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OAR Box 1865 

Prepped by Charmelle Mathews 

Document Number: 

55) IV-H-2 

Docket Number: 

A-83-27 

Printed 12/3/2008 9:15:29 AM Sheet 55 of 105 
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IV-H-2 

^tmO sr„^ 

/ A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

| ^W ^ 3 Office of Air Quality Planning and Standards 

X^aWam*^ Research Triangle Park, North Carolina 27711 

\ m o ^ 4 SEP 198 7 

MEMORANDUM 

SUBJECT: Request for OMB Clearance of Reporting and Recordkeeping 

Requirements Associated with Final Performance Standards 

(SO2) for Industrial-Commercial-Institutional Steam 

Generating Units (Subpart Db) 

FROM: Gerald A. Emison, Director 

Office of Air Quality Planning and Standards (MD-10) 

TO: Thomas E. Kelly, Acting Director 

Office of Standards and Regulations (PM-223) 

THRU: Janine Westhausen 

Office of Air and Radiation (ANR-443) 

Attached are the Standard Form SF-83 (four copies) and supporting 

statement (four copies) for requesting clearance of the reporting and 

recordkeeping requirements associated with the final performance standards (SO2) for industrial-commercial-institutional steam generating 

units (Subpart Db). The SF-83 and supporting statement have been 

revised based on additional information obtained since submittal of the 

Steering Committee package. 

Please review this request and forward it to the Office of 

Management and Budget. If you have any questions concerning this 

submittal, please contact Fred Porter (FTS 629-5251) or Walt Stevenson 

(FTS 629-5264). 

2 Attachments 

cc: Ken Durkee (MD-13) 

Robert Kolbinsky (MD-13) 

Harvey Nozick (ANR-443) (w/o attachments) 

Fred Porter (MD-13) 
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Standard form 83 

(B*v.S«ptem5«f 1983) Request for OMB Review 

Important 

Read instructions before completing form. Oo not use the same SF 83 

to request both an Executive Order 12291 review and approval under 

the Paperwork Reduction Act. 

Answer all questions in Part I. If this request is for review under E.O. 

12291, complete Part II and sign the regulatory certification. If this 

request is for approval under the Paperwork Reduction Act and 5 CFR 

1320, skip Part il, complete Part III and sign the paperwork certification. 

Send three copies of this form, the materia! to be reviewed, and fo 

paperwork—three copies of the supporting statement, to: 

Office of Information and Regulatory Affairs 

Office of Management and Budget 

Attention: Oocket Library, Room 3201 

Washington, DC 20503 

PART I.—Complete This Part for All Requests. 

1. Department/agency and Bureau/office originating request 

EPA/Office of Air and Radiation 

3. Name of person who can best answer questions regarding this request 

Walter H. Stevenson 

2. Agency code 

6 0 

Telephone number 

< FTS ) 629-5264 

4. Title of information collection or rulemaking 

NSPS for Industrial-Commercial-Institutional Steam Generating Units (SO2) 

5. Legal authority for information collection or 

4 2 USfi 741 1 A 7A1A 

6. Affected public (check all that apply) 

1 D Individuals or households 

2 D State or local governments 

rule (cite United States Coda, Public Law, or Executive Order) 

.or 

3 D Farms 

4 CJ Businesses or other for-profit 

6df 

7 D 

Federal agencies or employees 

Non-profit institutions 

Small businesses or organizations 

PART II.—Complete This Part Only if the Request is for OMB Review Under Executive Order 12291 

7. Regulation Identifier Number (RIN) 

, or, None assigned D 

8. Type of submission (check one in each category) 

Ct-wifteatlon 

1 D Major 

2 D Nonmajor 

Stage otdexmhpmarit 

1 D Proposed or draft 

2 D rlnalc*irrtarimfirujl,witJipriorproposal 

3 D Oral«interim finaL without prior proposal 

Type of review requested 

1 D Standard 

2 D Pending 

3 D Emergency 

4 D Statutory or judicial deadline 

9. CFR section affected 

CF» 

10. Ooes this regulation contain reporting or recordkeeping requirements that require OMB approval under the Paperwork Reduction Act 

t 

Certification for Regulatory Submissions 

In submitting this request for OMB review, the authorized regulatory contact and the program official certify that the requirements of E.O. 12291 and any applicant 

policy directives have been complied with. 

Signature of program official 

Signature of authorized regulatory contact 

Oate 

Date 

12. (OMB use only) 

Previous e3T>onj obsolete 

NSN7S4O-00-634-4034 83 108 StandirdFerm83(»ev. 9 

Prescribed by ( 

5 CFR 1320 ind EO .2 
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PART ill.—Complete This Part Only If the Request Is for Approval of a Collection 

of Information Under the Paperwork Reduction Act and 5 CFR 1320. 

i3.Abstract—Describe needs, uses and aHected public m so words or less Owners and operators of industrial-Commercial -

institutional steam generating units with heat input capacities greater than 29 MW (100 million 

Btu/hour) will be required to continuously monitor sulfur dioxide emissions and submit quarterly 

reports of emissions and quality assurance test results. This information is necessary to 

ensure that affected facilitie s comply with the SO? emission standards established under the 

NSPS : , — . 

