1
SUPPORTING
STATEMENT
STANDARDS
OF
PERFORMANCE
FOR
NEW
AND
EXISTING
STATIONARY
SOURCES:
ELECTRIC
UTILITY
STEAM
GENERATING
UNITS:
FINAL
RULE
EPA
ICR
No.
2137.02
PART
A
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Standards
of
Performance
for
New
and
Existing
Stationary
Sources:
Electric
Utility
Steam
Generating
Units(
Final
Rule)."

This
is
a
revision
of
EPA
ICR
2137.01
that
was
originally
titled
at
proposal,
"
NESHAP
for
Coal­
and
Oil­
Fired
Electric
Utility
Steam
Generating
Units:
Proposed
Rule
(
40
CFR
Part
63,
subpart
UUUUU)."

This
revision
incorporates
the
new
burden
estimates
that
have
been
made
for
the
recordkeeping
and
reporting
requirements
in
the
final
rule.
As
explained
below,
we
received
no
comments
from
OMB
or
the
public
on
the
burden
estimates
in
the
initial
version
of
the
ICR
that
was
docketed
with
the
proposed
rule.

(
b)
Short
Characterization.

Respondents
are
owners
or
operators
of
existing
and
new
coalfired
electric
utility
steam
generating
units
(
Utility
Units)

capable
of
firing
more
than
73
megawatts
(
MW)
(
250
million
Btu/
hour)
heat
input
including
industrial
cogeneration
facilities
that
sell
more
than
25
MW
of
electrical
output
and
more
than
one­
third
of
their
potential
output
capacity
to
any
utility
power
distribution
system.
The
final
rule
amends
40
CFR
parts
60,
63,
2
72,
and
75
to
establish
standards
of
performance
for
mercury
(
Hg)

for
new
and
existing
coal­
fired
Utility
Units,
as
defined
in
Clean
Air
Act
(
CAA)
section
111.
For
the
purpose
of
implementing
the
final
rule,
a
coal­
fired
Utility
Unit
is
an
electric
utility
steam
generating
unit
that
burns
coal,
coal
refuse,
or
a
synthetic
gas
derived
from
coal
either
exclusively,
in
any
combination
together,

or
in
any
combination
with
other
supplemental
fuels
(
e.
g.,

petroleum
coke
and
tire­
derived
fuels).

The
final
rule
amends
40
CFR
parts
72
and
75
to
establish
a
mechanism
by
which
Hg
emissions
from
new
and
existing
coal­
fired
Utility
Units
are
capped
at
specified,
nation­
wide
levels.
Under
this
cap­
and­
trade
program,
the
EPA
assigns
Hg
emission
allocations
or
"
budgets"
on
a
State­
by­
State
basis.
Each
State
and
affected
Tribal
government
participating
in
the
cap­
and­
trade
program
has
the
flexibility
to
distribute
however
they
choose
their
assigned
total
Hg
emission
budget
to
each
of
the
coal­
fired
units
operating
under
their
jurisdiction,
so
long
as
certain
timing
requirements
are
met.
States
and
affected
Tribal
governments
may
choose
to
participate
in
the
EPA­
administered
cap­
and­
trade
program.
They
can
adopt
the
Hg
cap­
and­
trade
program
either
by
incorporating
by
reference
the
model
cap­
and­
trade
rule
promulgated
by
this
rulemaking
under
40
CFR
60
subpart
HHHH
or
codifying
the
provisions
of
the
rule,
in
order
to
participate
in
the
EPA­
administered
Hg
cap­
and­
trade
program.
The
program
is
designed
to
integrate
with
the
existing
sulfur
dioxide
(
SO2)
and
nitrogen
oxides
(
NOx)
emission
3
cap­
and­
trade
program
under
the
Agency's
Acid
Rain
program
and
final
Clean
Air
Interstate
Rule
(
CAIR).

In
addition,
the
final
rules
amend
the
new
source
performance
standards
(
NSPS)
for
Utility
Units
in
40
CFR
60
subpart
Da
by
adding
Hg
emission
limits
for
coal­
fired
Utility
Units
(
oil­
fired
and
gas­
fired
Utility
Units
are
not
subject
to
the
Hg
emission
limits).
Separate
NSPS
emission
limits
expressed
in
units
of
pounds
of
Hg
per
gross­
MW
output
are
established
by
coal
subcategories:
bituminous
coal,
subbituminous
coal,
lignite,
coal
refuse,
and
synthetic
gas
derived
from
coal
(
i.
e.,
integrated
gasification
combined
cycle
(
IGCC)
units).
Compliance
with
the
applicable
emission
limit
is
determined
on
a
12­
month
rolling
average
basis.
These
new
units
are
included
under
the
Hg
emissions
cap­
and­
trade
program.

Only
those
coal­
fired
units
for
which
construction,

modification,
or
reconstruction
is
commenced
after
January
30,

2004,
are
subject
to
the
Hg
emission
limits
in
subpart
Da.

However,
all
affected
coal­
fired
Utility
Units
existing
on,
or
constructed
after,
January
30,
2004,
can
participate
in
the
Hg
capand
trade
program.

Under
the
final
rule,
existing
affected
coal­
fired
Utility
Units
with
Hg
emissions
at
or
below
29
lb
of
Hg
per
year
are
designated
as
"
low
mass
emitters"
or
LME.
Owners
and
operators
of
LME
units
are
required
to
perform
periodic
Hg
emission
testing.

Owners
and
operators
of
existing
affected
coal­
fired
Utility
Units
4
with
Hg
emissions
greater
than
29
lb
of
Hg
per
year
and
all
new
affected
coal­
fired
Utility
Units
are
required
to
use
a
Hg
continuous
emission
monitoring
system
(
CEMS)
or
a
Hg
sorbent
trap
method
for
semi­
continuous
Hg
sampling.
The
rulemaking
finalizes
Performance
Specification
12A,
"
Specification
and
Test
Methods
for
Total
Vapor
Phase
Mercury
Continuous
Emission
Monitoring
Systems
in
Stationary
Sources"
in
40
CFR
part
60,
appendix
B,
and
"
Quality
Assurance
and
Operating
Procedures
for
Sorbent
Trap
Monitoring
Systems"
in
appendix
K
to
40
CFR
part
75.

Owners
and
operators
of
existing
coal­
fired
Utility
Units
maintain
records
and
report
their
emissions
following
the
requirements
40
CFR
part
75.
The
final
rule
amends
these
existing
requirements
to
include
information
used
to
demonstrate
compliance
with
a
coal­
fired
Utility
Unit's
Hg
emissions
allocation.
Source
information
management,
emissions
data
reporting,
and
allowance
trading
is
conducted
through
electronic
data
systems
similar
to
those
currently
used
for
the
Acid
Rain
SO2
and
NOx
SIP
Call
programs.
Reporting
and
recordkeeping
requirements
for
the
Hg
capand
trade
program
are
summarized
in
Exhibit
1.

In
addition,
owners
and
operators
of
those
affected
coal­
fired
Utility
Units
subject
to
the
NSPS
under
40
CFR
60
subpart
Da
are
required
to
prepare
site­
specific
compliance
plans;
submit
notifications
of
compliance
status
and
semiannual
compliance
reports;
and
maintain
records
of
specific
information
to
ensure
that
the
rule
requirements
are
being
achieved.
The
final
rule
5
amends
these
existing
requirements
to
include
specific
information
about
the
Hg
monitoring
and
compliance
determinations
used
by
the
owner
or
operator
to
demonstrate
compliance
with
the
applicable
Hg
emissions
limit.
Reporting
and
recordkeeping
requirements
for
subpart
Da
are
summarized
in
Exhibit
2.

2.0
Need
for
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

CAA
section
111
establishes
authority
for
the
EPA
to
regulate
categories
of
stationary
sources
which
cause,
or
contribute
significantly
to,
air
pollution
which
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
CAA
section
111(
b)

authorizes
the
EPA
to
establish
NSPS
that
reflect
the
application
of
the
best
system
of
emission
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emission
reduction,
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated.
To
implement
and
enforce
NSPS,
certain
types
of
information
are
needed
by
the
EPA
to:
(
1)
confirm
the
compliance
status
of
affected
sources
and
identify
new
or
reconstructed
sources
subject
to
the
standards;
and
(
2)
ensure
that
the
applicable
standards
are
being
achieved.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
CAA
section
114
(
42
U.
S.
C.
7414)
and
are
codified
in
the
NSPS
General
Provisions
(
40
CFR
60
subpart
A)
and
in
the
applicable
source­
6
specific
rule
(
in
this
case
40
CFR
subpart
Da).

