergy
513­
287­
3839
Richard
Wilson
National
Environmental
Strategies
202­
333­
2524
Claudia
O'Brien
Latham
and
Watkins
Lee
Zeugin
Hunton
&
Williams
202­
955­
1535
David
Lamb
TXU
214­
812­
8482
Paul
Chu
EPRI
650­
855­
2812
Ralph
Roberson
RMB
Consulting
919­
510­
0376
Bill
Wemhoff
National
Rural
Electric
Coop
Assoc.
703­
907­
5824
8
Dennis
James
North
American
Coal
Assoc.
701­
442­
5751
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979.

(
g)
Sensitive
Questions.

This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
NAIC
Codes.

Potential
respondents
under
the
proposed
rule
are
owners
or
operators
of
coal­
or
oil­
fired
electric
utility
steam
generating
units;
natural
gas­
fired
units
are
not
affected.
The
NAIC
codes
for
this
industry
are
221112
"
Fossil
Fuel­
Fired
Steam
Generating
Units
(
including
those
owned
or
operated
by
the
Federal
government
or
municipalities)
and
921150
"
American
Indian
and
Alaska
Native
Tribal
Governments."

(
b)
Information
Requested.

(
i)
Data
Items,
Including
Recordkeeping
Requirements.

Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
proposed
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
Activities.
The
respondent
activities
required
by
the
proposed
amendments
are
identified
in
Table
2
and
introduced
in
section
6(
a).

5.0
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
Table
3
and
introduced
in
section
6(
c).

(
b)
Collection
Methodology
and
Management.

This
is
not
relevant
to
this
information
collection
request.

(
c)
Small
Entity
Flexibility.

According
to
the
Small
Business
Administration
size
standards
9
for
the
NAICS
categories,
a
small
entity
is
a
small
business
that,

including
its
affiliates,
is
primarily
engaged
in
the
generation,

transmission,
and/
or
distribution
of
electric
energy
for
sale
and
whose
total
electric
output
for
the
preceding
fiscal
year
did
not
exceed
4
million
Megawatt
hours
(
MWh).
The
EPA
has
not
completed
a
full
assessment
of
the
impacts
of
the
proposed
rule
on
small
entities
at
this
time.
Nonetheless,
we
have
tried
to
reduce
the
impact
of
the
proposed
rule
on
small
facilities.
We
held
several
meetings
with
industry
trade
associations
and
company
representatives
to
discuss
the
proposed
rule
and
have
included
provisions
to
address
their
concerns.
The
proposed
rule
provides
the
maximum
degree
of
flexibility
and
the
ICR
requirements
are
the
minimum
necessary
to
demonstrate
compliance.
Owners
and
operators
of
affected
units
would
have
up
to
3
years
to
demonstrate
compliance
and
the
Administrator
may
grant
1
additional
year
if
more
time
is
needed
to
install
controls.

(
d)
Collection
Schedule.

The
information
contained
in
the
periodic
reports
submitted
to
the
EPA
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
database
which
is
operated
and
maintained
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards.
Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
National
Compliance
Data
System
operated
and
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
enforcement
and
compliance
programs.
A
schedule
for
collection
of
information
and
publication
of
data
is
not
applicable
because
reports
are
triggered
by
actions
of
the
respondents.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.
10
The
annual
burden
estimates
for
the
additional
recordkeeping
and
reporting
requirements
in
the
proposed
rule
are
shown
in
Table
2.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
NESHAP
with
similar
compliance­
related
information
collection
activities.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
the
proposed
rule
are
presented
in
Table
2.

(
i)
Estimating
Labor
Costs.
Labor
rates
and
associated
costs
are
based
on
Bureau
of
Labor
Statistics
(
BLS)
data.
Technical,

management,
and
clerical
average
hourly
total
compensation
rates
for
private
industry
workers
were
taken
from
the
September
2003
E
m
p
l
o
yment
Cost
Trends
(
available
at
<

http://
stats.
bls.
gov/
news.
release/
ecec.
t10.
htm>).
Wages
for
whitecollar
occupations
are
used
as
the
basis
for
the
labor
rates
with
a
total
compensation
of
$
30.70/
hour
for
technical,
$
44.98/
hour
for
managerial,
and
$
19.02/
hour
for
clerical.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)

Costs.
As
shown
in
Table
2,
the
estimate
annualized
capital
and
O&
M
costs
for
the
proposed
rule
is
$
40,784,964
per
year.