14. Type of informationi collection (check only one) 

Information collections not contained In rules 

1 D Regular submission 

Information collections contained m rules 

3 D Existing regulation (no change proposed) 

4 D Notice of proposed rulemaking (NPRM) 

5 E Final, NPRM was previously published 

2 Q Emergency submrsstonfcert/f/cafweffac/wd} 

6 Final or interim final without prior NPRM 

' A D Regular submission 

B Q Emergency submission (ctrtftationattactted) 

7. Enter date of expected or actual Federal 

Register publication at this stage of ru:emaki.-.g 

(month.Hay.year): Dec . 1 . 198 7 

15. Type of review requested (check only one) 

l E New collection 

2 D Revision of a currently approved collection 

3 O Extension of the expiration date of a currently approved collection 

without any change in the substance or in the method of collection 

4 O Reinstatement of a previously approved collection for which approval 

has expired 

5 D Existing collection in use without an OMB control number 

16. Agency report form numbers) (include itandard/opfiiona/ form numbers)) 

17. Annual reporting or disclosure burden 

1 Number of respondents 

2 Number of responses per respondent . . 

3 Total annual responses (line I times line 2) 

4 Hours per response 

5 Total hours flinc 3 nme*//r» 4) . . . . 

22. Purpose of information collection (cnec* as many as apply) 

1 D Application for benefits 

2 D Program evaluation 

3 D General purpose statistics 

4 09 Regulatory or compliance 

SQ Program planning or management 

6 D Research 

7 D Audit 

23. Frequency of recordkeeping or reporting fenecfc all that apply) 

1 Q Recordkeeping 

Reporting 

2 D On occasion 

3 D Weekly 

4 D Monthly 

5 uD Quarterly 

6 D Semi-annually 

7 D Annually 

8 D Biennially 

9 D Other (describe;.-

18. Annual recordkeeping burden 

1 Number of recordkeepers . 

2 Annual hours per recerdkeeper. ..... . 

3 Total recordkeeping hours 0»ne J times line 2) 

4 Recordkeeping retention period 

19. Total annual burden 

1 Requested time 17-S plus line 18-3). 

2 In current OMB inventory . . . . 

3 Difference {Vne J Jess <tne 2J . . . 

Explanation ot difference 

4 Program change 

5 Adjustment 

_2 y«r 

20. Current (most recent) OMB control number or comment number 

2060-0136 

2 1 . Requested expiration date 

Dec. 1, 1990 

24. Respondents' obligation to comply (check the strongest obligation that applies. 

1 D Voluntary 

2 D Required to obtain or retain a benefit 

3 B Mandatory 

25. Are the respondents primarily educational agencies or institutions or is the primary purpose of the collection related to Federal education programs? D Yes Q Nl 

26. Doe Doess the the agency use sampling to select respondents or does the agency recommend or prescribe the use of sampling or statistical analysis ,-, yt 

by respondents' U Yes 13 Ni 

27. Regulatory authority for the information collection ~ " ~ 

40 rra 60 ,;or. FR ; or. Other (specify): 

Paperwork Certification " " — • 

In submitting this request for OMB approval, the agency head, the senior official or an authorized representative, certifies that the requirements of 5 CFR 1320. V 

rnvacy Act, statistical standards or directives, and any other applicable information policy directives have been complied with. 

. Signature of program c"ic;sl " ' " " —__—_ _ 

Director, 0AQP 

Signature of agency ?-••:«. the senior official or an authorised representative 

i i 
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SF-83 SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY 

STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES 

Industrial-Commercial-Institutional Steam Generating Units 

A. JUSTIFICATION 

1. Need for the Information Collection. The EPA is charged under 

Section 111 of the Clean Air Act, as amended, to establish standards of 

performance for new stationary sources that reflect: 

...application of the best technological system of continuous emission 

reduction which (taking Into consideration the cost of achieving such 

emission reduction, any nonair quality health and environmental impact and 

energy requirements) the Administrator determines has been adequately 

demonstrated [Section 111(a)(1)]. 

In addition, Section 114(a) states that: 

...the Administrator may require any person who owns or operates any 

emission source or who is 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 or methods, (D) sample such 

emissions (in accordance with such methods, at such locations, at such 

intervals, and in such manner as the Administrator shall prescribe), and 

(E) provide such other Information, as he may reasonably require. 

The full text of Section 114 1s reproduced in Attachment A. 

In the Administrator's judgment, Industrial-commercial-Institutional 

steam generating units having heat input capacity of 29 MW (100 million 

Btu/hr) or larger cause or contribute significantly to air pollution that 

may reasonably be anticipated to endanger public health or welfare. 

Therefore, new source performance standards (NSPS) for emissions of sulfur 

dioxide (SOJ are being promulgated for this source category. 

Industrial-commercial-institutional steam generating units are the 

largest source category for emissions of S02 listed on the EPA priority list 
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published in August 21, 1979. Sulfur dioxide emissions from a typical 

coal-fired industrial-commercial-institutional steam generating unit 

regulated under an average State implementation plan (SIP) limiting 

emissions of SO- are approximately 750 Mg/yr (830 tons/yr). Sulfur dioxide 

emissions from a typical oil-fired industrial-commercial-institutional steam 

generating unit regulated under an average SIP are approximately 980 Mg/yr 

(1,080 tons/yr). It 1s projected that approximately 600 new industrialcommercial -Institutional steam generating units subject to the standards 

will be constructed during the first 5 years following adoption of the 

standards, most of which will be located in close proximity to urban areas. 

