  SEQ CHAPTER \h \r 1 SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Electric Utility Steam Generating Units (40 CFR part 60,
subpart Da)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NSPS for Electric Utility Steam Generating Units (40 CFR part 60,
subpart Da)

	1(b)  Short Characterization/Abstract

	The New Source Performance Standards (NSPS), for the regulations
published at 40 CFR 60, Subpart Da, were proposed on September 18, 1978,
and promulgated on June 11, 1979 (44 FR 33613).  These regulations apply
to the following facilities in 40 CFR part 60, subpart Da: those that
have electric utility steam generating units which are capable of
combusting more than 73 megawatts (MW) heat input of fossil fuel
commencing construction, modification, or reconstruction after the date
of proposal.  This information is being collected to assure compliance
with 40 CFR part 60, subpart Da.

	In general, all NSPS standards require initial notifications,
performance tests, and periodic reports.  Owners or operators also are
required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction in the operation of an affected
facility, or any period during which the monitoring system is
inoperative.  These notifications, reports, and records are essential in
determining compliance, and are required of all sources subject to NSPS.

	Any owner or operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
two years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state, or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the appropriate United States Environmental
Protection Agency (EPA) regional office.

	According to data from the Edison Electric Institute, approximately 644
sources are currently subject to the regulation and approximately eleven
additional sources will become subject to the regulation in the next
three years.  The respondent cost of this ICR will be $7,628,548.

Terms of Clearance

	OMB approved the currently active ICR without any “Terms of
Clearance.”  

2.  Need for and Use of the Collection

	2(a)  Need/Authority for the Collection

	The EPA is charged under Section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every four years.

	In addition, Section 114(a) states that the Administrator may require
any owner or operator subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

	In the Administrator's judgment, sulfur dioxide (SO2), particulate
matter (PM), and nitrogen oxide (NOx) emissions from electric utility
steam generating units cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NSPS were promulgated for this source category at 40 CFR
part 60, subpart Da.

	2(b)  Practical Utility/Users of the Data

	The control of emissions of SO2, PM, and NOx from electric utility
steam generating units requires not only the installation of properly
designed equipment, but also the operation and maintenance of that
equipment.  Emissions of SO2, PM, and NOx from electric utility steam
generating units are the result of operation of the affected facilities.
 The subject standards are achieved by the capture and/or reduction of
SO2, PM, and NOx emissions using control technologies such as sorbent
injection technologies and wet and dry scrubbers for SO2; cyclones, 
electrostatic precipitators, and fabric filters for PM; and low NOx
burners and selective catalytic or noncatalytic reduction technologies
for NOx.  The notifications required in the applicable regulations are
used to inform the Agency, or delegated authority, when a source becomes
subject to the requirements of the regulations.  The reviewing authority
may then inspect the source to check if the pollution control devices
are properly installed and operated and the regulations are being met. 
Performance test reports are needed as these are the Agency's record of
a source's initial capability to comply with the emission standards, and
serve as a record of the operating conditions under which compliance was
achieved.  The semiannual and quarterly reports are used for problem
identification, as a check on source operation and maintenance, and for
compliance determinations.  The information generated by the monitoring,
recordkeeping, and reporting requirements described in this ICR is used
by the Agency to ensure that facilities affected by the NSPS continue to
operate the control equipment and achieve compliance with the
regulation.  Adequate monitoring, recordkeeping, and reporting are
necessary to ensure compliance with the applicable regulations, as
required by the Clean Air Act.  The information collected from
recordkeeping and reporting requirements also is used for targeting
inspections, and is of sufficient quality to be used as evidence in
court.

3.  Nonduplication, Consultations, and Other Collection Criteria

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

	3(a)  Nonduplication

	 If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state, or local agency. 
If a state, or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state, or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

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

	An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (70 FR 55368) on September 21,
2005.  No comments were received on the burden published in the Federal
Register.

			

	3(c)  Consultations

	EPA’s Office of Air Quality Planning and Standards, the Department of
Energy’s Energy Information Agency, the Electric Power Research
Institute, and the Edison Electric Institute were consulted to determine
the current number of facilities and the industry growth rate.  EPA’s
Online Tracking Information System (OTIS) usually is the primary source
of information regarding the number of existing sources and industry
trade associations and other government sources are used to verify OTIS
data.  Based on industry data, the OTIS number was adjusted.