(
iii)
Capital/
Startup
vs.
O&
M
Costs.
The
estimate
of
capital/
startup
costs
versus
O&
M
costs
is
shown
in
Table
2.
The
annual
O&
M
cost
over
the
3­
year
period
of
this
ICR
is
$
15,328,167
per
year.

(
iv)
Annualizing
Capital
Costs.
Table
2
shows
an
estimate
of
the
annualized
cost
of
capital
to
be
$
25,456,797
per
year.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
the
NESHAP
General
11
Provisions,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
the
Compliance
Data
System,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
EPA's
overall
compliance
and
enforcement
program,
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Table
3.

The
Agency
labor
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
2003
General
Schedule
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
Salary
Table
2003­
GS
available
on
the
OPM
website
(
available
at
<
http://
www.
opm.
gov­
oca­

03tables/
pdf/
gs
h.
pdf>).
The
government
employee
labor
rates
are
$
13.91/
hour
for
clerical
(
GS­
7,
Step
1),
$
29.35
for
technical
(
GS­

13,
Step
1),
and
$
40.80/
hr
for
management
(
GS­
15,
Step
1).

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

The
EPA
estimates
that
568
existing
electric
utility
power
plants
(
461
coal­
fired
power
plants
and
107
oil­
fired
power
plants)

would
be
subject
to
the
proposed
rule.
Owners
and
operators
of
these
plants
would
be
required
to
install
air
pollution
control
and
monitoring
equipment,
conduct
initial
performance
tests
(
if
applicable),
prepare
the
required
plans,
and
provide
one­
time
notifications
during
the
3­
year
clearance
period
of
this
ICR.
For
the
purpose
of
estimating
burden,
it
is
assumed
that
respondents
will
install
and
begin
operation
of
monitoring
systems
in
the
third
year
following
promulgation
of
the
date
(
the
proposed
rule
actually
would
set
the
compliance
date
for
existing
units
at
the
end
of
the
3­
year
ICR
period).
Details
on
the
number
of
respondents
affected
by
and
assumptions
made
for
each
individual
burden
item
are
provided
in
the
footnotes
to
Table
2.
12
(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
Table
2,
are
calculated
by
adding
personhours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
The
total
annual
hours
are
243,418;
the
estimated
costs
is
$
7,610,083
per
year
including
technical,
management,
and
clerical
hours.
The
total
cost
given
in
Table
2,
including
the
cost
of
labor,
capital,
operation
and
maintenance,
is
$
48,395,047
per
year.
The
annualized
cost
of
capital
for
monitoring
devices
is
$
25,456,797
averaged
over
the
first
three
years
of
this
ICR.
Annualized
costs
are
calculated
assuming
a
7
percent
interest
rate
and
a
3­
year
depreciation
period.

Operation
and
maintenance
costs
(
excluding
any
labor
hours
given
in
the
labor
burden
estimate)
are
estimated
at
$
15,328,167
per
year
averaged
over
the
3­
year
period.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Table
3,
are
calculated
by
adding
personhours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,

total
cost
is
the
sum
of
this
total
salary
cost
and
total
travel
expenses
for
government
personnel
to
observe
compliance
tests
at
a
selected
number
of
plants
each
year.
The
total
annual
hours
are
23,437.
The
total
annual
cost
is
$
763,127.

(
iii)
Variations
in
the
annual
bottom
line.
This
section
does
not
apply
since
no
significant
variation
is
anticipated.

(
f)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
ICR.

(
g)
Burden
Statement
The
average
annual
respondent
burden
per
facility
is
estimated
at
214
hours.
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
13
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
in
40
CFR
Part
63
are
listed
in
40
CFR
Part
9.

To
comment
on
the
Agency's
need
for
this
information
the
accuracy
of
the
provided
burden
estimates,
and
any
suggestions
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
the
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2002­
0056,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B­
102,
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
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
docket.
Use
EDOCKET
to
submit
or
view
public
comments,
and
to
access
the
index
listing
of
the
contents
of
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,",
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
14
725
17th
Street,
NW,
Washington,
DC
20503,
Attention
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OAR­
2002­
0056
in
any
correspondence.