This growth rate 1s among the highest for any source category considered for 

regulation under NSPS. 

Certain reports are necessary to enable the Administrator to identify 

new sources subject to the standards, to ensure that the best.demonstrated 

technological (BDT) system of continuous emission reduction 1s being used, 

and to determine when sources are not in compliance with the standards. 

Additionally, sources must maintain records to demonstrate that the emission 

reduction system 1s operated and maintained 1n a manner consistent with the 

best technological system of continuous emission reduction and that the S0~ 

emission limits are achieved on a continuous basis. 

New source performance standards for particulate matter (PM) and 

nitrogen oxides (NO ) emissions from industrial-commercial-Institutional 

steam generating units were promulgated on November 25, 1986 (51 FR 42768). 

Because many of the reporting and recordkeeping requirements associated with 

the promulgated SO, standards coincide with those contained in the 
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promulgated NSPS for PM and NOx (OMB Clearance Number 2060-0072), many of 

the actions taken to comply with the PM/N0X reporting requirements will also 

satisfy the SO- reporting requirements (discussed below). Once promulgated, 

the standards for SO-, PM, and NO will be covered in a single regulation 

under Subpart Db of 40 CFR Part 60. Only the incremental burden associated 

with the SO- standards is estimated and discussed in this supporting 

statement. 

2. Description and Practical Utility of the Information Collection 

Activity. 

(a) Information Collection Activity for Industrial-CommercialInstitutional Steam Generating Units. Under this regulation, owners or 

operators of industrial-commercial-institutional steam generating units 

would be required to submit notification of construction, anticipated and 

actual startup dates, and physical or operational changes to existing 

facilities, as required under the NSPS General Provisions, 40 CFR 60.7. All 

of these requirements have been accounted for in the Information collection 

request for the promulgated PM and NO standards. Reports of initial 

performance test and Initial performance evaluations of the NO continuous 

emission monitoring systems (CEMS) are already required. The final SOstandard requires S02 CEMS be Installed and operated at all facilities 

firing coal or oil. The SO- CEMS performance evaluation can be combined 

with the NOx CEMS evaluation. 

After Initial startup, the regulation requires continuous monitoring of 

emissions at the inlet and outlet to the SO- control device and calculation 

of average percent reduction and emission rate on a 30-day rolling average 
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basis. The first 30-day rolling average after initial startup would serve 

as the initial performance test; a new 30-day average percent reduction and 

emission rate would be calculated at the end of each steam generating unit 

operating day. (Although not credited in the burden calculations, the final 

regulations allow the use of low-sulfur compliance fuels for coal- or 

oil-fired steam generating units with annual capacity factors for coal or 

oil of 30 percent or less. The final standards also allow abbreviated 

(24-hour) compliance tests for steam generating units with annual capacity 

factors for oil of 10 percent or less. These provisions reduce the burden 

of the initial compliance tests and subsequent monitoring for these units.) 

The final regulation requires each affected facility to submit 

quarterly reports. These reports would Include each 30-day rolling average 

percent reduction and SO- emission rate calculated during the quarter, as 

well as identification of any periods for which data were excluded from 

these calculations, the reason for this exclusion, and a description of 

corrective action taken. If the percent reduction requirement or emission 

limit 1s exceeded by any 30-day average, the quarterly report would Include 

the reason for the exceedance and a description of corrective action taken. 

In addition, information required under 40 CFR Part 60, Appendix F, 

Procedure 1 (Quality Assurance Requirements for Gaseous Continuous Emission 

Monitoring System Used for Compliance Determinations) (52 FR 21003, June 4, 

1987) would be submitted with the quarterly reports. This would Include 

results of all quarterly accuracy assessments performed on each CEMS and 

Information Identifying any periods during which the CEMS was operating with 

an excessive degree of measurement drift, as determined by dally calibration 
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drift tests. Records of all emission measurements and quarterly reports 

would be maintained by the affected facility for a period of 2 years. 

(b) EPA Use of Data Collected. The information will be used by the 

Agency to (1) identify new, modified, or reconstructed sources subject to 

the standards, (2) ensure that BDT is being applied to reduce emissions from 

the affected sources, (3) ensure that the emission control system is being 

properly operated and maintained, and (4) ensure that the affected sources 

are being operated in compliance with the applicable emission standards. 

If the information required by the standards were not collected, the 

Agency would have no means for ensuring that compliance with the NSPS is 

achieved and maintained by the new, modified, or reconstructed sources 

subject to the regulation. Under these circumstances, an owner or operator 

could elect without consequence to reduce expenses by not Installing, 

maintaining, or operating the control technology required by the standards. 

In the absence of the information collection requirements, the standards 

could be enforced only through continuous on-site inspection by regulatory 

agency personnel. Consequently, not collecting the Information would result 

in (1) greatly Increased resource requirements for enforcement personnel or 

(2) the inability to enforce the standards on a continuous basis. 