	3(d)  Effects of Less Frequent Collection

	Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

	3(e)  General Guidelines

	None of these reporting or recordkeeping requirements violates any of
the regulations established by OMB at 5 CFR 1320.5.

	3(f)  Confidentiality

	The required information has been determined not to be confidential. 
However, any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, Part 2, Subpart B -
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, September 20, 1978; 44 FR 17674, March 23, 1979).

	3(g)  Sensitive Questions

	None of the reporting or recordkeeping requirements contains sensitive
questions.	

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

	The respondents to the recordkeeping and reporting requirements are
electric utility steam generating units which are capable of combusting
more than 73 megawatts (MW) heat input of fossil fuel, for which
construction, or modification is commenced after September 18, 1978.  
The United States Standard Industrial Classification (SIC) code for the
respondents affected by the standards is SIC 4911,  which corresponds to
the North American Industry Classification System (NAICS) 221112 for
electric utility steam generating units.

	4(b)  Information Requested 

		(i)  Data Items

	All data in this ICR that are recorded and/or reported are required by
40 CFR part 60, subpart Da.

	A source must make the following reports:

Reports for 40 CFR part 60, subpart Da

Construction/reconstruction	60.7(a)(1) 

Actual startup	60.7(a)(3)

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

Initial performance test	 60.8(d)

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

Monitoring system performance	60.7(c), 60.49a(i)

Physical or operational change	60.7(a)(4)

Daily operating parameter - emission controls	60.49a(b)

Monitoring system - minimum emissions data	60.49a(c)

Control system malfunction	60.49a(d)

Fuel treatment credit – SO2	60.49a(e)

Data unavailability (SO2, NOx)	60.49a(f)

Minimum data requirements	60.49a(g)

Excess emissions	60.7(c), 60.49a(h)

Quarterly reporting	60.49a(j)

Semiannual Reporting	60.49a(i)



	A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart Da

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative	60.7(b)

Reporting requirements	60.49(a)

Emissions monitoring	60.47a

Records are required to be retained for 2 years at the facility 	60.7(f)

			

		(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate Continuous Monitoring System
(CMS) for opacity, or for pressure drop and liquid supply pressure for
wet scrubber.

Perform initial performance test, Reference Method tests (Method 3B,
Method 5, Method 9, and Method 19) and repeat performance tests.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.

Adjust the existing ways to comply with any previously applicable
instructions and requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.



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

	5(a)  Agency Activities

	EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

Review notifications and reports, including performance test reports and
excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS)
database.



	5(b)  Collection Methodology and Management

	Following notification of startup, the reviewing authority might
inspect the source to determine whether the pollution control devices
are properly installed and operated.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.  The semiannual and quarterly reports are used for problem
identification, as a check on source operation and maintenance, and for
compliance determinations.

	Information contained in the reports is entered into the Air Facility
System (AFS), which is operated and maintained by EPA's Office of
Compliance.  AFS is EPA’s database for the collection, maintenance,
and retrieval of compliance and annual emission inventory data for over
100,000 industrial and government-owned facilities.  EPA uses AFS for
tracking air pollution compliance and enforcement by local and state
regulatory agencies,  EPA regional offices and EPA headquarters.  EPA
and its delegated Authorities can edit, store, retrieve and analyze the
data.

	 The records required by this regulation must be retained by the owner
or operator for two years.

	5(c)  Small Entity Flexibility

	There are no small businesses affected by this regulation.

	

	5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Burden of Reporting and
Recordkeeping Requirements as a Result of the Standards for Electric
Utility Steam Generating Units/NSPS Subpart Da.

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the Subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

	The Agency may not conduct, or sponsor, and a person is not required to
respond to, a  collection of information unless it displays a currently
valid OMB Control Number.

				

	6(a)  Estimating Respondent Burden

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be
133,553 person hours.  These hours are based on Agency studies and
background documents from the development of the regulation, Agency
knowledge and experience with the NSPS program, the previously approved
ICR,  and any comments received.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs 

 

	This ICR uses a Technical Labor Rate of $57.12 per hour.  This rate is
from the United States Department of Labor, Bureau of Labor Statistics,
March 2001, “Table 10: Private industry, by occupational and industry
group.”  The rates are from column 1, “Total compensation.”  The
wage rate of $27.20 has been increased by 110% to account for the
benefit packages available to those employed by private industry for a
labor rate of $57.12 per hour.