Existing
sources
are
addressed
under
CAA
section
111(
d).
The
EPA
can
issue
standards
of
performance
for
existing
sources
in
a
source
category
only
if
it
has
established
standards
of
performance
for
new
sources
in
that
same
category
under
CAA
section
111(
b),
and
only
for
designated
pollutants,
as
that
term
is
defined
in
the
final
rule.
(
CAA
section
111(
d)(
1)).
CAA
section
111(
d)

authorizes
EPA
to
promulgate
standards
of
performance
that
States
must
adopt
through
a
SIP­
like
process,
which
requires
State
rulemaking
action
followed
by
review
and
approval
of
State
plans
by
EPA.
If
a
State
fails
to
submit
a
satisfactory
plan,
the
EPA
has
the
authority
to
prescribe
a
plan
for
the
State.
(
CAA
section
111(
d)(
2(
A)).
The
EPA
is
interpreting
the
term
"
standard
of
performance,"
as
applied
to
existing
coal­
fired
Utility
Units,
to
include
a
Hg
cap­
and­
trade
program.
The
final
standards,
which
include
recordkeeping
and
reporting
requirements,
will
be
published
at
40
CFR
part
60,
subpart
HHHH.

(
b)
Use/
Users
of
the
Data.

The
information
required
by
the
final
rule
will
be
used
by
State
and
EPA
enforcement
personnel
to
ensure
that
the
cap­

andtrade
program
Hg
emissions
allocation
and
the
NSPS
emission
limit,

as
applicable
to
a
given
coal­
fired
Utility
Unit,
are
being
achieved.
Based
on
review
of
the
recorded
information
at
the
site
and
the
reported
information,
the
EPA
can
identify
units
that
may
7
not
be
in
compliance
and
decide
which
facilities
require
additional
compliance
or
enforcement
action.

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
provisions
of
the
NSPS
for
Utility
Units
and
the
Acid
Rain
cap­

andtrade
program
related
to
SO2
and
NOx
emissions.
These
programs
have
similar
reporting
and
recordkeeping
requirements
but
do
not
involve
the
monitoring
of
Hg
emissions;
therefore,
there
is
no
duplication
of
effort.
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
final
rule.
Sources,
therefore,
may
submit
to
EPA
a
copy
of
the
report
submitted
to
their
respective
State
or
local
agency
provided
the
information
in
that
report
satisfies
the
requirements
of
the
final
rule.

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

This
section
is
not
applicable
because
this
is
a
rule­
related
ICR.

(
c)
Consultations.

The
proposed
rule
was
posted
on
the
Agency's
Internet
website
and
entered
into
the
docket
(
OAR­
2002­
0056)
for
public
review.
8
Following
publication
of
the
notice
of
proposed
rulemaking
(
NPR)
in
the
Federal
Register
(
69
FR
4652;
January
30,
2004),
a
60­
day
public
comment
period
ensued.
Concurrent
public
hearings
were
held
in
Research
Triangle
Park,
NC,
Philadelphia,
PA,
and
Chicago,
IL,

on
February
25
and
26,
2004,
at
which
time
any
member
of
the
public
could
provide
oral
comment
on
the
NPR.
On
March
16,
2004,
a
supplemental
notice
of
proposed
rulemaking
(
SNPR)
was
published
in
the
Federal
Register
(
69
FR
12398).
On
March
17,
2004,
EPA
announced
that
the
public
comment
period
on
the
NPR
and
SNPR
had
been
extended
to
April
30,
2004.
A
public
hearing
on
the
SNPR
was
held
in
Denver,
CO,
on
March
31,
2004,
during
which
time
members
of
the
public
could
provide
oral
comment
on
any
aspect
of
the
NPR
or
SNPR.
On
May
5,
2004,
EPA
announced
(
69
FR
25052)
that
the
public
comment
period
for
the
NPR
and
SNPR
had
been
reopened
and
extended
until
June
29,
2004.
On
December
1,
2004,
EPA
published
a
notice
of
data
availability
(
NODA)
with
a
public
comment
period
until
January
3,
2005
(
69
FR
69864).

In
addition
to
the
above­
noted
public
comment
process,
EPA
met
with
a
number
of
stakeholder
groups
and
has
placed
in
the
docket
records
of
these
meetings.
Approximately
500,000
public
comments
were
received
during
the
comment
period,
indicating
wide
public
interest
and
access.

At
proposal,
the
draft
information
collection
request
was
submitted
to
OMB
for
review
and
was
also
posted
on
the
Agency's
Internet
website
and
entered
into
the
docket
(
OAR­
2002­
0056)
for
9
public
review.
EPA
received
no
comments
specific
to
the
information
collection
burden
identified
in
the
initial
ICR
in
support
of
the
proposed
rule.
As
explained
further
below,
this
revision
incorporates
the
new
burden
estimates
that
have
been
made
for
the
recordkeeping
and
reporting
requirements
in
the
final
rule.

We
modified
these
burden
estimates,
in
part,
because
of
certain
changes
made
to
the
monitoring
requirements
in
the
final
rule
in
response
to
comments.

(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
required
by
the
final
rule
were
collected
less
frequently,
the
EPA
would
not
be
reasonably
assured
that
a
Utility
Unit
is
in
compliance
with
its
annual
cap­
and­
trade
program
Hg
emissions
allocation
and
the
12­
month
rolling
average
NSPS
emission
limit,
as
applicable
to
a
given
coal­
fired
Utility
Unit.

(
e)
General
Guidelines.

The
final
rule
would
require
owners
or
operators
of
an
affected
source
to
retain
records
for
5
years,
which
exceeds
the
3­

year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.10.

40
CFR
60.7(
f)
requires
that
records
be
retained
for
at
least
2
years.
The
5­
year
retention
period
is
consistent
with
the
requirement
in
the
operating
permit
program
under
Title
V
of
the
CAA.
These
records
must
be
kept
on
file
for
use,
if
needed,
by
the
regulating
authority
to
ensure
that
the
plant
personnel
are
10
operating
and
maintaining
the
unit
and
the
control
equipment
properly.
All
subsequent
general
guidelines
have
been
followed
and
do
not
violate
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.

(
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
36902,

September
1,
1976;
amended
by
43
FR
39999,
September
28,
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
final
rule
are
owners
or
operators
of
coal­
fired
Utility
Units;
oil­
fired
and
natural
gasfired
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.
11
Exhibits
1
and
2,
Source
Data
and
Information
Requirements,

summarize
the
recordkeeping
and
reporting
requirements
in
the
final
rule.

(
ii)
Respondent
Activities.
The
respondent
activities
required
by
the
final
rule
are
identified
in
Exhibit
3
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
Exhibit
4
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
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).

This
rule
would
not
directly
establish
requirements
applicable
to
existing
small
entities.
Instead,
it
would
require
States
and
affected
Tribal
governments
to
develop,
adopt,
and
submit
a
plan
that
would
achieve
the
necessary
Hg
emissions
reductions,
and
would
12
leave
to
the
States
the
task
of
determining
how
to
obtain
those
reductions,
including
which
coal­
fired
Utility
Units
to
regulate.

EPA's
analysis
of
the
final
rule
found
that
the
rule
would
not
have
a
significant
impact
on
a
substantial
number
of
existing
small
entities.
Analysis
conducted
for
the
final
rule
projects
that
in
2020,
two
years
into
the
start
of
the
second
phase
of
the
cap­

andtrade
program,
the
total
compliance
costs
to
small
entities
under
the
rule
would
be
approximately
$
37
million.
This
is
just
under
1
percent
of
the
total
projected
electricity
generation
revenues
to
small
entities
for
2020.
A
few
of
the
80
small
entities
identified
in
EPA
analysis
may
experience
significant
costs
in
2020.
These
entities
do
not
bank
allowances
over
the
course
of
the
program,
and
must
purchase
allowances
in
2020
to
cover
their
emissions.
It
is
important
to
note
that
the
marginal
cost
of
Hg
control
in
2020
projected
by
EPA
modeling
is
largely
responsible
for
the
presence
of
significant
impacts.
The
EPA
modeling
assumes
no
improvements
in
the
cost
or
effectiveness
of
Hg
control
technology
over
time.

In
reality,
by
2020,
costs
of
Hg
control
are
expected
to
have
declined,
such
that
the
actual
impacts
of
the
cap­
and­
trade
program
on
small
entities
will
be
less
than
projected.
Additionally,
given
that
most
of
the
small
entities
identified
operate
in
market
environments
in
which
they
can
pass
on
compliance
costs
to
consumers,
most
of
these
entities
should
be
able
to
recover
their
costs
of
compliance
with
the
rule.