3. Minimizing Burden. The burden to respondents has been minimized 

by requiring the collection and reporting of only that information which the 

Agency believes 1s essential to ensure that continuous compliance with the 

standards is being achieved. As discussed below, the specific procedures 

for data collection, data reduction, and reporting have been established so 

as to minimize the burden to respondents. 
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Most of the data required to be collected and reported can be generated 

automatically with available electronic data processing equipment, thus 

minimizing manpower requirements. Such equipment can automatically perform 

the necessary calculations and format the results in a manner suitable for 

submittal in the quarterly compliance report. The costs of this equipment 

have been included in the total CEMS costs. In addition, no specific format 

for required reports has been established, allowing each respondent to 

select the least burdensome approach to data collection and reporting based 

on site-specific conditions. 

The major burden Item associated with the proposed rulemaking 1s the 

requirement to comply with the Appendix F, Procedure 1 quality assurance 

testing and reporting requirements, which requires the CEMS operator to 

conduct quarterly CEMS accuracy audits. The Agency believes that quarterly 

audits of accuracy are essential to ensure valid CEMS compliance results. 

To reduce the testing burden on the respondents, Procedure 1 requires a 

relative accuracy test once a year and allows the use of less expensive, 

surrogate auditing procedures for the other three quarters. Two techniques 

for performing the surrogate quarterly audits are Included in Procedure 1 

allowing CEMS operators to select a procedure that Is less burdensome in 

light of site-specific circumstances. 

The dally calibration drift data collection procedure required in 

» 

Procedure 1 1s the same as currently required 1n the General Provisions of 

40 CFR 60.13(d)(1), and these values can be generated with available 

electronic data processing equipment. Procedure 1 additionally requires 

that the results of the calibration drift measurements be compared with 
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specific limits to determine the acceptability of the CEMS responses. The 

Agency considered requiring the respondents to calculate and report 

statistically determined precision values using the CEMS response drift 

data. This procedure was rejected as being too burdensome for the minimal 

increase in information that would be supplied. 

4. Nonduplication. Duplication in the reporting of emissions data 

under the final standards would be minimal, if it occurs at all. Because 

the standards apply only to new units, data on emissions from these 

facilities are not currently being collected and do not duplicate existing 

data collection activities. 

In more than 95 percent of the cases, the enforcement of NSPS has been 

delegated to State air pollution control agencies. In such cases, the 

actual emission data reports required by the standards would be submitted to 

the appropriate State agency, and not directly to EPA. Thus, there 1s 

minimal possibility for the submittal of duplicate Information to State 

agencies and EPA. In those limited cases where State agencies have not 

requested delegation of NSPS enforcement, It would theoretically be possible 

that owners or operators would be required to report Information to the 

State which duplicates that required by the Agency. However, the general 

provisions of 40 CFR Part 60 provide that submission of a copy of the State 

or local report to the Administrator will satisfy the reporting 

requirements. Finally, EPA 1s using and will continue to use the Federal 

Information Locator System (FILS) to ensure that duplication of Federal 

data-gathering efforts does not occur. 
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As discussed previously, many of the reporting and recordkeeping 

requirements contained in the SO- regulation coincide with those in the 

promulgated standards for PM and N0X. Where this occurs, a single report 

for all three pollutants is required. This has been reflected in the burden 

estimates and cost analyses contained in this supporting statement. 

5. Consideration of Alternatives. The continuous monitoring 

requirements under the final standards are necessary to ensure that sources 

subject to the SO- standards are 1n continuous compliance with the 

standards. No other data are currently available that could be used to 

demonstrate this continuous compliance. 

Reporting of only excess 30-day average emission rates (and percent 

reduction levels) rather than each dally 30-day rolling average value was 

considered during development of the standards, but was not adopted. 

Reporting of only excess emission values does not noticeably reduce the 

information burden, but would noticeably reduce enforceability of the 

standards. In addition, because emissions data will be collected and 

generated using electronic data processing equipment, any Increased burden 

associated with reporting all 30-day rolling average values per quarter 

(90 data values) 1s minimal. These data will ensure that both the source 

and EPA are familiar with the general performance of the facility and 

identify in a timely manner periods of noncompliance. 

Quarterly reporting 1s considered to be the minimum reporting frequency 

which will provide enforcement agencies with timely Information necessary to 

ensure that sources are in continuous compliance with the SO- standards. 

This reporting burden will be minimal considering the magnitude of emissions 

8 
P.13 

from industrial-commercial-institutional steam generating units, and 

considering that the reported information will be generated using electronic 

data processing equipment. Semiannual and annual reporting periods were 

considered, but were determined to be too infrequent to be compatible with 

timely enforcement of the standard. 

6. Minimizing Burden for Small Business. The information collection 

burden on small businesses will be negligible or nonexistent. Because of 

the lower size cutoff of 29 MW (100 million Btu/hr) heat Input capacity 

under the standard, few, if any, small businesses are expected to be 

affected by the standard. 

In the event that a small business would be subject to the standard, 

and thereby subject to the compliance testing and reporting requirements, 

the Impacts would be small because the costs of emission measurement and 

reporting requirements under this rulemaking represent less than 1 percent 

of the total annualized steam generating unit costs. 