		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	The types of industry costs associated with the information collection
activity in the regulations are for labor and continuous emission
monitoring (CEM).  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

		(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	(B)

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

Number of New Affected Facilities to Startup	(D)

Total Startup 

(B X C)	(E)

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

Number of Affected Facilities with O&M	(G)

Total O&M

(E X F)

SO2, PM, and NOx	$200,000	11	$2,200,000	$15,000	644	$9,660,000

 

	The total capital/startup costs for this ICR are $2,200,000.  This is
the total of column D in the above table.  These costs are shown in
block 14(a), Total annualized capital/startup costs, on the OMB 83-I
form.  It should be noted that the numbers in block 14 of the OMB 83-I
form are rounded to show the cost in thousands of dollars.

	The total operation and maintenance (O&M) costs for this ICR are
$9,660,000.  This is the total of column G.  These costs are shown in
block 14(b), Total annual costs (O&M), on the OMB 83-I form.

	The total respondent non-labor costs in block 14 have been calculated
as the addition of the capital/startup costs, and the annual operation
and maintenance costs.  The average annual cost for capital/startup and
operation and maintenance costs to industry over the next three years of
the ICR is estimated to be $11,860,000.  This cost is shown on the OMB
83-I form in block 14 (c), Total annualized cost requested.  The numbers
in block 14 of the OMB 83-I form are rounded to show the cost in
thousands of dollars.

	6(c)  Estimating Agency Burden and Cost

	The only costs to the Agency are those costs associated with the
analysis of the reported information.  Publication and distribution of
the information are part of the AFS program.  Examination of records to
be maintained by the respondents will occur as part of the periodic
inspection of sources, which is part of EPA's overall compliance and
enforcement program. 

	The average annual Agency cost during the three years of the ICR is
estimated to be $569,246.  This cost is based on the average hourly
labor rate at a GS-12, Step 1, times a 1.6 benefits multiplication
factor to account for government overhead expenses for a total of
$38.30.

		

	These rates are from the Office of Personnel Management (OPM) “2002
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Resource Requirement for Monitoring Electric Utility Steam Generating
Units/NSPS Subpart Db, below.

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

	Approximately 644 sources are currently subject to the regulation and
it is estimated that an additional 11 sources per year will become
subject to the regulation in the next three years.

Respondent Universe and Number of Responses Per Year



Regulation Citation	(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Sources	(F)

Number of Respondents that keep records but do not submit reports	(E)

Total Annual Responses =

(AxB)+(CxD)+ F

40 CFR 60.49a(i)	9	2	515	2	0	1,048

40 CFR 60.49a(j)	2	4	129	4	0	524

Total	11

644

	1,572

	

	The number of total respondents is 655.  This number is the sum of
column A and column C of the Respondent Universe and Number of Responses
Per Year table.  This represents the number of existing sources plus the
number of new sources averaged over the three-year period (i.e., the
total number of new respondents over the three-year period divided by
three years).  It is shown in block 13 (a), Number of respondents, on
the OMB 83-I form.

	The number of Total Annual Responses is 1,572.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table.  It is shown in block 13 (b), Total annual responses, on the OMB
83-I form.

	The total annual labor costs are $7,628,548.  This number is not shown
on the OMB 83-I form in block 13(c), Total hours requested.  Only the
burden hours are reflected in block 13(c).  Details upon which this
estimate is based appear in Table 1. Annual Burden of Recordkeeping and
Reporting Requirements as a Result of the Standards for Electric Utility
Steam Generating Units/NSPS Subpart Da.

 

	The total annual capital and O&M costs to the regulated entities are
$11,860,000.  This number is shown on the OMB 83-I form in block 14 (c),
Total annualized cost requested.  These costs are detailed in section
6(b)(iii), Capital/Startup vs. Operating and Maintenance (O&M) Costs.

	6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

	The bottom line burden hours and cost tables for both the Agency and
the respondents are attached below.

	6(f)  Reasons for Change in Burden

	There is no change in burden.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 85 hours per response.
 Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit, or otherwise disclose the information. 