Two
other
points
should
be
considered
when
evaluating
the
13
impact
of
final
rule,
specifically,
and
cap­
and­
trade
programs
more
generally,
on
existing
small
entities.
First,
under
the
final
rule,
the
cap­
and­
trade
program
is
designed
such
that
States
determine
how
Hg
allowances
are
to
be
allocated
across
units.
A
State
that
wishes
to
mitigate
the
impact
of
the
rule
on
small
entities
might
choose
to
allocate
Hg
allowances
in
a
manner
that
is
favorable
to
small
entities.
Finally,
the
use
of
cap­
and­
trade
in
general
will
limit
impacts
on
small
entities
relative
to
a
less
flexible
command­
and­
control
program.

The
final
rule
would
impose
requirements
on
a
new
source,
even
if
owned/
operated
by
a
small
entity.
The
final
rule
does
not
contain
any
provisions
reserved
exclusively
for
the
benefit
of
small
entities,
including
new
sources
that
could
be
owned/
operated
by
small
entities.
However,
the
final
rule
does
contain
several
provisions
that
reduce
the
impact
on
all
regulated
entities,
which
include
small
entities
(
e.
g.,
allowing
any
source
to
use
the
sorbent
trap
option,
compliance
flexibility
for
low
emitters,

relaxed
missing
data
procedures,
revision
of
Hg­
diluent
monitoring
system
requirements).

(
d)
Collection
Schedule.

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
14
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.

The
annual
burden
estimates
for
the
additional
recordkeeping
and
reporting
requirements
in
the
final
rules
are
shown
in
Exhibit
3.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
the
cap­
and­
trade
program
for
electric
utilities
under
the
Title
IV
Acid
Rain
program,
implementation
of
existing
NSPS,
and
similar
compliance­
related
information
collection
activities.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
the
final
rule
are
presented
in
Exhibit
3.

(
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
electric
utility
industry
workers
were
selected
using
labor
category
mean
hourly
wages
listed
in
the
November
2003
National
Industry­
Specific
Occupational
Employment
and
Wage
Estimates
for
North
American
Industry
Classification
System(
NAICS)
industry
1
Cost
Analysis
of
Mercury
Monitoring
Techniques.
Draft
report
prepared
by
Arcadis
for
Dr.
Ruben
Deza,
U.
S.
Environmental
Protection
Agency,
Washington,
DC.,
November
3,
2003.

15
category
221000
­
Utilities
(
available
at
<
http://
www.
bls.
gov/
oes/
current/
naics3_
221000.
htm>)
and
adjusted
to
2004
costs
using
the
change
in
the
BLS
Employment
Cost
Index
for
the
private
industry
sector
from
the
years
2003
to
2004
(
3.8
percent).
The
labor
rates
used
for
the
burden
estimates
are
$
48.95/
hour
for
managerial
(
2003
mean
for
management
occupations
category
of
$
47.15/
hr
times
1.038),
$
33.17/
hour
for
technical
(
2003
mean
for
architecture
and
engineering
occupations
category
of
$
31.95/
hr
times
1.038),
and
$
18.96/
hour
for
clerical
(
2003
mean
for
office
and
administrative
support
occupations
category
of
$
18.26/
hr
times
1.038).
An
overhead
rate
of
110
percent
was
used
to
account
for
overhead
costs.
The
fully
burden
rates
used
to
represent
respondent
labor
costs
are:
clerical
at
$
39.82,
technical
at
$
69.66,
and
management
at
$
102.80.

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

Costs.
Estimation
of
the
capital
and
operations
and
maintenance
(
O&
M)
costs
are
largely
based
on
information
collected
by
the
EPA's
Clean
Air
Markets
Division,
specifically
the
technical
report,

"
Cost
Analysis
of
Mercury
Monitoring
Techniques"
1;
a
second
cost
analysis
performed
by
MACTEC
Inc.;
and
additional
information
obtained
by
the
Agency
in
the
development
of
the
rule.

Based
on
available
cost
information,
the
EPA
estimates
that
16
the
costs
for
Hg
emissions
testing
required
for
an
LME
coal­
fired
Utility
Unit
will
average
about
$
5,500
per
test.
An
additional
$
1,500
in
annual
costs
are
estimated
for
technical
calculations,

labor
and
other
associated
expenses.
An
LME
unit
with
annual
Hg
emissions
less
than
9
lb/
yr
are
required
under
the
rule
to
perform
annual
emission
testing.
The
LME
units
with
annual
Hg
emissions
greater
than
9
lb/
yr
but
less
than
29
lb/
yr
are
required
under
the
rule
to
perform
semiannual
emission
testing.

For
Hg
CEMS,
there
are
two
major
cost
components
to
be
considered,
capital
costs
and
operational
costs.
Based
on
a
survey
of
11
manufacturers,
it
is
estimated
that
an
average
capital
cost
of
a
Hg
CEM
is
$
60,000.
In
addition,
each
source
needs
to
purchase
a
HOVOCAL
or
MERcal
unit
to
generate
ionic
mercury,
which
is
necessary
for
CEMS
calibration.
The
approximate
cost
of
either
instrument
is
$
10,000.
Based
on
these
costs,
the
capital
cost
of
a
complete
Hg
CEMS
is
estimated
to
be
about
$
70,000.
The
operational
costs
can
also
be
broken
into
two
components,
i.
e.,

routine
maintenance
and
operation,
and
quality
assurance/
control
procedures.
These
costs
are
estimated
at
$
87,000
per
year
and
are
the
same
basic
cost
estimates
as
were
used
in
the
initial
ICR.

The
Hg
sorbent
trap
method
system
used
for
semi­
continuous
monitoring
of
Hg
emissions
includes
a
carbon
trap
with
a
threesection
cartridge:
a
primary
capture
cartridge,
backup
for
breakthough,
and
a
portion
for
spiking
for
QA/
QC.
Two
carbon
traps
would
be
run
in
parallel
for
one­
week
runs.
The
cost
for
a
trap
17
system
is
estimated
be
$
8,500.
Capital
cost
including
the
installation
of
the
complete
system
is
estimated
to
be
about
$
20,000.
The
annual
operational
costs
to
use
this
monitoring
method
include
routine
operational
costs,
laboratory
costs
to
analyze
Hg
in
capture
cartridges,
and
costs
to
perform
QA/
QC
procedures.
The
total
for
these
operational
costs
is
estimated
to
about
$
113,000
per
year.

(
iii)
Capital/
Startup
vs.
O&
M
Costs.
The
estimate
of
capital/
startup
costs
versus
O&
M
costs
for
implementing
the
Hg
monitoring
required
by
the
rule
is
shown
in
the
following
table.

The
basis
for
the
nationwide
numbers
of
coal­
fired
Utility
Units
shown
in
the
table
using
a
given
Hg
emissions
monitoring
method
is
presented
in
section
6(
c)
of
this
supporting
statement.

Capital/
Startup
vs.
O&
M
Costs
Mercury
(
Hg)
Emissions
Monitoring
Method
Nationwide
Number
of
Units
Using
Method
Per
Unit
Costs
Nationwide
Costs
Capital/
Startup
Cost
Annual
O&
M
Cost
Capital
Costs
($
1000)
Annual
O&
M
Costs
($
1000)

LME
Annual
HG
Emission
Testing
228
0
$
7,000
$
0
$
1,596
LME
Semiannual
HG
Emission
Testing
207
0
$
12,500
$
0
$
2,588
Hg
CEMS
347
$
70,000
$
87,000
$
24,290
$
30,189
Hg
Sorbent
Trap
343
$
20,000
$
113,000
$
6,860
$
38,759
Total
1,125
­­­
­­­
$
31,150
$
73,132
(
iv)
Annualizing
Capital
Costs.
The
estimate
of
18
capital/
startup
costs
versus
O&
M
costs
for
implementing
the
Hg
monitoring
required
by
the
rule
is
shown
in
the
following
table.

Annualized
costs
are
calculated
assuming
a
7
percent
interest
rate
and
a
3­
year
depreciation
period.

Annualized
Costs
Mercury
(
Hg)
Emissions
Monitoring
Method
Nationwide
Number
of
Units
Using
Method
Nationwide
Annualized
Costs
Annualized
Capital
Cost
($
1000)
Annual
O&
M
Costs
($
1000)
Total
Annualized
Cost
($
1000)

LME
Annual
Hg
emissions
testing
228
0
$
1,596
$
1,596
LME
Semiannual
Hg
emissions
testing
207
0
$
2,588
$
2,588
Hg
CEMS
347
$
9,256
$
30,189
$
39,445
Hg
Sorbent
Trap
343
$
2,614
$
38,759
$
41,373
Total
1,125
$
11,870
$
73,132
$
85,002
(
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
applicable
rule
provisions
in
40
CFR
parts
60
and
75,
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
19
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.