7. Consideration of Collection. Four of the information requirements 

under the final S02 standards are already satisfied by the final PM/NO 

regulation and the burden associated with these was addressed in the 

information collection request submitted with that regulation. These 

requirements are for: 

notification of construction or reconstruction, 

notification of physical or operational change, 

notification of anticipated startup, and 

notification of actual startup. 
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In addition, four other information requirements under the SO- standards are 

one-time only notifications or reports and cannot be performed on a less 

frequent basis. These are: 

notification of demonstration of CEMS, 

notification of Initial performance test, 

report of initial performance test, and 

report of demonstration of CEMS. 

Only the quarterly emissions report (Including results of the Appendix F 

relative accuracy tests and dally drift assessments discussed above) 1s a 

repetitive requirement. These reports are necessary to ensure compliance 

with the standards on a continuous basis. As discussed above, the quarterly 

frequency of these reports was chosen by the Agency as the period that will 

provide an adequate margin of assurance that facilities subject to the 

standard will not operate for extended periods in violation of the 

standards. Consequently, data collection and reporting on a less frequent 

basis would decrease the margin of assurance that facilities are in 

compliance with the standards and Increase the risk to public health and 

welfare. In addition, because the data are collected and analyzed by 

automated equipment, the burden associated with generating, copying, and 

submitting these data on a quarterly versus semiannual basis 1s minimal. 

8. Paperwork Reduction Act Guidelines. There are no special 

circumstances that require the Information collection to be conducted in a 

manner inconsistent with the guidelines In 5 CFR 1320.6. 

9. Consultations. From the outset, the comments of Interested 

persons have been solicited In formulating the final standards. An 

10 
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important element in efforts to solicit public comments during development 

of NSPS is the review of staff technical analyses and policy recommendations 

by the National Air Pollution Control Techniques Advisory Committee 

(NAPCTAC). This advisory committee is composed of representatives of State 

and local governments, regulated industries, environmental organizations, 

and technical consultants with expertise in air pollution control 

technologies. 

Several presentations to NAPCTAC were made to solicit the views of 

committee members and interested members of the public. Additional meetings 

were held with affected Industries at several times during development of 

the standards to solicit comments on the monitoring and reporting 

requirements. Table 1 is a representative sample of persons consulted in 

developing the standards. In addition, a public comment period was held 

from June 19, 1986, to October 2, 1986, to solicit comments on the proposed 

standards. A public hearing was held on September 4, 1986, to allow 

interested parties the opportunity for oral presentation of views. These 

comments were carefully considered in developing the final standards. 

10. Confidentiality. The data required by the reporting requirements 

are principally emissions data and are not confidential. However, if any 

information 1s submitted to EPA for which a claim of confidentiality is 

made, the Information 1s safeguarded according to the Agency policies set 

forth in 40 CFR Part 2, Subpart B - Confidentiality of Business Information. 

11. Sensitive Questions. Not applicable. Information consists of 

emissions data and other similar information that have been determined not 

to be private. 

11 
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12. Cost to the Government and to the Respondents. 

(a) Cost to the Federal Government. The regulation results in costs 

to the Federal Government associated with the analysis of the reported 

information. Publication and distribution of the reported Information are 

part of the Compliance Data System that is operated and maintained by EPA's 

Stationary Source Compliance Division. Examination of the records to be 

maintained by the respondents will occur Incidentally as part of the 

periodic Inspection of sources that 1s a part of EPA's overall compliance 

and enforcement program. 

The average incremental annual costs to the Federal government 

associated with the S02 reporting requirements during each of the next 

3 years are expected to be about $290,200. These costs are based on an 

average salary of $14.50 per hour (Grade 10, Step 7), 2,080 working hours 

per year, and a 110 percent overhead rate, and are in addition to the costs 

identified in the PM/N0X standard submittal for this source category. The 

breakdown of these costs by category 1s shown below: 

Cost Category £gsl 

Direct personnel costs $138,200 

Overhead (110 percent) $152.000 

Total $290,200 

The basis of this estimate 1s presented in Table 2. 

(b) Cost to Respondents. The costs for a single representative 

respondent to comply with the SO- recordkeeping and reporting requirements 

are summarized in Table 3. The Incremental annual cost to a representative 

respondent associated with these recordkeeping and reporting requirements 

12 
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would be about $35,000 to $49,000 in Year 1 and $17,000 to $30,000 in 

subsequent years, depending on the type of CEMS used. These costs are based 

on an average salary of $14.50 per hour and a 110 percent overhead rate. 

The costs to comply with the Appendix F quality assurance requirements are 

based on all work being performed by contractor personnel at $50 per hour. 

As shown in Table 3, much of the calculated costs to respondents are 

one-time only costs associated with initial performance demonstrations. The 

only recurrent costs to respondents are those associated with collecting and 

maintaining the required emissions data and submitting quarterly compliance 

reports and Appendix F quality assurance reports. Because the data 

collection and maintenance activities are performed using the same automated 

equipment as were already required in the final standards for PM and NO , 

only minimal additional time 1s necessary for operation and maintenance of 

CEMS in compliance with the SO- standards. 

