# 1 SUPPORTING STATEMENT

ENVIRONMENTAL PRO TECTION AGENCY

National Emission Standards for Hazardou s Air Pollutants from Coal- and Oil-fired

Electric Utility Steam Generating Units and Standards of Performance for Fossil-FuelFired Electric Utility, Industrial-Commercia l-Institutional, and Small IndustrialCommercial-Institutional Steam Generating Units

(40 CFR part 63, subpart UUUUU)

(40 CFR part 60, subparts D, Da, Db, and Dc)

February 2011

Part A of the Supporting Statement

1. Identification of the Information Collection

(a) Title and Number of the Information Collection

“Recordkeeping and Reporting Requirements for Coal- and Oil-fired Electric Utility

Steam Generating Units (40 CFR Part 63, Subpart UUUUU).” The Office of Management and

Budget (OMB) previously approved the informa tion collection requirements for the Clean Air

Mercury Rule (CAMR) in 2005. However, th e ICR was discontinued because CAMR was

vacated by a three-judge panel of the United States (U.S.) Court of Appeals for the District of

Columbia Circuit (D.C. Circui t Court) on February 8, 2008, and the mandate effectuating the

decision was issued on March 14, 2008 (as a result of a motion by the plaintiffs for expedited

issuance of the mandate). Because that inform ation collection was developed explicitly to

determine compliance with CAMR, it was no l onger needed. This is considered a new

information collection request (ICR). The OMB control number is 2060-0567. The EPA ICR

tracking number is 2137.05.

(b) Short Characterization

The U.S. Environmental Protection Agency (EPA or Agency) is proposing national

emission standards for hazardous air pollutants (NESHAP) from coal- and oil-fired electric

utility steam generating units (E GUs or Utility Units) under Clean Air Act (CAA) section 112(d)

and proposing revised new source performance st andards (NSPS) for fossil fuel-fired EGUs

under CAA section 111(b).

On December 20, 2000, EPA determined pursuan t to CAA section 112(n)(1)(A) that it

was appropriate and necessary to regulate coal- and oil-fire d EGUs under CAA section 112 and

added such units to the CAA sec tion 112(c) list of sources that must be regulated under CAA

section 112(d) (see 65 FR 79825). On Janua ry 30, 2004, EPA proposed CAA section 112(d)

standards for mercury (Hg) emissions from coal-fired EGUs and nickel (Ni) emissions from oilfired EGUs, and, in the alternativ e, proposed to remove EGUs fr om the CAA section 112(c) list

based on a finding that it was neith er appropriate nor necessary to regulate EGUs pursuant to

CAA section 112 (see 69 FR 4652). On March 29, 2005, EPA issued a final revision of the

appropriate and necessary finding for coal- and oi l-fired EGUs and removed such units from the

CAA section 112(c) list of sour ces (Section 112(n) Revision Rule (Revision Rule) (see 70 FR

15994). EPA never finalized the proposed CAA s ection 112(d) standard. The removal of EGUs

# 2 from the CAA section 112 list was challenged in the D.C. Circuit Court. On February 8, 2008,

the D.C. Circuit Court vacated the Revision Rule after determining that EPA violated the CAA

by removing EGUs from the CAA section 112(c) list of sources without complying with the

delisting requirements set forth in CAA section 112(c)(9). State of New Jersey v. EPA, 517 F.3d

583. Thus, EGUs remain a CAA sec tion 112(c) listed source category.

In response to the D.C. Circuit Court’s vacatur, EPA is proposing CAA section 112(d)

NESHAP for all coal- and oil-fired EGUs that re flect the application of the maximum achievable

control technology (MACT) consiste nt with the requirements of CAA sections 112(d)(2) and (3).

The proposed rule would protect air quality and promote public health by reducing emissions of

the hazardous air pollutants (HAP) listed in CAA section 112(b).

In general, all NESHAP sta ndards require initial notifica tions, performance tests, and

periodic reports. These notif ications, reports, and records are essential in determining

compliance, and are required of al l sources subject to the NESHAP.

Any owner or operator subject to the provisions of this part sh all maintain a file of these

measurements, and retain the file for at least fi ve years following the date of such measurements,

maintenance reports, and records. All reports are se nt to the delegated stat e or local authority. In

the event that there is no such delegated authority , the reports are sent directly to the U.S. EPA

regional office.