Costs
that
the
Federal
government
will
incur
associated
with
the
final
rule
are
user
costs
associated
the
one­
time
review
and
approval
of
the
plans
submitted
by
States
and
Tribal
governments
participating
in
the
Hg
cap­
and­
trade
program
and
with
the
analysis
of
the
additional
Hg
emissions
information
included
in
the
notifications
and
reports
that
coal­
fired
Utility
Unit
owners
and
operators
are
already
required
to
submit
under
40
CFR
parts
60
and
75.
The
Agency
tasks
that
will
be
performed
include
processing,
reviewing,
and
evaluating
Hg
emissions
data
in
the
reports
submitted
by
owners
and
operators,
and
conducting
appropriate
audit
activities
to
verify
the
information
provided.

Exhibit
4
presents
an
estimate
of
the
Agency
burden
and
costs
associated
with
emissions
reporting.

The
Agency
labor
rates
used
for
estimating
the
Agency
costs
are
from
the
Office
of
Personnel
Management
(
OPM)
2004
General
Schedule
which
excludes
locality
rates
of
pay.
These
rates
were
obtained
from
Salary
Table
2004­
GS
available
on
the
OPM
website
(
http://
http://
www.
opm.
gov/
oca/
04tables/
html/
gs.
asp).
The
government
employee
labor
rates
are
$
14.34/
hour
for
clerical
(
GS­
7,
Step
1),
$
30.24
for
technical
(
GS­
13,
Step
1),
and
20
$
42.04/
hr
for
management
(
GS­
15,
Step
1).
An
overhead
rate
of
60
percent
was
used
to
account
for
overhead
costs.
The
fully
burdened
rates
used
to
represent
respondent
labor
costs
are:

clerical
at
$
22.94,
technical
at
$
48.38,
and
management
at
$
67.26.

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

To
estimate
the
number
of
respondents,
the
EPA
used
data
available
from
the
1999
Mercury
Information
Collection
Request
(
ICR).
This
ICR
provided
mercury
emission
information
on
a
total
of
1,120
existing
Utility
Units.
For
the
purpose
of
the
nationwide
burden
estimates,
each
coal­
fired
Utility
Unit
is
counted
as
an
industry
respondent.
In
actuality,
at
many
power
plant
sites,
there
are
multiple
coal­
fired
Utility
Units
subject
to
the
final
rule.
In
these
cases,
some
rule
reporting
and
recordkeeping
related
activities
can
be
performed
by
the
facility
owner
or
operator
on
a
plant­
wide
basis
(
e.
g.,
planning
activities,
developing
record
system,
and
training
facility
personnel)
instead
of
on
a
per
coal­
fired
Utility
Unit
basis
as
is
assumed
for
the
burden
estimates.
Therefore,
we
believe
that
our
burden
estimates
are
conservative.

In
addition,
the
EPA
estimates
that
five
new
coal­
fired
steam
generating
units
will
be
built
during
the
next
5
years
and
subject
to
the
NSPS
emission
limits.
21
The
EPA
estimates,
based
on
the
ICR
data,
the
nationwide
distribution
of
coal­
fired
Utility
Units
subject
to
the
final
rule
as
follows:

Nationwide
Respondent
Distribution
By
Coal­
fired
Utility
Unit
Category
Coal­
fired
Utility
Unit
Category
Nationwide
Number
of
Units
Existing
coal­
fired
Utility
Units
with
Hg
emissions
levels
<
9
lb/
yr
228*

Existing
coal­
fired
Utility
Units
with
Hg
emissions
levels
>
9
and
<
29
lb/
y
207*

Existing
coal­
fired
Utility
Units
with
Hg
emissions
levels
>
29
lb/
yr
685
New
coal­
fired
Utility
Units
constructed
after
January
31,
2004
5
Total
1,125
*
Designated
LME
units
under
the
rule
requirements.

For
the
purpose
of
estimating
burden,
it
is
assumed
that
all
of
the
respondents
will
install
and
begin
operation
of
monitoring
systems
in
the
first
year
following
promulgation
of
the
final
rule.
For
those
existing
units
required
to
conduct
continuous
Hg
emissions
monitoring,
it
is
assumed
that
50
percent
will
use
Hg
CEMS
and
50
percent
will
use
Hg
sorbent
traps.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours
and
costs
for
the
first
3
years
following
promulgation
are
presented
in
Exhibits
3a,
3b,
and
3c.
The
bottom
line
respondent
burden
hours
and
labor
costs
are
calculated
by
adding
person­
22
hours
per
year
down
each
column
in
the
tables
for
technical,

managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.

Respondent
Bottom
Line
Burden
Hours
and
Labor
Costs
Year
Total
Annual
Burden
Hours
Total
Annual
Labor
Costs
1st
year
902,238
hours
$
61,805,909
2nd
year
615,370
hours
$
42,154,650
3rd
year
615,370
hours
$
42,154,650
Average
710,993
hours
$
48,705,070
The
annualized
cost
of
capital
for
Hg
monitoring
devices
is
$
11,865,949
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
$
73,131,500
per
year.
The
total
cost
including
the
average
cost
of
labor
over
the
3­
year
period,

capital,
operation
and
maintenance,
is
$
121,836,570
per
year.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs
for
the
first
3
years
following
promulgation
are
presented
in
Exhibit
4.
The
bottom
line
Agency
burden
hours
and
costs
are
calculated
by
adding
person­
hours
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
23
of
this
total
salary
cost
and
total
travel
expenses
for
government
personnel
to
observe
compliance
tests
at
a
selected
number
of
coal­
fired
Utility
Units
each
year.

Agency
Bottom
Line
Burden
Hours
and
Labor
Costs
Year
Total
Annual
Burden
Hours
Total
Annual
Labor
Costs
1st
year
47,877
hours
$
2,249,860
2nd
year
33,249
hours
$
1,562,451
3rd
year
33,249
hours
$
1,562,451
Average
38,125
hours
$
1,791,587
The
total
annual
hours
over
the
3­
year
period
are
38,125.

The
total
annual
cost
over
the
3­
year
period
is
$
1,791,587.

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

(
f)
Reasons
for
Change
in
Burden.

In
the
proposed
rule,
EPA
proposed
two
primary
alternative
regulatory
options.
One
of
those
regulatory
options
involved
the
proposed
issuance
of
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
under
CAA
section
112,
and
the
other
involved
the
issuance
of
standards
of
performance
under
CAA
section
111.
Under
either
regulatory
option,
however,
the
same
universe
of
coal­
fired
Utility
Units
would
be
affected
because
both
options
govern
new
and
existing
coal­
fired
units.
In
addition,
under
both
the
CAA
section
112
and
CAA
section
111
24
regulatory
options,
we
required
similar
monitoring
(
i.
e.,
both
regulatory
options
required
the
use
of
either
CEMS
or
sorbent
trap
monitoring),
reporting,
and
recordkeeping
requirements,
and
we
solicited
comment
on
those
proposed
requirements.

The
burden
estimates
in
the
initial
ICR
prepared
for
the
proposed
rule
were
based
on
the
proposed
CAA
section
112
regulatory
option,
which
again
covered
the
same
universe
of
coalfired
Utility
Units
as
the
CAA
section
111
regulatory
approach
and
the
same
general
monitoring,
reporting,
and
recordkeeping
requirements.
The
initial
version
of
the
ICR
also
included
burden
estimates
for
oil­
fired
Utility
Units
because
both
the
CAA
section
112
regulatory
option
and
the
CAA
section
111
option
proposed
requiring
reductions
of
nickel
from
oil­
fired
units.
We
did
not
receive
any
comments
from
the
public
or
OMB
concerning
the
burden
estimates
provided
in
the
initial
version
of
the
ICR.

Based
on
a
thorough
review
of
the
comments
received
in
response
to
the
proposal,
EPA
finalized
the
CAA
section
111
regulatory
approach.
The
final
CAA
section
111
rule
sets
standards
of
performance
for
Hg
emitted
from
new
and
existing
coal­
fired
Utility
Units
and
requires
certain
monitoring,

reporting,
and
recordkeeping
as
described
generally
in
this
document
and
more
fully
in
the
preamble
to
the
final
rule.
In
addition,
the
final
rule
only
covers
coal­
fired
Utility
Units,

not
oil­
fired
units.
We
made
this
change
in
the
final
rule
in
response
to
comments
received
concerning
nickel
emissions
from
25
oil­
fired
Utility
Units.

