SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NSPS for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal) EPA ICR Number 1053.10, OMB Control Number 2060
- 0023 1. Identification of the Information Collection 1(a) Titl e of the Information Collection NSPS for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal) , EPA I CR Number 1053.10, OMB Control Number 2060

- 0023 1(b) Short Characterization/Abstract The New Source Performance Standards (NSP S), for the Electric Utility S team Generating Units ( 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 s team 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 are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all sources sub ject to NSPS. Any owner or operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority . In the event that there is no such delegated authority, the reports are sent directly to the United States Environmental Protection Agency (EPA) regional office. Based on our consultations with industry rep resentatives, there is an average of one affected facility

at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an average of 677 facilities per year will be subject to the standard, and it is estimated that eleven additional sources per year will become subject to the standard in the next three years. There are approximately

6 77 electric utility

s team generating facilities in the United States, which are all publicly owned and operated b y the electric utility steam generating industry . None of the 677 facilities in the United States are owned by either state, local, tribal or the Federal2

Government. They

are all owned and operated solely by privately owned for

- profit businesses. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

- NSPS for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal) . The burden to the Federal government is attribute d entirely to work performed by Federal emplo ye es or government contractors and may be found below in Table 2: Average Annual EPA Burden

- NSPS for Electric Utility S team Generating Units (40 CFR Part 60, Subpart Da) (Renewal)

. The Office of Management and Budget (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 s tandards of performance for new stationary sources that reflect:

. . . application of the best technological sy stem 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 adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires th at the Administrator review and, if appropriate, revise such standards every four years. In the Administrator's judgment, sulfur dioxide (SO 2 ), particulate matter (PM), and nitrogen oxide (NO x) 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 was promulgated for this source category at 40 CFR part 60, subpart Da. 2(b) Practical Utility/Users of the Data The recordkeep ing and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility’s i nitial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.3

The notifications required in the standard are used to inform the Agency or delegat ed authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properl y installed and operated, that leaks are being detected and repaired, and that the standard is being met. The performance test may also be observed. The required semiannual and quarterly reports are used to determine periods of excess emissions, identify

problems at the facility , verify operation/maintenance procedures, and for compliance determinations.
3. Non
- duplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 60, subpart Da. 3(a) Non
- duplication If the subject standards have not be en delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists. 3(b) Public Notice Required Prior to ICR Submissi on to OMB An announcement of a public comment period for the renewal of this IC R was published in the Federal Register (75 FR 3081 3 ) on June 2, 2010. No comments were received on the burden published in the Federal Register

. 3(c) Consultations Over th e next three ye ars, an average of 677 facilities per year will be subject to the standard, with eleven additional sources per ye ar becoming subject to the standard. In estimating the affected number of sources, the growth rate, and the accuracy of other data for electric utility

steam generating facilities subject to this standard, previous consultations were conducted with the Edison Electric Institute (EEI), Mr. Ed Yawn at (202) 508

- 5000, the Department of Energy , Mr. Tom Leckey at (202) 586

- 3548, and th e Electric Power Research Institute (EPRI), Mr. Dan Rastler at (650) 855

- 2521. Additionally , the most recent ICR was referenced, and other internal resources used to obtain the most recent data available. Information was reviewed from the Online Tracking In formation Sy stem (OTIS) which is the primary source of information regarding the number of existing sources. OTI S data was used in conjunction with industry consultation to verify

the number of sources and the industry growth rate. For this renewal, the same individuals from the Edison Electric Institute (EEI), the Department of Energy , and the Electric Power Research Institute (EPRI) were contacted for4

consultation regarding the accuracy of the EPA burden estimates. No comments were received in respo nse. 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 techniqu es to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possib ility of detecting violations would be less likely