Potential respondents are owners or operat ors of EGUs. The pr oposed NESHAP would

establish emission limits for total particulate matt er (PM), hydrogen chlori de (HCl), and mercury

(Hg) for coal-fired EGUs, and emission limits for Hg, total metal HAP, HCl, and hydrogen

fluoride (HF) for oil-fired EGUs. To demonstrat e compliance with these emission limits, owners

or operators of EGUs would be required to continuously monitor PM, Hg, HF, and HCl

emissions. Respondents would be required to maintain additional records to demonstrate

compliance with Hg, HF, HCl, metal HAP, and PM limits and notify EPA of performance tests.

These requirements are listed in Exhibit 1.

Exhibit 1. Source Data and Information Requirements

Requirement Regula tion Citation

Notifications

Notification of Demonstration of continuous

emissions monitoring system (CEMS) 63.10030

Notification of Initial Performance Test 63.10030

Quality Assurance Program Notification 63.10030

Notification of Compliance Status 63.10030

Request to use alternative monitoring procedure 63.10030

Initial notification 63.10030

Reports

Report of Performance Test 63.10031

Startup, shutdown, and malfunction Report 63.10031

Semi-Annual Compliance Report 63.10031

Site-specific performance ev aluation test plan 63.10031

Recordkeeping

Existing Sources - Records of CEMS malfunctions 63.10032

Existing Sources - Records of Startups, Shutdowns, 63.10032

# 3 malfunctions, etc

Existing Sources - Records of monthly fuel use 63.10032



# EPA estimates that approximately 1,257 existi ng EGUs would be subject to the proposed

NESHAP, and that no new EGUs will be built during the period of this information collection.

On February 27, 2006, EPA promulgated amendments to the new source performance

standards (NSPS) for particulate ma tter (PM), sulfur dioxide (SO 2 

# ), and nitrogen oxides (NO X 

# )

contained in the standards of performance for EGUs (40 CFR part 60, subpart Da, 71 FR 9866).

EPA was subsequently sued by the offices of multiple States Attorneys General and

environmental organizations on the amendmen ts. On September 2, 2009, EPA was granted a

voluntary remand without vacatur of the 2006 amendm ents. These proposed amendments are in

response to the voluntary remand. We also are proposing several minor amendments, technical

clarifications, and corrections to existing provisions of the foss il fuel-fired EGU and industrialcommercial-institutional, and small industrial-commercial-institutional steam generating units

NSPS, subparts D, Db, and Dc of 40 CFR part 60. Because no new EGUs are projected to be

built, there would be no recordkeeping and re porting burden associated with the proposed

amendments.

2. Need for and Use of the Collection

(a) Need/Authority for the Collection

Section 112 of the CAA requires that EPA establish MACT standards for new or existing

major or area sources according to the requi rements in section 112(d). Certain records and

reports are necessary for the Administrator to : (1) confirm the compliance status of major

sources, identify any non-major sources not subj ect to the standards, and identify new or

reconstructed sources subject to the standards; and (2) ensure th at the MACT standards are being

achieved on a continuous basis. These recordkeep ing and reporting requirements are specifically

authorized by section 114 of the CAA (42 U.S.C. 7414) and set out in the General Provisions for

NESHAP in 40 CFR part 63, subpart A.

(b) Use/Users of the Data

The additional information will be used by Agency enforcement personnel to ensure that

the emission limitations are being achieved. Base d on review of the recorded information at the

site and the reported information, EPA can identify facilities that may not be in compliance and

decide which plants, records, or processes should be inspected.

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication

No other regulation currently requires the sa me information requested under this ICR

from owners/operators of Coal- and Oil-fired EG Us or owners/operators of Fossil-Fuel-Fired

Electric Utility, Industrial-Co mmercial-Institutional, and Sm all Industrial-CommercialInstitutional Steam Generating Units. In the event that certain reports requ ired by State or local

agencies may duplicate information required by th e proposed requirements, a copy of the report

submitted to the State or local agency can be pr ovided to the Administrator in lieu of the

# 4 information that would be required in the se mi-annual compliance report. Therefore, no

duplication exists.

(b) Public Notice Required Pr ior to ICR Submission to OMB

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

(c) Consultations

EPA met with 10 national orga nizations representing State an d local elected officials to

provide general background on the proposed NESHAP , answer questions, and solicit input from

State/local governments. EPA also consulted w ith Tribal officials ear ly in the process of

developing the proposed NESHAP to permit them to have meaningful and timely input into its

development. Consultation letters were sent to 584 Tribal leaders. The letters provided

information regarding EPA’s development of NESHAP for EGUs and offered consultation.