We
also
received
several
comments
in
response
to
the
proposed
rule
concerning
the
proposed
monitoring
and
associated
requirements
for
coal­
fired
Utility
Units.
We
made
certain
changes
in
the
final
rule
in
light
of
those
comments.
The
changes
made
address
commenters'
concerns
regarding,
for
example,

allowing
any
source
to
use
the
sorbent
trap
option,
providing
increased
compliance
flexibility
for
low
emitters;
modifying
the
procedures
for
missing
data;
and
revising
the
Hg­
diluent
monitoring
system
requirements.
As
noted
below,
however,
not
all
changes
made
as
a
result
of
the
public
comments
received
resulted
in
a
decreased
burden
estimate.

In
addition
to
modifying
the
burden
estimates
in
response
to
the
changes
made
to
the
monitoring
requirements
in
the
final
rule,
we
made
certain
other
adjustments
to
our
burden
estimates.

Those
adjustments
resulted
in
a
burden
estimate
for
the
final
rule
that
is
higher
than
the
burden
estimate
in
support
of
the
proposed
rule.
The
reasons
for
the
difference
in
the
burden
estimates
are
as
follows:

1.
The
burden
estimate
at
proposal
failed
to
account
for
new
units,
even
though
we
proposed
CAA
section
112(
d)
emission
standards
for
such
units.
This
omission
was
an
inadvertent
error.
As
noted
above,
we
estimate
that
five
new
coal­
fired
steam
generating
units
will
be
built
during
the
next
5
years.

2.
For
the
burden
estimate
at
proposal,
a
"
respondent"
was
26
defined
to
be
an
individual
power
plant
(
461
coal­
fired
plants).

For
the
final
rule
burden
estimate,
a
"
respondent"
was
defined
to
be
an
individual
coal­
fired
Utility
Unit
(
1,125
units).
Overall,

the
assumption
used
for
the
final
rule
is
more
conservative
than
at
proposal
because
many
power
plants
have
multiple
affected
coal­
fired
Utility
Units,
and,
therefore,
the
burden
activities
can
be
performed
on
a
plant­
wide
basis
instead
of
on
a
per­
unit
basis
as
is
assumed
for
the
burden
calculations
(
i.
e.,
the
burden
associated
with
reading
instructions,
training
personnel,
and
like
activities
is
being
shared
by
the
units
and,
thus,
is
somewhat
lower
that
if
attributed
to
each
unit).
Thus,
although
we
changed
the
definition
of
the
term
"
respondent,"
the
initial
version
of
the
ICR
and
this
revision
both
address
the
same
general
universe
of
coal­
fired
Utility
Units.
In
addition,
we
believe
that
a
Utility
Unit­
based
burden
calculation
better
reflects
the
monitoring
requirements
for
LME
units.

3.
For
the
final
burden
estimate,
it
was
assumed
than
all
States
and
affected
Tribal
governments
would
participate
in
the
cap­

andtrade
program
and
that
all
existing
coal­
fired
Utility
Units
would
implement
the
required
Hg
monitoring
during
the
first
year
following
promulgation.
For
the
burden
estimate
for
the
proposed
rule,
it
was
assumed
that
Hg
monitoring
would
be
phased
in
over
the
3­
year
compliance
period
allowed
for
NESHAP
rules
(
i.
e.,

onethird
of
the
power
plants
installing
CEMS
during
the
first
year,

another
one­
third
installing
CEMS
during
the
second
year,
and
the
27
final
one­
third
installing
CEMS
during
the
third
year).
Assuming
compliance
in
the
first
year,
therefore,
resulted
in
increased
burden
estimates.

4.
Allowing
use
of
the
sorbent
trap
method
allocates
more
cost
to
the
source
but
provides
greater
flexibility
in
monitoring
options,
which
is
what
many
commenters
wanted.
In
the
burden
estimates
for
the
final
rule,
it
was
assumed
that
50
percent
of
affected
Utility
Units
would
choose
to
use
the
sorbent
trap
method.

(
g)
Burden
Statement
The
average
annual
respondent
burden
during
the
first
3­
year
period
following
rule
promulgation
is
estimated
at
632
hours
per
respondent.
This
is
based
on
an
estimated
total
710,993
hours
per
year
(
as
averaged
over
the
rule
first
3­
year
period
following
promulgation)
for
a
projected
1,125
respondents.

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
28
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
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.
29
Exhibit
1.
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
UNDER
40
CFR
PART
60
SUBPART
HHHH
EMISSION
GUIDELINES
AND
COMPLIANCE
TIMES
FOR
COAL­
FIRED
ELECTRIC
STEAM
GENERATING
UNITS
REQUIREMENT
REGULATION
CITATION
RECORD
RETENTION
Reports
Notifications
§
75.61
5
years
Certification
applications
§
75.63
5
years
Quarterly
reports
§
75.64
5
years
QA/
QC
plan
Part
75
Appendix
B
Section
1
5
years
Recordkeeping
General
recordkeeping
requirements
§
75.57
5
years
Recordkeeping
for
special
situations
§
75.58
5
years
Quality
assurance
recordkeeping
§
75.59
5
years
QA/
QC
recordkeeping
Part
75
Appendix
B
Section
1
5
years
30
Exhibit
2.
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
UNDER
40
CFR
PART
60
SUBPART
Da
NEW
SOURCE
PERFORMANCE
STANDARDS
FOR
COAL­
FIRED
ELECTRIC
UTILITY
STEAM
GENERATING
UNITS
REQUIREMENT
REGULATION
CITATION
RECORD
RETENTION
Reports
Initial
notifications
as
applicable
to
facility(
i.
e.,
date
of
construction
or
reconstruction,
dates
of
anticipated
and
actual
startup,
modifications
to
existing
facility)
§
60.7(
a)(
1)­(
4)
5
years
Notification
of
performance
tests
§
60.8(
d)
5
years
Notification
of
CEM
performance
evaluation
§
60.7(
a)(
5)
5
years
Semi­
annual
compliance
report
§
60.51a(
i)
5
years
Recordkeeping
Records
of
notifications
and
reports,
performance
tests,
performance
evaluations,
monitoring
data,
performance
evaluation
test
plan
§
60.52a
5
years
Startup,
shutdowns,
and
malfunctions
§
60.7(
b)
5
years
Records
required
to
demonstrate
continuous
compliance
with
emission
limits
§
60.52a
5
years
31
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)
(
H)

Personhours
per
occurrence
No.
of
occurrences
per
respondent
(
see
note
a)
Personhours
per
re
spondent
(
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
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
240
1
240
342
82,080
4,104
8,208
$
6,466,127
B.
Acquire
and
install
Hg
sorbent
traps
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
240
1
240
343
82,320
4,116
8,232
$
6,485,034
C.
Acquire
and
install
Hg
CEMS
for
new
coal­
fired
units
subject
to
NSPS
240
1
240
5
1,200
60
120
$
94,534
4.
Reporting
Requirements
0
A.
Read
instructions
(
see
note
c)
8
1
8
1,125
9,000
450
900
$
709,005
B.
Required
activities
0
i.
Prepare
monitoring
plan
40.0
1
40
690
27,600
1,380
2,760
$
2,174,282
ii.
Collect
data
for
coal­
fired
units
0.5
365
182.5
1,125
205,313
10,266
20,531
$
16,174,180
iii.
Perform
LME
for
existing
coal­
fired
units
with
Hg
emissions
<
9
lb/
yr
40
1
40
228
9,120
456
912
$
718,459
vi.
Perform
LME
for
existing
coal­
fired
units
with
9
lb/
yr
<
Hg
emissions
<
29
lb/
yr
40
2
80
207
16,560
828
1,656
$
1,304,569
v.
Operate
Hg
CEMS
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
0.5
365
182.5
342
62,415
3,121
6,242
$
4,916,951
vi.
Operate
Hg
sorbent
traps
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
0.5
365
182.5
343
62,598
3,130
6,260
$
4,931,328
vii.
Operate
Hg
CEMS
for
new
coal­
fired
units
subject
to
NSPS
0.5
365
182.5
5
913
46
91
$
71,885
viii.
Calculate
12­
mo.
rolling
average
Hg
emission
rate
in
lb/
MW
for
new
coal­
fired
units
subject
to
NSPS
8
12
96
5
480
24
48
$
37,814
Exhibit
3a.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
FINAL
RULE
First
Year
After
Promulgation
Burden
item
32
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
reports
i.
Initial
notification
2
1
2
1,125
2,250
113
225
$
177,251
ii.
LME
emission
test
notification
(
see
note
c)
2
1.5
3
435
1,305
65
131
$
102,806
iii.
Notification
of
monitoring
performance
evaluation
2
1
2
690
1,380
69
138
$
108,714
iv.
LME
report
for
existing
coal­
fired
units
with
Hg
emissions
<
9
lb/
yr
16
1
16
228
3,648
182
365
$
287,383
v.
LME
report
for
existing
coal­
fired
units
with
9
lb/
yr
<
Hg
emissions
<
29
lb/
yr
16
2
32
207
6,624
331
662
$
521,828
vi.
Hg
monitoring
data
quarterly
report
for
existing
coal­
fired
units
2
4
8
685
5,480
274
548
$
431,705
vi.
Hg
monitoring
data
quarterly
report
for
new
coal­
fired
units
subject
to
NSPS
2
4
8
5
40
2
4
$
3,151
vii.
Semiannual
compliance
report
for
new
coal­
fired
units
subject
to
NSPS
16
2
32
5
160
8
16
$
12,605
5.
Recordkeeping
Requirements
A.
Read
instructions
(
see
note
c)
See
4A
0
B.
Plan
activities
(
see
note
c)
40
1
40
1,125
45,000
2,250
4,500
$
3,545,026
C.
Implement
activities
See
4B
D.
Develop
record
system
(
see
note
c)