13. Estimation of Respondent Burden. As mentioned above, the 

information collection requirements include the following one-time only 

reports: 

notification of construction or reconstruction, 

notification of physical or operational changes, 

notification of anticipated date of Initial startup, 

notification of actual date of initial startup, 

notification of demonstration of CEMS, and 

notification of the date of the initial performance test. 

13 
P.18 

The first four of these do not convey any incremental burden for the SOinformation collection request, since they are completely satisfied by the 

PM/NO reporting requirements. 

In addition to the one-time only requirements, the following periodic 

recordkeeping and reporting activities are required: 

quarterly compliance reports, 

quarterly Appendix F quality assurance report, and 

records of performance test emissions data collected using the 

CEMS. 

As mentioned above, the recordkeeping burden associated with the SOstandard has been Included 1n the Information collection request for the 

final PM and NO standards. 

These information collection requirements were applied to the 

121 fossil-fuel-fired Industrial-commercial-Institutional steam generating 

units projected to be constructed each year in the 5-year period following 

promulgation of the standard. The annual burden to all respondents subject 

to the SO- standards 1s estimated to be 150,172 person-hours 

(72 person-years) per year during the first 3 years following promulgation 

of the standard. Table 3 provides a breakdown of the components that make 

up the total burden. The burden may vary from respondent to respondent as 

shown in the table, depending on the type of CEMS employed by the 

* 

respondent. 

For a number of reasons, this annual respondent burden level should be 

considered an "upper limit" estimate of possible burden Impacts. First, the 

American Boiler Manufacturers Association (ABMA) suggests the projected 

14 
P.19 

121 fossil-fuel-fired steam generating units per year overestimates actual 

new steam generating unit construction, thereby overestimating the industry 

burden associated with this regulation. Second, Subpart Db will supersede 

Subpart D for new steam generating units with heat input capacities greater 

than 73 MW (250 million Btu/hour) and burden credits which could have been 

claimed for the Subpart D monitoring requirements (which would require these 

units to Install CEMS even in the absence of the Subpart Ob estimates. This 

would have further reduced the Industry burden estimates associated with the 

final SO- standards. Third, the final standards allow "compliance fuels" to 

be fired and abbreviated compliance testing for steam generating units 

operating at low capacity factors for coal or oil. As noted previously, 

these less stringent requirements have not been Included in these burden 

estimates and would further reduce the industry burden. 

Finally, these burden estimates assume that all of the projected 

605 new fossil-fuel-fired steam generating units would fire either coal or 

oil, and that no natural gas (for which there are no continuous monitoring 

or reporting requirements) would be used. It is difficult to determine 

exactly how much natural gas will be fired in the future, but estimates have 

indicated that as much as 80 percent of the new fossil-fuel-fired steam 

generating units projected to be constructed over the next 5 years could be 

gas-fired. Thus, the Industry burdens presented 1n Table 3 represent a 

conservative estimate. 

Because of the conservative nature of the estimates presented, no 

additional burden has been added for the possible 20 to 30 mixed-fuel-fired 

(coal/wood or oil/wood) steam generating units that may be covered under the 

final SO- standards. 

15 
P.20 

14. Reasons for Change in Burden. The annual burden estimate for the 

promulgated standard is 150,742 person-hours. Since this is a new standard, 

there is no previous burden level associated with it. It would Increase the 

PM/NO burden level of 141,167 person-hours by 150,742 for a total 

Subpart Db burden of 291,909 person-hours per year. As discussed above, 

this is a conservative estimate. 

15. Scheduling. The data submitted by respondents will be used to 

monitor compliance with the SO- emission standard and will be entered Into 

the Compliance Data System (CDS). A specific time schedule for the 

collection of information 1s not applicable. The data are not being 

requested for any currently scheduled survey or report. 

16. Standard Industrial Classification (SIC) Code. This standard will 

apply to steam generating units that are operated under numerous industrial 

classifications (SIC codes). Any industrial sources that employ a steam 

generating unit with a heat Input capacity greater than 29 MW (100 millfon 

Btu/hour) that fires coal or oil would be subject to the SO- compliance, 

reporting, and recordkeeping requirements. The five SIC groups covering the 

majority of respondents are SIC Codes 20 (food and kindred products), 

22 (textile products), 26 (paper and allied products), 28 (chemicals and 

allied products), and 29 (petroleum and coal products). 

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS 

This section 1s not applicable because statistical methods are not used 

in the data collection associated with this regulation. 

16 
P.21 

TABLE 1. REPRESENTATIVE SAMPLE OF PERSONS CONSULTED ON THE 

DEVELOPMENT OF THE INDUSTRIAL-COMMERCIAL-INSTITUTIONAL 

STEAM GENERATING UNIT NSPS FOR SOName 

Barney Camponeschi 

Don Culbertson 

Mark Wade 

Bill Quan 

Vivian Mclntire 

Ellyce H111berry 

Benjamin Rogers 

George Green 

John Pinkerton 

Bill Axtman 

Affiliation 

FMC Corporation 

Chevron 

Gulf 011 

California Dept. of Health Services 

Tennessee Eastman 

Kern County (Calif.) Air Pollution 

Control District 

General Motors 

Public Service of Colorado 

National Council of the Paper 

Industry for Air and Stream 

Improvement, Inc. 