PART
B
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
the
proposed
rule.
15
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)
(
H)

Personhours
per
occurrence
No.
of
occurrences
per
respondent
(
see
note
a)
Personhours
per
respondent
(
C=
AxB)
Respondents
per
year
Technical
personhours
per
year
(
E=
CxD)
Management
personhours
per
year
(
Ex0.05)
Clerical
personhours
per
year
(
Ex0.1)
Costs,
$

(
see
note
b)

1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
A.
Acquire
and
install
Hg
CEMS
system
for
coal­
fired
units
(
see
notes
d,
g
,
i)
274
1
274
154
42,043
2,102
420
$
1,393,278
B.
Acquire
and
install
ESP
operating
parameter
monitoring
system
for
oil­
fired
units
(
see
notes
e,
h,
i)
128
1
128
36
4,565
228
46
$
151,291
4.
Reporting
Requirements
A.
Read
instructions
(
see
note
c)
8
1
8
190
1,517
76
15
$
50,283
B.
Required
activities
i.
Collect
coal
data
for
coal­
fired
units
0.5
365
183
154
28,044
1,402
280
$
929,361
ii.
Operate
Hg
CEMS
for
coal­
fired
units
(
see
notes
d,
g,
i)
394
1
394
154
60,575
3,029
606
$
2,007,420
iii.
Calculate
12­
mo.
rolling
average
Hg
emission
rate
for
coal­
fired
units
(
see
note
i)
4
12
48
154
7,376
369
74
$
244,435
iv.
Supervise
contractor
performed
Method
29
performance
test
for
oil­
fired
units
(
see
note
e,
h,
i)
64
1
64
36
2,283
114
23
$
75,646
v.
Monitor
ESP
operation
for
oil­
fired
units
(
see
notes
e,
h,
i)
0.50
365
183
36
6,509
325
65
$
215,709
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
Burden
item
Table
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
PROPOSED
RULE
(
Continued)
16
E.
Write
reports
i.
Initial
notification
(
see
note
c)
2
1
2
190
379
19
4
$
12,571
ii.
Performance
test/
evaluation
notification
(
see
note
c)
2
1
2
190
379
19
4
$
12,571
iii.
Initial
compliance
determination
(
see
note
c)
40
1
40
190
7,587
379
76
$
251,416
iv.
Performance
test/
evaluation
reports
(
see
note
c)
8
1
8
190
1,517
76
15
$
50,283
v.
Semiannual
compliance
report
16
2
32
568
18,176
909
182
$
602,338
vi.
Startup/
shutdown/
malfunction
rpt
(
see
note
c)
8
1
8
190
1,517
76
15
$
50,283
5.
Recordkeeping
Requirements
A.
Read
instructions
(
see
note
c)
See
4A
B.
Plan
activities
(
see
note
c)
40
1
40
190
7,587
379
76
$
251,416
C.
Implement
activities
See
4B
D.
Develop
record
system
(
see
note
c)
40
1
40
190
7,587
379
76
$
251,416
E.
Time
to
enter
information
i.
Coal­
fired
power
plants
(
see
note
i)
1
52
52
154
7,991
400
80
$
264,804
ii.
Oil­
fired
power
plants
(
see
note
i)
1
12
12
36
428
21
4
$
14,184
F.
Time
to
train
personnel
i.
Coal­
fired
power
plants
(
see
note
i)
80
1
80
154
12,293
615
123
$
407,391
ii.
Oil­
fired
power
plants
(
see
note
i)
40
1
40
36
1,427
71
14
$
47,279
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
(
see
note
c)
40
1
40
190
7,587
379
76
$
251,416
H.
Time
to
transmit
or
disclose
information
2
2
4
568
2,272
114
23
$
75,292
I.
Time
for
audits
(
see
note
j)

TOTAL
LABOR
BURDEN
AND
COST
229,640
11,482
2,296
$
7,610,084
Annualized
cost
of
capital
(
see
note
k)
$
25,456,797
Operation
and
maintenance
(
O&
M)
$
15,328,167
Total
(
capital
recovery
+
O&
M
costs)
$
40,784,964
Table
2.
(
Continued)
(
Continued)
17
NOTES:

N/
A
=
Not
applicable
a.
"
Respondent"
defined
to
be
each
individual
electric
utility
power
plants
subject
to
rule:
461
coal­
fired
plants
and
107
oil­
fired
plants.

b
Costs
are
based
on
the
following
hourly
total
compensation
rates
for
respondent
employees:
technical
at
$
30.70,
management
at
$
44.98,
and
clerical
at
$
19.02
as
reported
by
the
U.
S.
Bureau
of
Labor
Statistics
for
September
2003
<
http://
stats.
bls.
gov/
news.
release/
ecec.
t10.
htm>.

d.
Assumes
on
average
each
of
the
461
coal­
fired
power
plant
has
1.8
affected
units
with
each
requiring
an
individual
CEMS
(
821
units/
461
plants
=
1.8
units
per
plant).

e.
Assumes
on
average
each
of
the
107
oil­
fired
power
plants
has
2
affected
units
requiring
individual
ESP
control
devices
(
210
units/
107
plants
=
2
units
per
plant).

f.
Labor
hour
requirements,
capital
costs,
and
O&
M
costs
for
mercury
CEMS
based
on
information
in
draft
report
titled
"
Cost
Analysis
of
Mercury
Monitoring
Techniques"

prepared
by
ARCADIS
G&
M,
Inc.
for
U.
S.
EPA
Clean
Air
Markets
Division,
November
3,
2003.

g.
Occurrence
defined
for
this
burden
item
to
be
total
annual
person
hours
to
perform
activity
for
CEMS
at
respondents
coal­
fired
plant
site.