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2005-0064, which is available for public viewing at the
Enforcement and Compliance Docket and Information Center in the EPA
Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Avenue,
N.W., Washington, D.C.  The EPA Docket Center Public Reading Room is
open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays.  The telephone number for the Reading Room is (202) 566-1744,
and the telephone number for the Enforcement and Compliance Docket and
Information Center is (202) 566-1514. An electronic version of the
public docket is available through the Federal Docket Management System
(FDMS) at http://www.regulations.gov.  Use FDMS to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the Docket ID Number identified above.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention:
Desk Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2005-0064 and OMB Control Number 2060-0023 in any
correspondence.

Part B of the Supporting Statement

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

TABLE 1.  ANNUAL BURDEN OF RECORDKEEPING AND REPORTING REQUIREMENTS AS
A RESULT OF THE STANDARDS FOR ELECTRIC UTILITY STEAM GENERATING UNITS/
NSPS SUBPART Da.

	A	B	C	D	E	F

Reporting and recordkeeping requirements	Person hours per occurrence
Annual occurrences per respondent	Annual person hours per respondent

(A x B)	Total number of respondents	Total annual person hours

(C x D)	Total annual cost

(E x $57.12)

1. APPLICATIONS	N/A





	2. SURVEYS AND STUDIES	N/A





	3. REPORTING REQUIREMENTS







a. Read instructions	1	1	1	11	11	$628

b. Required activities







      Initial Emissions Test	160	1	160	11	1,760	$100,531

      Reference Method 9	4	30	120	11	1,320	$ 75,398

      Report Performance Test	60	0.2(b)	12	11	132	$ 7,540

c. Create information



Included in 3B



d. Gather information.



Included in 3E



e. Write report







      Notification of Construction/reconstruction	2	1	2	11	22	$1,257

      Notification of anticipated/actual   startup	2	1	2	11	22	$1,257

      Notify of actual startup	2	1	2	11	22	$1,257

      Notify of initial performance test	2	1.2	2	11	22	$1,257

      Notify of demonstration of CMS	2	1	2	11	22	$1,257

      Report of Performance test



Included in 3B



      Semiannual report	8	2	16	515	8,240	$470, 669

      Quarterly report	8	4	32	129	4,128	$235,791

4. RECORD KEEPING REQUIREMENTS







a. Read instructions



Included in3A



b. Plan Activities



Included in 4C



      Implement Activities



Included in 3B



      Development record system



N/A



C. Time to check computer system and calibrate continuous monitors	0.5
365(c)	183	644	117,852	$6,731,706

d. Time to Train Personnel 



N/A



e. Time For Audits



N/A



TOTAL: ANNUAL BURDEN



	133,553	$7,628,548

Footnotes:

a) Assume approximately 6 plants (respondents) will become subject over
a 3-year period.  Assume consistent progression of NSPS coverage, so
that the number of new sources per year equal 6/3 or 2.

b) Assume 20% of initial performance tests must be repeated due to
failure.

c) Assume operation 365 days per year as specified in the NSPS review
document

TABLE 2.  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR MONITORING
ELECTRIC UTILITY STEAM GENERATING UNITS/ NSPS SUBPART Da.

	(A)	(B)	(C)	(D)	(E)	(F)

Activity	EPA hours per occurrence	Occurrences per plant per year	EPA
hours per plant per year

(A x B)	Plants per year	EPA hours per year

(C x D)	Total annual cost

(E x $38.30)

Performance tests







     New Plants	24	1.2	28.8	11	316.8	$12,133

     Review report of startup	160	1.2	192	11	2,112	$80,890

Report Review







     Notified of construction	2	1	2	11	22	$843

     Notified of anticipated startup	0.5	1	0.5	11	5.5	$211

     Notified of actual startup	0.5	1	0.5	11	5.5	$211

     Notified of Initial test	0.5	1.2	0.6	11	6.6	$253

     Notified if CMS demonstration	0.5	1	0.5	11	5.5	$211

Review excess emissions reports







     Semiannual	8	2	16	515	8,240	$315, 592

     Quarterly	8	4	32	129	4, 128	$158,102

Travel(e)





$800

TOTAL



	14,842	$568,446

TOTAL ANNUAL COST





$569,246

Footnotes:

a, A x B = C

b) C x D = E

c) Assume 20% of initial performance test must be repeated due to
failure.

d) Burden cost is calculated at a rate of $38.30 ($23.94 x 1.6 to
account for government benefits and overhead expenses).

e) Travel Expenses (1 person x 2 plants/yr x 3 days/plant X $50 per
diem) + ($250 round trip/plant x 2 plants/yr) = $800

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