American Boiler Manufacturers 

Association (ABMA) 

Telephone 

Number 

(312) 

(805) 

(805) 

(916) 

(615) 

(805) 

(313) 

(303) 

(212) 

(703) 

843-1700 

762-7550 

395-6311 

324-1807 

229-3045 

861-3682 

857-5000 

571-7511 

532-9000 

522-7350 

17 
TABLE 2. ANNUAL ESTIMATE OF DIRECT PERSONNEL COST TO THE FEDERAL GOVERNMENT TO IMPLEMENT 

INDUSTRIAL-COMMERCIAL-INSTITUTIONAL STEAM GENERATING UNIT NSPS FOR SO * 

Activity Hours Assumptions 

1. Review notification of construction or reconstruction 

2. Review notification of anticipated startup 

3. Review notification of actual startup 

4. Review notification of physical or operational change 

5. Review notification of initial performance test 

6. Review notification of continuous Monitoring system 

7. Review report of initial performance test 

8. Review continuous eon 1 tor Ing systea perforaance 

9. Review quarterly reportsi 

Excess ealsslon reports 

Appendix F OA data assessment reports 

0 

0 

0 

0 

242 

242 

968 

,936 

.792 | 

362 

0 

0 

0 

0 

3.500 

3.500 

14,000 

28.000 

84.000 

S.200 

Already covered by PM/NO regulation. 

See 1. above. 

See 1. above. 

No reconstructed sources anticipated. 

2 hours per report, 121 new sources subject to 

perforaance test per year. 

2 hours per report, 121 sources per year. 

8 hours per report, 121 sources per year. 

16 hours per report, 121 sources per year. 

8 hours per report, 4 reports per source per year, 

average of 181 sources per reporting period. 

0.5 hours per report, 4 reports per source per 

year, average of 181 sources per reporting 

period. 

Based on a scenario of 100 percent of all units eaploytng FGD. 

S14.50 per hour direct personnel cost (rounded to nearest SlOO). 

c121 new sources per year averaged over the 3-year period. 

ro 
TABLE 3. ESTIMATED ANNUAL COST AND BURDEN TO INDUSTRY TO IMPLEMENT INDUSTRIAL-COMMERCIAL-INSTITUTIONAL STEAM GENERATING UNIT NSPS FOR S0„ 

Burden Itea 

Person-Hours 

Per 

Occurrence 

Occurrences 

Per Respondent 

Per Year 

Person-Hours 

Per Respondent 

Per Year 

Cost 

Per Respondent 

<») a 

Respondents 

Per Year 

Person-Hours 

Per Year 

Cost 

Per Year 

($> a 

1. Applications 

2. Surveys and Studies 

3. Reporting Requirements 

A. Read Instructions 

B. Required Activities 

- Initial perforaance test 

- Deaonstratlon of CEMS 

- Appendix F annual relative accuracy 

test 

- Appendix F quarterly audits: 

- In situ CEMS (RAA) 

- Extractive CEMS (CGA) 

C Create Information 

0. Gather Existing Information 

E. Write Report 

- Notification of construction/ 

reconstruction 

- Notification of physical/operational 

changes 

- Notification of anticipated startup 

- Notification of actual startup 

- Notification of demonstration of CEMS 

- Notification of Initial perforaance 

test 

- Report of Initial perforaance test 

- Report of deaonstratlon of CEMS 

- Quarterly emission report 

- Appendix F QA data assessment report 

N/A 

N/A 

250 

350 

146 

125 

36 

See 3B 

See 3E 

1 

1 

1 

3 

3 

250 

350 

146 

375 

108 

30u 

7.612° 

10.657° 

7.300c 

18.750*-

5,400c 

0

r\ 

o

d 

2 

2 

See 3B 

See 3B 

16 

11 

0 

0 

1 

1 

4 

4 

0 

0 

2 

2 

64 

44 

0 

61° 

1,950 

2.200c 

121 

121 

121 

181 

45 

136 

121 

30.250 

42.350 

26,426 

16.875 

14,688 

0 

0 

121 

121 

181 

181 

0 

0 

242 

242 

11.584 

7.964 

3.684 

921.112 

1,289.557 

1.321.300c 

843,1S0T 

734.400c 

0 

0 

7,369 

7,369 

352,733 

398.200 

(Continued) 
TABLE 3. ESTIMATED ANNUAL COST AND BURDEN TO INDUSTRY TO IMPLEMENT INDUSTRIAL-COMMERCIAL-INSTITUTIONAL STEAM GENERATING UNIT NSPS FOR SO 

(Concluded) 

Burden Ite a 

Person-Hours 

Per 

Occurrence 

Occurrences Person-Hours Cost Cost 

Per Respondent Per Respondent Per Respondent Respondents Person-Hours Per Year 

Per Year Per Year ($)" Per Year Per Year ($) 

4. Recordkeeping Requirements 

A. Read Instructions 

B. Plan Activities 

C. Implement Activities 

D. Develop Record System 

E. Time to Enter Information 

- Records of startup, shutdown, 

malfunction 

- Records of all measurements 

and Information required 

F. Time to Train Personnel 

G. Time for Audits 

See 3A 

N/A 

N/A 

N/A 

N/A 

0

d 

N/A 

N/A 

Total: All Burden Ita 1,234 (967) f.h 48,621 (35.271) f.h 

629 (362)9'

h 30.200 (16,850)9'h 

150.742 5.879.474 

aCosts are based on a $14.50 per hour pay rate plus an overhead rate of 110 percent. Thus, the total cost per hour Is assumed to be $30.45. 