Person­
hours
per
occurrence
represents
estimated
annual
hours
per
one
CEMS
times
the
1.8
unit
per
plant
factor
from
note
(
d).

h.
Occurence
defined
for
this
burden
item
to
be
total
annual
person
hours
to
perform
activity
for
ESP
at
respondents
oil­
fired
plant
site.

Person­
hours
per
occurrence
represents
estimated
annual
hours
per
one
ESP
times
the
2.0
unit
per
plant
factor
from
note
(
e).

i.
Assumes
compliance
activity
begins
in
3rd
year
following
promulgation
[(
461
coal­
fired
plants/
3
=
154,
107
oil­
fired
plants/
3
=
36].

j.
Time
for
audit
of
Hg
CEMS
addresses
by
Relative
Accuracy
Test
Audit
(
RATA)
included
as
part
of
Item
4.
B.
ii.

k.
Annualized
costs
calculated
assuming
a
7%
interest
rate
and
a
3­
year
depreciation
period.

Capital
cost
for
individual
Hg
CEMS
determined
using
average
capital
cost
of
Hg
CEMS
=
$
60,233
from
note
(
f)
plus
30%
for
installation
=
$
78,303.

c.
One
time
event
over
the
first
3­
year
term
of
the
ICR
following
promulgation
of
the
rule
(
number
shown
represents
33%
of
the
total
568
affected
plants
=
190
plants).

Table
2.
(
Concluded)
18
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)

Hours
per
occurrence
Hours
per
plant
per
year
Units
of
plants
per
year
Technical
personhours
per
year
(
D=
BxC)
Management
personhours
per
year
(
Dx0.05)
Clerical
personhours
per
year
(
Dx0.1)
Costs,
$

(
see
note
a)

Observe
CEMS
performance
evaluation
for
coal­
fired
units
(
see
notes
b,
d,
f)
16
29
16
461
230
46
$
23,566
Observe
performance
test
for
oil­
fired
units
(
see
notes
c,
e,
g)
16
32
4
128
64
13
$
6,546
Repeat
performance
test/
evaluation
­
Retesting
prep
(
see
note
h)
$
0
Repeat
performance
test/
evaluation
­
Retesting
(
see
note
h)
$
0
Litigation
(
see
note
i)
$
0
Excess
emissions
enforcement
activities
(
see
note
i)
$
0
Report
Review
Notification
of
construction
/
reconstruction
N/
A
Notification
of
anticipated
startup
N/
A
Notification
of
actual
startup
N/
A
Notification
of
special
compliance
requirements
N/
A
Notification
of
applicability
(
see
note
j)
4
4
190
760
380
76
$
38,867
Notification
of
CEMS
performance
evaluation
for
coal­
fired
plants
(
see
note
j)
4
4
154
616
308
62
$
31,503
Notification
of
initial
performance
test
for
oil­
fired
plants
(
see
note
j)
4
4
36
144
72
14
$
7,364
CEMS
Q/
A
Plan
for
coal­
fired
plants
(
see
note
j)
16
16
154
2,464
1,232
246
$
126,011
Notification
of
compliance
status
(
see
note
j)
4
4
190
760
380
76
$
38,867
Semi­
annual
compliance
report
8
16
568
9,088
4,544
909
$
464,769
NESHAP
wavier
application
8
8
0
0
0
0
$
0
Compliance
extension
request
(
see
notes
j,
k)
8
8
19
151
76
15
$
7,746
Emergency
startup,
shutdown,
and
malfunction
report
(
see
notes
j,
l)
4
4
19
76
38
8
$
3,887
TOTAL
BURDEN
AND
COST
(
SALARY)
14,648
7,324
1,465
$
749,127
OTHER
EXPENSES
(
see
note
m)
$
14,000
Activity
Table
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENTS
OF
THE
PROPOSED
RULE
(
Continued)
NOTES:

N/
A
=
Not
applicable
a
Costs
are
based
on
the
following
hourly
rates
for
government
employees:
technical
at
$
46.96,
management
at
$
65.28,
and
clerical
at
$
22.26.