. 3(e) General Guidelines These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. 3(f) Confidentiality Any information submitted to the Agenc y fo r which a claim of confidentiality i s made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality

of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, S eptember 1, 1976; amended b y 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 contain sensitive questions. 4. The Respondents an d the Information Requested 4(a) Respondents/SIC Codes The respondents to the recordkeeping and reporting requirements are source category description. The United States Standard Industrial Classification (SI C) code for the respondents affected b y the standards is SI C 4911, which corresponds to the North American Industry Classification System (NAI CS) 221112 for source category description. The respondents to the recordkeeping and reporting requirements are electric utility steam generating units. 4(b ) Information Requested None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5.5 (i) Data Items In this ICR, all the data recorded or reported is required by the New Source Performance Standards for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da). A source must make the following reports:
Notifications Notification of construction or reconstruction 60.7(a)(1) Notification of actual startup 60.7 (a)(3) Notification of initial performance test results 60.8(a), 60.49a(a) Initial performance test 60.8(d) Demonstration of continuous monitoring sy stem 60.7(a)(5) Monitoring s ys tem performance 60.7(c), 60.49a(i) Phy sical or operational change 60.7(a)(4) Daily operating parameter

– emission controls 60.49a(b) Monitoring s ys tem

– 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) Quarterl y reporting 60.49a(j) Semiannual reporting 60.49a(i) A source must keep the following records: Recordkeeping Maintain records of startups, shutdowns, malfunctions, periods where the continuous monitoring system is inoperative 60.7(b) Reporting requirements 60.49a Emissions monitoring 60.47a Maintain all records for two years 60.7(f) Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically. However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.6 Respondent Activities Read instructions. Install, calibrate, maintain, and operate continuous monitoring sy stem (CMS) for opacity , or for pressure drop and liquid supply pressure for wet scrubber. Perform initial performance test, Reference Metho d 3B, 5, 9, and 19, and repeat performance tests if necessary

. Write the notification and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s 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. Currently , sources are using monitoring equipment that provides parameter data in an automated way

e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. 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, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information System (OTI S). 5(b) Collection Methodology and Management Following n otification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properl y installed and operational. Performance test reports are used b y the Agency to discern a source’s initial capability to compl y with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in7

compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the Air Facility S ys tem (AFS) which is operated and maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner or operator for two ye ars. 5 (c) Small Entity Flexibility The majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses,) was taken into consideration during the development of the regulation. According to the EPA 2006 Final Rule (71 FR 9865) regarding amendments proposed to 40 CFR part 60, subparts Da, Db, and Dc, on February 28, 2005, “ . . . at most, one entity

out of five new entities in the industry may be small entities.” Applying this data to the respondent universe for this IC R results in approximately 1 35 small entities impacted by this ICR. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements ar e the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of s cale to reduce their burden, the overall burden will be reduced. 5(d) Collection Schedule The specific frequency

f or each information collection activity w ithin this request is shown below in Table 1: Annual Respondent Burden

- NSPS for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal)

. 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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever 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.8

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 160,839 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previously approved ICR, and any comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the following lab or rates: Managerial $116.05 ($55.26 + 110%) Technical $97.21 ($46.29 + 110%) Clerical $48.87 ($23.27 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2010, “Table 2. Civilian Workers, by Occupatio nal and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 1 10 percent to account for the benefit packages available to those employed by private industry

. (ii) Estimating Capital/Startup and Operation and Maintenance Costs The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. The type of industry costs associated with the information collection activities in the subj ect standard are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the 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)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/ Startup Cost, (B×C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E×F)

SO 2 , PM, and NOx $200,000 11 $2,200,000 $15,000 677 $10,155,000 The total capital/startup costs for this ICR are $2,200,00 0. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $10,155,000. This is9

the total of column G. The average annual cost for capital/startup and operation and maintenance costs to indus try over the next three ye ars of the I CR is estimated to be $12,355,000. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with anal ys is of the reported information. The EPA compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of th e ICR is estimated to be $719,137. This cost is based on the average hourl y labor rate as follows: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%) Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%) These rate s are from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality

rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to government emplo ye es. Details upon which this e stimate is based appear below in Table 2: Average Annual EPA Burden

- NSPS for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal)

. 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our research for this I CR, on average over the next three ye ars, approximately 677 existing respondents will be subject to the standard. It is estimated that an additional eleven respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below is 677 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. Number of Respondents Year (A)