One-time only costs. 

cBased on contractor costs of $50 per hour. 

Already covered In the PN/NOx reporting requirements. 

e No modified or reconstructed units anticipated. 

fYear 1. 

^Years 2 and 3. 

Nuaber In parentheses Is for units equipped with extractive CEMS; nuaber not In parentheses Is for units equipped with In-sltu CEMS. 
P.25 

AttachMnt _£ 

THE CLEAN AIR ACT1 

' TITLE I--AIR POLLUTION PREVENTION ANO CONTROL 

INSPECTIONS, MONITORING, ANO ENTRY 

Sac. 114 (a) For tht purpose (1) of developing or assisting in tha 

develop—nt of any implementation plan undar Section 110 or 111(d), any 

standard of parfornanca undar Saction 111, or any fission standard undar 

Section 112. (ii) of determining whether any parson is in violation of 

any such standard or any requirement of such a plan, or (ill) carrying 

out any provision of this Act (axcapt a provision of Titla II with 

respect to a manufacturer of new motor vehicles or new motor vehicle 

anginas)— 

(1) Tht Administrator may require any parson who owns or operates 

any Mission sourca or who 1s subject to any requirement of this Act 

(othtr than a manufacturer subject to tht provisions of Stctlon 206(c) 

or 208) with rtspact to a provision of Titlt II to (A) establish and 

maintain such records. (B) aaka such raports. (C) install, ust. and maintain such monitoring tguiptnt or Methods, (0) sample such fissions (in 

accordance with such mtthods. at such locations, at such intervals, and 

in such manntr as tht Administrator shall prescribe), and (E) provide 

such othtr inforation, as ht may reasonably require; and 

(2) tht Administrator or his authorized representative, upon 

presentation of his credentials— 

(A) shall have a right of entry to, upon, or through any premises 

of such parson or in which any records required to bt maintained undtr 

paragraph (1) of this saction art located, and 

(B) M y at reasonable tilts havt accass to and copy any records, 

inspect any monitoring equipment and method required undtr paragraph (1), 

l42 U.S.C 1857 at sag. 

19 
P.26_ 

and sample any fissions which such parson is required to sample undar 

paragraph (1). 

(b) (1) Each State may develop and submit to tht Administrator a 

procedure for carrying out this stctitn in such Statt. If tht 

Administrator finds tht Statt procedure is adtquatt, ht nay delegate to 

such Stata any authority ht has to carry out this saction. 

(2) Nothing in this subsection shall prohibit tht Administrator 

from carrying out this saction in a Stata. 

(c) Any records, rtports, or information obtained undtr 

subsection (a) shall ba avallabia to tht public, txctpt that upon a 

showing satisfactory to tht Administrator by any parson that records, 

reports, or information, or particular part tharaof, (othtr than emission 

data) to which tht Administrator has accass undar this saction if madt 

public, would divulge mtthods or processes entitled to prottction as 

tradt secrets of such ptrsons, tht Administrator shall considar such 

record, report, or information or particular portion tharaof confidential 

in accordance with tha purposes of saction 1905 of Titlt 18 of tha 

Unittd Statas Coda, axcapt that such record, report, or information may 

bt disclosed to othtr officers, employees, or authorized representatives 

of tht Unittd States concerned with carrying out this Act or whan 

relevant in any procttding undtr this Act. 

(d) (1) In tht cast of any fission standard or limitation or othar 

requirement which is adoptad by a Stata, as part of an applicable 

implementation plan or as part of an order undtr Section 113(d), before 

carrying out an entry, inspection, or monitoring undtr Paragraph (2) of 

Subsection (a) with respect to such standard, limitation, or othar 

requirement, tht Administrator (or his representatives) shall provide the 

Statt air pollution control agency with reasonable prior notica of such 

action, Indicating tht purpose of such action. No Statt agency which 

rtctivas notice undtr this paragraph of an action proposad to bt taken 

•ay usa tht information contained In tht notict to inform tht ptrson 

whose property is propostd to bt affected of tht proposad action. If 

tht Administrator has reasonable basis for btlitving that a Statt agency 

is so using or will so ust such information, notica to tha agency under 

this paragraph is not required until such tlmt as tht Administrator 

20 
P.27 

rdtttrmlnts tht agency will no longtr so usa information contained in a 

notict undtr this paragraph. Nothing in this section shall bt construed 

to require notification to any Stata agency of any action taken by the 

Administrator with respect to any standard, limitation, or other requirement which is not part of an applicable implementation plan or which was 

promulgated by the Administrator under Section 110(c). 

(2) Nothing in Paragraph (1) shall be construed to provide that any 

failure of the Administrator to comply with tht requirements of such 

paragraph shall be a defense in any enforcement action brought by the 

Administrator or shall make inadmissible as evidence in any such action 

any information or material obtained notwithstanding such failure to 

comply with such requirement. 

21