i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
8
1
8
435
3,480
174
348
$
274,149
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
24
1
24
685
16,440
822
1,644
$
1,295,116
iii.
New
coal­
fired
units
subject
to
NSPS
40
1
40
5
200
10
20
$
15,756
E.
T
ime
to
enter
information
i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
1
2
2
435
870
44
87
$
68,537
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
1
52
52
685
35,620
1,781
3,562
$
2,806,085
iii.
New
coal­
fired
units
subject
to
NSPS
1
52
52
5
260
13
26
$
20,482
F.
T
ime
to
train
personnel
i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
40
1
40
435
17,400
870
1,740
$
1,370,743
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
80
1
80
435
34,800
1,740
3,480
$
2,741,487
iii.
New
coal­
fired
units
subject
to
NSPS
100
1
100
5
500
25
50
$
39,389
33
G.
T
ime
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
(
see
note
c)
40
1
40
1,125
45,000
2,250
4,500
$
3,545,026
H.
T
ime
to
transmit
or
disclose
information
1
4
4
1,125
4,500
225
450
$
354,503
I.
Time
for
audits
(
see
note
e)

TOTAL
LABOR
BURDEN
AND
COST
784,555
39,228
78,455
$
61,805,909
Annualized
cost
of
capital
(
see
note
f)
$
11,869,759
Operation
and
maintenance
(
O&
M)
$
73,131,500
Total
(
capital
recovery
+
O&
M
costs)
$
85,001,259
NOTES:

N/
A
=
Not
applicable
a.
"
Respondent"
defined
to
be
owner/
operator
for
each
individual
electric
utility
coal­
fired
steam
generating
unit
b
Costs
are
based
on
the
following
hourly
total
compensation
rates
for
respondent
employees:
technical
at
$
33.17,
management
at
$
48.95,
and
clerical
at
$
18.96.

The
fully
burdened
rates
used
in
this
table
are:
technical
at
$
69.66,
management
at
$
102.80,
and
clerical
at
$
39.82.

e.
T
ime
for
audit
of
Hg
monitoring
systems
addresses
by
Relative
Accuracy
T
est
Audit
(
RATA)
included
as
part
of
Item
4.
B.
v
­
vii
d.
Labor
hour
requirements,
capital
costs,
and
O&
M
costs
for
Hg
CEMS
and
sorbent
trap
systems
based
on
information
prepared
for
U.
S.
EPA
Clean
Air
Markets
Division,
February
2005
f.
Annualized
costs
calculated
assuming
a
7%
interest
rate
and
a
3­
year
depreciation
period.

c.
Average
notification
occurrences
based
on
228
LME
units
performing
annual
test
and
207
LME
units
performing
semi­
annual
test
rounded
to
1.5.
34
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)
(
H)

Personhours
per
occurrence
No.
of
occurrences
per
respondent
(
see
note
a)
Personhours
per
re
spondent
(
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
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
240
(
see
note
c)
0
342
0
0
0
$
0
B.
Acquire
and
install
Hg
sorbent
traps
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
240
(
see
note
c)
0
343
0
0
0
$
0
C.
Acquire
and
install
Hg
CEMS
for
new
coal­
fired
units
subject
to
NSPS
240
(
see
note
c)
0
5
0
0
0
$
0
4.
Reporting
Requirements
0
A.
Read
instructions
(
see
note
c)
8
(
see
note
c)
0
1,125
0
0
0
$
0
B.
Required
activities
0
i.
Prepare
monitoring
plan
40.0
(
see
note
c)
0
690
0
0
0
$
0
ii.
Collect
data
for
coal­
fired
units
0.5
365
182.5
1,125
205,313
10,266
20,531
$
16,174,180
iii.
Perform
LME
for
existing
coal­
fired
units
with
Hg
emissions
<
9
lb/
yr
40
1
40
228
9,120
456
912
$
718,459
vi.
Perform
LME
for
existing
coal­
fired
units
with
9
lb/
yr
<
Hg
emissions
<
29
lb/
yr
40
2
80
207
16,560
828
1,656
$
1,304,569
v.
Operate
Hg
CEMS
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
0.5
365
182.5
342
62,415
3,121
6,242
$
4,916,951
vi.
Operate
Hg
sorbent
traps
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
0.5
365
182.5
343
62,598
3,130
6,260
$
4,931,328
vii.
Operate
Hg
CEMS
for
new
coal­
fired
units
subject
to
NSPS
0.5
365
182.5
5
913
46
91
$
71,885
viii.
Calculate
12­
mo.
rolling
average
Hg
emission
rate
in
lb/
MW
for
new
coal­
fired
units
subject
to
NSPS
8
12
96
5
480
24
48
$
37,814
Exhibit
3b.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
FINAL
RULE
Second
Year
After
Promulgation
Burden
item
35
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
reports
i.
Initial
notification
2
(
see
note
c)
0
1,125
0
0
0
$
0
ii.
LME
emission
test
notification
2
1.5
3
435
1,305
65
131
$
102,806
iii.
Notification
of
monitoring
performance
evaluation
2
1
2
690
1,380
69
138
$
108,714
iv.
LME
report
for
existing
coal­
fired
units
with
Hg
emissions
<
9
lb/
yr
16
1
16
228
3,648
182
365
$
287,383
v.
LME
report
for
existing
coal­
fired
units
with
9
lb/
yr
<
Hg
emissions
<
29
lb/
yr
16
2
32
207
6,624
331
662
$
521,828
vi.
Hg
monitoring
data
quarterly
report
for
existing
coal­
fired
units
2
4
8
685
5,480
274
548
$
431,705
vi.
Hg
monitoring
data
quarterly
report
for
new
coal­
fired
units
subject
to
NSPS
2
4
8
5
40
2
4
$
3,151
vii.
Semiannual
compliance
report
for
new
coal­
fired
units
subject
to
NSPS
16
2
32
5
160
8
16
$
12,605
5.
Recordkeeping
Requirements
A.
Read
instructions
(
see
note
c)
See
4A
0
B.
Plan
activities
(
see
note
c)
40
1
40
1,125
45,000
2,250
4,500
$
3,545,026
C.
Implement
activities
See
4B
D.
Develop
record
system
(
see
note
c)

i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
8
1
8
435
3,480
174
348
$
274,149
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
24
1
24
685
16,440
822
1,644
$
1,295,116
iii.
New
coal­
fired
units
subject
to
NSPS
40
1
40
5
200
10
20
$
15,756
E.
T
ime
to
enter
information
i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
1
2
2
435
870
44
87
$
68,537
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
1
52
52
685
35,620
1,781
3,562
$
2,806,085
iii.
New
coal­
fired
units
subject
to
NSPS
1
52
52
5
260
13
26
$
20,482
F.
T
ime
to
train
personnel
i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
40
1
40
435
17,400
870
1,740
$
1,370,743
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
80
1
80
435
34,800
1,740
3,480
$
2,741,487
iii.
New
coal­
fired
units
subject
to
NSPS
100
1
100
5
500
25
50
$
39,389
36
G.
T
ime
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
(
see
note
c)
40
(
see
note
c)
0
1,125
0
0
0
$
0
H.
T
ime
to
transmit
or
disclose
information
1
4
4
1,125
4,500
225
450
$
354,503
I.
Time
for
audits
(
see
note
e)

TOTAL
LABOR
BURDEN
AND
COST
535,105
26,755
53,510
$
42,154,650
Annualized
cost
of
capital
(
see
note
f)
$
11,869,759
Operation
and
maintenance
(
O&
M)
$
73,131,500
Total
(
capital
recovery
+
O&
M
costs)
$
85,001,259
NOTES:

N/
A
=
Not
applicable
a.
"
Respondent"
defined
to
be
owner/
operator
for
each
individual
electric
utility
coal­
fired
steam
generating
unit
b
Costs
are
based
on
the
following
hourly
total
compensation
rates
for
respondent
employees:
technical
at
$
33.17,
management
at
$
48.95,
and
clerical
at
$
18.96.