Number of New Respondents a (B)

Number of Existing Respondents (C)

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

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)
1 11 655 0 0 666 2 11 666 0 0 677 3 11 677 0 0 688 Average 11 666 0 0 677
a New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard10

existing respondents submit initial notifications. Column D is subtracted to avoid double

- counting respondents. As shown above, the av erage Number of Respondents over the three

- ye ar period of this ICR is 677. The total number of annual responses per ye ar is calculated using the following table: Total Annual Responses (A) Information Collection Activity (B) Number of Respondents (C)

Numb er of Responses (D)

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

Total Annual Responses E=(B×C)+D

Notification of construction/reconstruction 11 1 n/a 11 Notification of actual startup 11 1 n/a 11 Notify of initial p erformance test 11 1.2 n/a 13.2 Notification of demonstration of CMS 11 1 n/a 11 Semiannual report 542 2 n/a 1,084 Quarterly report 135 4 n/a 540 TO TAL (rounded) 1,670 The number of total respondents is 677. The number of Total Annual Responses i s 1,670. This is the number in column E of the Respondent Universe and Number of Responses per year in table above. The total annual labor costs are $15,090,813. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden

- NSPS for Electric Utility S team Generating Units (40 CFR Part 60, Subpart Da) (Renewal)

. 6(e) Bottom Line Burden Hours Burden Hours and Cost Tables The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. (i) Respondent Tally The total annual labor costs are $15,090,813. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

- NSPS for Electric Utility Ste am Generating Units (40 CFR Part 60, Subpart Da) (Renewal) . Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 96 hours per response. The total annual capital/startup and O&M cost to the regulated entity are $12,355,000. (ii) The Agency Tally The average annual Agency b urden and cost over next three ye ars is estimated to be 15,95811

labor hours at a cost of $719,137. See below Table 2 : Annual Annual EPA Burden

- NSPS for Electric Utility

Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal)

. 6(f) Reasons for Change in Burden There is no change in the labor hours in this IC R compared to the previous ICR. This is due to two considerations. F irst, the regulations have not changed over the past three years and are not anticipated to change over the next three years. Secondly, the growth rate for the industry is very low, negative or non

- existent, so there is no significant change in the overall burden. It shoul d be noted that an increase of one labor hour is shown due to more accurate rounding in the labor calculations. The increase in labor cost to both Respondents and the Agency is due to labor rate adjustments to reflect the most recent available estimates. 6(g) Burd en Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 96 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid O MB Control Number. The OMB Control Numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any s uggested methods for minimiz ing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

–HQ

–OECA

–2010

–0359 . An electronic version of the public docket is available at http://www.regulations.g ov which may be used to obtain a cop y of the draft collection of information, submit or view public comments, access the index listing of the content of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and th e telephone number for the Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 1752

. Also, yo u can send comments to the Office of Information and Regulatory Affairs, Office of12

Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

–HQ

–OECA

–2010

–0359 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.13

Table 1: Annual Respondent Burden and Cost

– NSPS for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal) (A) (B) (C) (D) (E) (F) (G) (H) Burden item Person

hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent per year (C=A × B) Respondents

per year (a) Technical

person hours per year (E=C × D) Management

person - hours per year (E × 0.05) Clerical

person - hours per year (E × 0.1) Cost {$} (b)

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions 1 1 1 11 11 0.55 1.1 $1,186.89 B. Required activities Initial emissions tests 160 1 160 11 1,760 88 176 $189,903.12 Reference Method 9 4 30 120 11 1,320 66 132 $142,427.34 Report performance test c 60 0.2 12 11 132 6.6 13.2 $14,242.73 C. Create information See 3B D. Gather existing information See 3E E. Write report Notify of construction/ 2 1 2 11 22 1.1 2.2 $2,373.79 reconstruction Notify of actual startup 2 1 2 11 22 1.1 2.2 $2,373.79 Notify of initial performance test 2 1.2 2.4 11 26.4 1.32 2.64 $2,848.55 Notification of demonstration of 2 1 2 11 22 1.1 2.2 $2,373.79 CMS Report of performance test See 3B Semiannual report d 8 2 16 542 8,672 433.6 867.2 $935,704.46 Quarterly report e 8 4 32 135 4,320 216 432 $466,125.84 Subtotal Reporting 18,75 4 $1,759,560.31 4. Recordkeeping requirements A. Read ins tructions See 3A B. Plan activities See 4C Im plement activities See 3B Develop record system N/A C. Time to check computer system and calibrate continuous monitor f 0.5 365 182.5 677 123,552.50 6,177.62 12,355.25 $13,331,2 52.39 D. Train personnel N/A E. Audits N/A Subtotal Recordkeeping 142,085 $13,331,252.3914 (A) (B) (C) (D) (E) (F) (G) (H) Burden item Person

hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent per year (C=A × B) Respondents

per year (a) Technical

person hours per year (E=C × D) Management

person - hours per year (E × 0.05) Clerical

person - hours per year (E × 0.1) Cost {$} (b)

TO TAL ANNUAL BURDEN AND COST (rounded) 160,839 $15,090,813
Assu mptions:
a. We have assumed that the average num ber of respondents that wil l be subject to the rule will be 677. T here will be eleven additional new sources per year that will become subject to the rule over the three

- year period of this ICR. b. This ICR uses the following labor rates: $116.05 per hour for Executive, Administrative, and Managerial labor; $97.21 per hour for Technical labor, and $48.87 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2010, "Tab le 2. Civilian Workers, by Occupational and Industry group." The rates are from column 1, "Total Compensation." The rates have been increased by 110 percent to account fo r the benefit packages available to those em ployed by private industry.
c. We have assumed that 20 percent of initial performance t est will be repeated due to failure. d. We have assumed that 80 percent of respondents will each take 8 hours two times per year to w rite the semiannual report.
e. We have assumed that 20 percent of respondents will each take 8 hours four times per year to write the quarterly report. f. We have assumed that each respondent will take 30 minutes each day to check computer system and calibrate continuous monitors

.15

Table 2: Average Annual EPA Burden

– NSPS for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal) (A) (B) (C) (D) (E) (F) (G) (H) Activity EPA person

hours per occurrence No. of

occurrences per plant per year EPA

person hours per plant per year (C=A × B) Plants per

year (a) Technical

person hours per year (E=C × D) Management

person - hours per year (E × 0.05) Clerical

person - hours per year (E × 0.1) Cost {$} (b)

Performance tests New plants 24 1.2 28.8 11 316.8 15.84 31.68 $16,418.00 Revie w report of startup 40 1.2 48 11 528 26.4 52.8 $27,363.34 Report Review Notification of construction 2 1 2 11 22 1.1 2.2 $1,140.14 Notification of actual startup 0.5 1 0.5 11 5.5 0.275 0.55 $285.03 Notification of initial test 0.5 1.2 0.6 11 6.6 0.33 0.66 $342.04 Notification of CMS demonstration 0.5 1 0.5 11 5 .5 0.275 0.55 $285.03 Revie w excess emissions reports Semiannual 8 2 16 542 8,672 433.6 867.2 $449,422.06 Quarterly 8 4 32 135 4,320 216 432 $223,881.84 Subtotal 13,876.40 693.82 1,387.64 $719,137.49 TO TAL ANNUAL BURDEN AND COST (round ed) 15,958 $719,137
Assu mptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 677. There will be eleven ad ditional new sources that will become subject to the rule over the three

- year period of this ICR. b. The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for governme nt overhead expenses. Managerial rates of $62.27 (GS

- 13, Step 5, $38.92 + 60%), Technical rate of $46.21 (GS

- 12, Step 1, $28.88 + 60%), and Clerical rate of $25.01 (GS

- 6, Step 3, $15.63 + 60%). These rates are from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality rates of p ay. T he rates have been increased by 60 percent to account for the benefit packages available to government employees.
c. We have assumed that it will take 40 hours to review each startup report. d. We have assumed that it will take 8 hours two times per year to review each semiannual report.
e. We have assumed that it will take 8 hours four times per year to review each the quarterly report.