b
Assumes
EPA/
State
personnel
attend
10%
of
the
CEMS
performance
evaluations
per
year
beginning
in
3rd
year
following
promulgation
[(
461
coal­
fired
plants
x
10%
)/
3]

c
Assumes
EPA/
State
personnel
attend
10%
of
the
oil­
fired
unit
performance
test
per
year
beginning
in
3rd
year
following
promulgation
[(
107
oil­
fired
plants
x
10%
)/
3]

d.
Assumes
on
average
each
of
the
461
coal­
fired
power
plant
has
1.8
affected
units
requiring
individual
CEMS
(
821
units/
461
plants
=
1.8
units
per
plant)

f.
Occurrence
defined
for
this
activity
to
be
total
annual
person
hours
to
perform
activity
for
CEMS
at
respondents
coal­
fired
plant
site.

Person­
hours
per
occurrence
represents
estimated
annual
hours
per
one
CEMS
times
the
1.8
unit
per
plant
factor
from
note
(
d).

g.
Occurence
defined
for
this
activity
to
be
total
annual
person
hours
to
perform
activity
for
ESP
at
respondents
oil­
fired
plant
site.

Person­
hours
per
occurrence
represents
estimated
annual
hours
per
one
ESP
times
the
2.0
unit
per
plant
factor
from
note
(
e).

h
Assumes
no
plant
must
repeat
the
performance
test
or
CEM
evaluation,
as
applicable,
over
the
3­
year
term
of
the
ICR.

i.
No
enforcement
or
litigation
during
the
3­
year
term
of
the
ICR
because
the
rule
compliance
date
for
existing
sources
is
3
years
after
the
date
of
rule
promulgation.

k.
Assumes
10%
of
the
568
plants
request
compliance
extensions
in
3rd
year
following
rule
promulgation
[(
568
plants
x
10%
)/
3]

l.
Assumes
10%
of
the
568
plants
submit
SSM
report
in
3rd
year
following
rule
promulgation
[(
568
plants
x
10%
)/
3]

m.
Government
travel
expenses
to
observe
performance
test/
evaluation
based
on
[
1
person
x
($
100
per
diem
x
2
days
+
$
100
hotel
x
$
400
roundtrip
air
fare)
x
20
plants]

e.
Assumes
on
average
each
of
the
107
oil­
fired
power
plants
has
2
affected
units
requiring
individual
ESP
control
devices
(
210
units/
107
plants
=
2
units
per
plant).

j.
One
time
event
over
the
first
3­
year
term
of
the
ICR
following
promulgation
of
the
rule
(
number
shown
represents
33%
of
the
total
568
affected
plants
=
190
plants).

19
Table
3.
(
Concluded)
20
ATTACHMENT
1.
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions
citation
Record
retention
STUDIES
AND
PLANS
Startup,
shutdown,
and
malfunction
plan
63.10000(
e)
63.6(
e)(
3)
5
yearsa
Unit­
specific
monitoring
plan
63.10008(
h)
N/
A
5
yearsa
Site­
specific
test
plan
63.10007(
a)
63.7(
c)
5
yearsa
Performance
evaluation
test
plan/
report
63.10000(
d)
63.8(
e)
5
yearsa
REPORTS
Notification
of
fuel
switch
63.10030(
a)
N/
A
5
yearsa
Initial
notification,
Notification
of
performance
evaluation,
performance
test,
construction/
reconstruction,
and
compliance
status
63.10030(
a)
63.6(
h),
63.7(
b)­
(
c),
63.8(
e)­(
f),
63.9(
b)­(
h)
5
yearsa
Semi­
annual
compliance
report
63.0031(
b)
63.9(
h)
5
yearsa
Immediate
startup,
shutdown,
and
malfunction
report
Table
4
63.6(
f)(
3)(
iv)
5
yearsa
RECORDKEEPING
Records
of
notifications
and
reports,
performance
tests,
performance
evaluations,
monitoring
data,
performance
evaluation
test
plan
63.10032(
a)
63.10(
b)­(
c)
5
yearsa
Startup,
shutdowns,
and
malfunctions
63.10032(
a)
63.6(
e)(
6)
5
yearsa
Records
required
to
demonstrate
continuous
compliance
with
emission
limits
63.311(
f)(
1)
63.10(
b)(
2)(
viii)
5
yearsa
a
Onsite
for
at
least
2
years
and
offsite
for
the
remaining
3
years
as
required
by
40
CFR
63.10(
b)(
1).