The
fully
burdened
rates
used
in
this
table
are:
technical
at
$
69.66,
management
at
$
102.80,
and
clerical
at
$
39.82.

e.
T
ime
for
audit
of
Hg
monitoring
systems
addresses
by
Relative
Accuracy
T
est
Audit
(
RATA)
included
as
part
of
Item
4.
B.
v
­
vii
d.
Labor
hour
requirements,
capital
costs,
and
O&
M
costs
for
Hg
CEMS
and
sorbent
trap
systems
based
on
information
prepared
for
U.
S.
EPA
Clean
Air
Markets
Division,
February
2005
f.
Annualized
costs
calculated
assuming
a
7%
interest
rate
and
a
3­
year
depreciation
period.

c.
One
time
event
over
the
first
3­
year
term
of
the
ICR
following
promulgation
of
the
rule
assumed
to
be
completed
during
the
1st
year.
37
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)
(
H)

Personhours
per
occurrence
No.
of
occurrences
per
respondent
(
see
note
a)
Personhours
per
re
spondent
(
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
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
240
(
see
note
c)
0
342
0
0
0
$
0
B.
Acquire
and
install
Hg
sorbent
traps
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
240
(
see
note
c)
0
343
0
0
0
$
0
C.
Acquire
and
install
Hg
CEMS
for
new
coal­
fired
units
subject
to
NSPS
240
(
see
note
c)
0
5
0
0
0
$
0
4.
Reporting
Requirements
0
A.
Read
instructions
(
see
note
c)
8
(
see
note
c)
0
1,125
0
0
0
$
0
B.
Required
activities
0
i.
Prepare
monitoring
plan
40.0
(
see
note
c)
0
690
0
0
0
$
0
ii.
Collect
data
for
coal­
fired
units
0.5
365
182.5
1,125
205,313
10,266
20,531
$
16,174,180
iii.
Perform
LME
for
existing
coal­
fired
units
with
Hg
emissions
<
9
lb/
yr
40
1
40
228
9,120
456
912
$
718,459
vi.
Perform
LME
for
existing
coal­
fired
units
with
9
lb/
yr
<
Hg
emissions
<
29
lb/
yr
40
2
80
207
16,560
828
1,656
$
1,304,569
v.
Operate
Hg
CEMS
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
0.5
365
182.5
342
62,415
3,121
6,242
$
4,916,951
vi.
Operate
Hg
sorbent
traps
for
existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
0.5
365
182.5
343
62,598
3,130
6,260
$
4,931,328
vii.
Operate
Hg
CEMS
for
new
coal­
fired
units
subject
to
NSPS
0.5
365
182.5
5
913
46
91
$
71,885
viii.
Calculate
12­
mo.
rolling
average
Hg
emission
rate
in
lb/
MW
for
new
coal­
fired
units
subject
to
NSPS
8
12
96
5
480
24
48
$
37,814
Exhibit
3c.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
FINAL
RULE
Third
Year
After
Promulgation
Burden
item
38
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
reports
i.
Initial
notification
2
(
see
note
c)
0
1,125
0
0
0
$
0
ii.
LME
emission
test
notification
2
1.5
3
435
1,305
65
131
$
102,806
iii.
Notification
of
monitoring
performance
evaluation
2
1
2
690
1,380
69
138
$
108,714
iv.
LME
report
for
existing
coal­
fired
units
with
Hg
emissions
<
9
lb/
yr
16
1
16
228
3,648
182
365
$
287,383
v.
LME
report
for
existing
coal­
fired
units
with
9
lb/
yr
<
Hg
emissions
<
29
lb/
yr
16
2
32
207
6,624
331
662
$
521,828
vi.
Hg
monitoring
data
quarterly
report
for
existing
coal­
fired
units
2
4
8
685
5,480
274
548
$
431,705
vi.
Hg
monitoring
data
quarterly
report
for
new
coal­
fired
units
subject
to
NSPS
2
4
8
5
40
2
4
$
3,151
vii.
Semiannual
compliance
report
for
new
coal­
fired
units
subject
to
NSPS
16
2
32
5
160
8
16
$
12,605
5.
Recordkeeping
Requirements
A.
Read
instructions
(
see
note
c)
See
4A
0
B.
Plan
activities
(
see
note
c)
40
1
40
1,125
45,000
2,250
4,500
$
3,545,026
C.
Implement
activities
See
4B
D.
Develop
record
system
(
see
note
c)

i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
8
1
8
435
3,480
174
348
$
274,149
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
24
1
24
685
16,440
822
1,644
$
1,295,116
iii.
New
coal­
fired
units
subject
to
NSPS
40
1
40
5
200
10
20
$
15,756
E.
T
ime
to
enter
information
i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
1
2
2
435
870
44
87
$
68,537
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
1
52
52
685
35,620
1,781
3,562
$
2,806,085
iii.
New
coal­
fired
units
subject
to
NSPS
1
52
52
5
260
13
26
$
20,482
F.
T
ime
to
train
personnel
i.
Existing
coal­
fired
units
with
Hg
emissions
<
29
lb/
yr
40
1
40
435
17,400
870
1,740
$
1,370,743
ii.
Existing
coal­
fired
units
with
Hg
emissions
>
29
lb/
yr
80
1
80
435
34,800
1,740
3,480
$
2,741,487
iii.
New
coal­
fired
units
subject
to
NSPS
100
1
100
5
500
25
50
$
39,389
39
G.
T
ime
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
(
see
note
c)
40
(
see
note
c)
0
1,125
0
0
0
$
0
H.
T
ime
to
transmit
or
disclose
information
1
4
4
1,125
4,500
225
450
$
354,503
I.
Time
for
audits
(
see
note
e)

TOTAL
LABOR
BURDEN
AND
COST
535,105
26,755
53,510
$
42,154,650
Annualized
cost
of
capital
(
see
note
f)
$
11,869,759
Operation
and
maintenance
(
O&
M)
$
73,131,500
Total
(
capital
recovery
+
O&
M
costs)
$
85,001,259
NOTES:

N/
A
=
Not
applicable
a.
"
Respondent"
defined
to
be
owner/
operator
for
each
individual
electric
utility
coal­
fired
steam
generating
unit
b
Costs
are
based
on
the
following
hourly
total
compensation
rates
for
respondent
employees:
technical
at
$
33.17,
management
at
$
48.95,
and
clerical
at
$
18.96.

The
fully
burdened
rates
used
in
this
table
are:
technical
at
$
69.66,
management
at
$
102.80,
and
clerical
at
$
39.82.

e.
T
ime
for
audit
of
Hg
monitoring
systems
addresses
by
Relative
Accuracy
T
est
Audit
(
RATA)
included
as
part
of
Item
4.
B.
v
­
vii
d.
Labor
hour
requirements,
capital
costs,
and
O&
M
costs
for
Hg
CEMS
and
sorbent
trap
systems
based
on
information
prepared
for
U.
S.
EPA
Clean
Air
Markets
Division,
February
2005
f.
Annualized
costs
calculated
assuming
a
7%
interest
rate
and
a
3­
year
depreciation
period.

c.
One
time
event
over
the
first
3­
year
term
of
the
ICR
following
promulgation
of
the
rule
assumed
to
be
completed
during
the
1st
year.
40
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)

Agency
Person
Hours
per
Occurrence
No.
of
Occurrence
s
Per
Respondent
Per
Year
No.
of
Respondents
Per
Year
Te
chnical
personhours
per
year
(
D=
AxBxC)
Management
personhours
per
year
(
Dx0.05)
Clerical
personhours
per
year
(
Dx0.1)
Costs,
$

(
see
note
a)

Hg
Emission
Cap­
and
Trade
Program
1.
EPA
review
and
approve
State/
Tribal
Plans
(
see
note
b)
240
1
53
12,720
636
1,272
$
687,409
2.
Review
respondent
notifications
4
2
1,125
4,500
225
450
$
243,187
3.
Review
respondent
Hg
monitoring
plans
(
see
note
b)
16
1
1,125
18,000
900
1,800
$
972,749
4.
Review
respondent
quarterly
Hg
emissions
reports
4
4
1,125
4,500
225
450
$
243,187
5.
Site
observation
of
Hg
emissions
test
for
coal­
fired
utility
units
?
29
lb
Hg/
yr
(
see
note
c)
16
1
44
704
35
70
$
38,045
6.
Site
observation
of
Hg
monitor
performance
evaluation
for
coal­
fired
utility
units
>
29
lb
Hg/
yr
(
see
note
d)
16
1
67
1,072
54
107
$
57,933
7.
Litigation
(
see
note
e)
$
0
Subpart
Da
NSPS
Hg
Emission
Limits
1.
Review
respondent
notifications
4
2
5
20
1
2
$
1,081
2.
Review
respondent
Hg
monitoring
plans
(
see
note
b)
16
1
5
80
4
8
$
4,323
3.
Review
respondent
semi­
annual
compliance
reports
4
2
5
20
1
2
$
1,081
4.
Site
observation
of
Hg
monitor
performance
evaluation
for
coal­
fired
utility
units
16
1
1
16
1
2
$
865
6.
Litigation
(
see
note
e)
$
0
TOTAL
BURDEN
AND
COST
(
SALARY)
41,632
2,082
4,163
$
2,249,860
OTHER
EXPENSES
(
see
note
f)
$
78,400
NOTES:

a
Costs
are
based
on
the
following
hourly
rates
for
government
employees:
technical
at
$
30.24,
management
at
$
42.04,
and
clerical
at
$
14.34.

The
fully
burdened
rates
used
in
this
table
are:
technical
at
$
48.38,
management
at
$
67.26,
and
clerical
at
$
22.94.

c
Assumes
Agency
personnel
attend
10%
of
the
LME
coal­
fired
utility
unit
Hg
emission
test
per
year
d.
Assumes
Agency
personnel
attend
10%
of
the
CEMS
and
Hg
sorbent
trap
performance
evaluations
per
year
e.
Assumes
no
enforcement
action
or
litigation
during
the
3­
year
term
of
the
ICR
Exhibit
4a.
ANNUAL
AGENCY
BURDEN
AND
COST
OF
FINAL
RULE
Activity
f.
Government
travel
expenses
to
observe
performance
test/
evaluation
based
on
[
1
person
x
($
100
per
diem
x
2
days
+
$
100
hotel
for
1­
night
+
$
400
roundtrip
air
fare)
x
112
coal­
fired
utility
units]

b.
One
time
event
over
the
first
3­
year
term
of
the
ICR
following
promulgation
of
the
rule
First
Year
After
Promulgation
41
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)

Agency
Person
Hours
per
Occurrence
No.
of
Occurrence
s
Per
Respondent
Per
Year
No.
of
Respondents
Per
Year
Te
chnical
personhours
per
year
(
D=
AxBxC)
Management
personhours
per
year
(
Dx0.05)
Clerical
personhours
per
year
(
Dx0.1)
Costs,
$

(
see
note
a)

Hg
Emission
Cap­
and
Trade
Program
1.
EPA
review
and
approve
State/
T
ribal
Plans
(
see
note
b)
240
0
53
0
0
0
$
0
2.
Review
respondent
notifications
4
2
1,125
4,500
225
450
$
243,187
3.
Review
respondent
Hg
monitoring
plans
(
see
note
b)
16
0
1,125
18,000
900
1,800
$
972,749
4.
Review
respondent
quarterly
Hg
emissions
reports
4
4
1,125
4,500
225
450
$
243,187
5.
Site
observation
of
Hg
emissions
test
for
coal­
fired
utility
units
?
29
lb
Hg/
yr
(
see
note
c)
16
1
44
704
35
70
$
38,045
6.
Site
observation
of
Hg
monitor
performance
evaluation
for
coal­
fired
utility
units
>
29
lb
Hg/
yr
(
see
note
d)
16
1
67
1,072
54
107
$
57,933
7.
Litigation
(
see
note
e)
$
0
Subpart
Da
NSPS
Hg
Emission
Limits
1.
Review
respondent
notifications
4
2
5
20
1
2
$
1,081
2.
Review
respondent
Hg
monitoring
plans
(
see
note
b)
16
0
5
80
4
8
$
4,323
3.
Review
respondent
semi­
annual
compliance
reports
4
2
5
20
1
2
$
1,081
4.
Site
observation
of
Hg
monitor
performance
evaluation
for
coal­
fired
utility
units
16
1
1
16
1
2
$
865
6.
Litigation
(
see
note
e)
$
0
TOTAL
BURDEN
AND
COST
(
SALARY)
28,912
1,446
2,891
$
1,562,451
OTHER
EXPENSES
(
see
note
f)
$
78,400
NOTES:

a
Costs
are
based
on
the
following
hourly
rates
for
government
employees:
technical
at
$
30.24,
management
at
$
42.04,
and
clerical
at
$
14.34.

The
fully
burdened
rates
used
in
this
table
are:
technical
at
$
48.38,
management
at
$
67.26,
and
clerical
at
$
22.94.

c
Assumes
Agency
personnel
attend
10%
of
the
LME
coal­
fired
utility
unit
Hg
emission
test
per
year
d.
Assumes
Agency
personnel
attend
10%
of
the
CEMS
and
Hg
sorbent
trap
performance
evaluations
per
year
e.
Assumes
no
enforcement
action
or
litigation
during
the
3­
year
term
of
the
ICR
Activity
f.
Government
travel
expenses
to
observe
performance
test/
evaluation
based
on
[
1
person
x
($
100
per
diem
x
2
days
+
$
100
hotel
for
1­
night
+
$
400
roundtrip
air
fare)
x
112
coal­
fired
utility
units]

b.
One
time
event
over
the
first
3­
year
term
of
the
ICR
following
promulgation
of
the
rule
Second
Year
After
Promulgation
Exhibit
4b.
ANNUAL
AGENCY
BURDEN
AND
COST
OF
FINAL
RULE
42
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)

Agency
Person
Hours
per
Occurrence
No.
of
Occurrences
Per
Respondent
Per
Year
No.
of
Respondents
Per
Year
Technical
personhours
per
year
(
D=
AxBxC)
Management
personhours
per
year
(
Dx0.05)
Clerical
pe
rsonhours
per
year
(
Dx0.1)
Costs,
$

(
see
note
a)

Hg
Emission
Cap­
and
Trade
Program
1.
EPA
review
and
approve
State/
Tribal
P
lans
(
see
note
b)
240
0
53
0
0
0
$
0
2.
Review
respondent
notifications
4
2
1,125
4,500
225
450
$
243,187
3.
Review
respondent
Hg
monitoring
plans
(
see
note
b)
16
0
1,125
18,000
900
1,800
$
972,749
4.
Review
respondent
quarterly
Hg
emissions
reports
4
4
1,125
4,500
225
450
$
243,187
5.
Site
observation
of
Hg
emissions
test
for
coal­
fired
utility
units
?
29
lb
Hg/
yr
(
see
note
c)
16
1
44
704
35
70
$
38,045
6.
Site
observation
of
Hg
monitor
performance
evaluation
for
coal­
fired
utility
units
>
29
lb
Hg/
yr
(
see
note
d)
16
1
67
1,072
54
107
$
57,933
7.
Litigation
(
see
note
e)
$
0
Subpart
Da
NSPS
Hg
Emission
Limits
1.
Review
respondent
notifications
4
2
5
20
1
2
$
1,081
2.
Review
respondent
Hg
monitoring
plans
(
see
note
b)
16
0
5
80
4
8
$
4,323
3.
Review
respondent
semi­
annual
compliance
reports
4
2
5
20
1
2
$
1,081
4.
Site
observation
of
Hg
monitor
performance
evaluation
for
coal­
fired
utility
units
16
1
1
16
1
2
$
865
6.
Litigation
(
see
note
e)
$
0
TOTAL
BURDEN
AND
COST
(
SALARY)
28,912
1,446
2,891
$
1,562,451
OTHER
EXPENSES
(
see
note
f)
$
78,400
NOTES:

a
Cost
s
are
based
on
the
following
hourly
rates
for
government
employees:
technical
at
$
30.24,
management
at
$
42.04,
and
clerical
at
$
14.34.

The
fully
burdened
rates
used
in
this
table
are:
technical
at
$
48.38,
management
at
$
67.26,
and
clerical
at
$
22.94.

c
Assumes
Agency
personnel
attend
10%
of
the
LME
coal­
fired
utility
unit
Hg
emission
test
per
year
d.
Assumes
Agency
personnel
attend
10%
of
the
CEMS
and
Hg
sorbent
trap
performance
evaluations
per
year
e.
Assumes
no
enforcement
action
or
litigation
during
the
3­
year
term
of
the
ICR
Exhibit
4c.
ANNUAL
AGENCY
BURDEN
AND
COST
OF
FINAL
RULE
Activity
f.
Government
travel
expenses
to
observe
performance
test
/
evaluation
based
on
[
1
person
x
($
100
per
diem
x
2
days
+
$
100
hotel
for
1­
night
+
$
400
roundtrip
air
fare)
x
112
coal­
fired
utility
units]

b.
One
time
event
over
the
first
3­
year
term
of
the
ICR
following
promulgat
ion
of
the
rule
Third
Year
After
Promulgation