Three consultation meetings we re requested and held.

(d) Effects of Less Frequent Collection

If the relevant information were collected less frequently, EPA would not be reasonably

assured that a plant is in co mpliance with the standards.

(e) General Guidelines

None of the guidelines in 5 CFR 1320.5 are being exceeded.

(f) Confidentiality

All information submitted to the Agency for wh ich 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 01, 1976;

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR

17674, March 23, 1979).

(g) Sensitive Questions

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

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes

Under the proposed NESHAP, respondents are 1,257 owners or operators of existing

EGUs. It is estimated that no new EGUs will be built during the period of this information

collection. All respondents wi ll be subject to the monito ring, recordkeeping, and reporting

requirements. The NAICS code for this industry is 221100, Elect ric Power Generation,

Transmission and Distribution. There are no re spondents under the prop osed NSPS amendments

because no new EGUs are projected to be built.

# 5 (b) Information Requested

(i) Data Items, Including Recordkeeping Requirements.

Exhibit 1 (Source Data and Information Requirements) summarizes the final

recordkeeping and reporting requirements.

(ii) Respondent Activities.

The respondent activities required by the pr oposed NESHAP are introduced in section

6(a).

In setting the standards, th e CAA requires us to consider alternative emission control

approaches, taking into account the estimated co sts and benefits, as well as the energy, solid

waste and other effects. EPA requests comment on whether it has iden tified the appropriate

alternatives and whether the proposed standard s adequately take in to consideration the

incremental effects in terms of emission re ductions, energy, and other effects of these

alternatives. EPA will consider the availabl e information in developing the final rule.

The costs, environmental, energy, and econom ic impacts are typically expressed as

incremental differences between th e impacts of owners/operators of facilities complying with the

proposed NSPS amendments and the current NSPS emission standards (i.e., baseline). However,

for EGUs this would not accurately represent actual costs and benefits of the proposed

amendments. Requirements of the New Source Review (NSR) program often result in new

utility units installing controls beyond what is required by the existing NSPS. In addition,

owners/operators of new EGUs subject to the re quirements of the Clean Air Transport Rule will

likely elect to minimize opera ting costs by operating at SO 2 

# and NO X 

# emission rates lower than

what is required by the existing NSPS . Finally, the EGU NESHAP PM and SO 2 

# standards for

new facilities are as stringent or more stringent than the proposed NSPS amendments so we have

concluded that there are no costs or benefits associated with t hose amendments. In addition, no

new EGUs are projected to be built during th e period of the information collection.

While multiple coal-fired EGUs have recently commenced operation and several are

presently under construction, no new coal-fired power plants have commenced construction in

either 2009 or 2010. In addition, forecasts of new generation capacity from both the Energy

Information Administration and the Edison Electric Institute do not project any new coal-fired

power plants will be constructed in the short term. This is an indication that in the near term

there will not be any new coal-fired EGUs that would be subject to the NSPS amendments or the

NESHAP requirements for new EGUs. Because of fuel supply availability and cost

considerations, EPA projects no new oil-fired EGUs will be built during the next 5 years. Thus,

there would not be any new oil- fired EGUs that would be subj ect to the NSPS amendments or

the NESHAP requirements for new EGUs. All new natural gas-fired EGUs built in the

foreseeable future are likely to be combined cy cle units or combustion turbine peaking units and,

thus not subject to subpart Da of 40 CFR part 60, but instead subject to the NSPS for combustion

turbines under subpart KKKK of 40 CFR part 60.

(iii) Electronic Reporting.

EPA is proposing that utility units have th e option of submitting to an EPA electronic

database an electronic copy of th eir required stack test. This el ectronic database should become

available as of December 31, 2011. Currently, sources are using monitoring equipment that

# 6 provides automated parameter data (e.g., continu ous opacity monitoring). Although personnel at

the affected facility must evalua te these data, this type of moni toring equipment has significantly

reduced the burden associated w ith monitoring and recordkeeping. In addition, some regulatory

agencies are setting up electronic reporting sy stems to allow sources to report such data

electronically which also reduces the reporting burden. It is estimated that approximately 10

percent of the respondents curren tly use electronic reporting.

5. The Information Collected: Agency Ac tivities, Collection Methodology, and

Information Management

(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 re peat performance tests, if necessary.

Review notifications and repor ts, including performance test reports, and excess emissions

reports, required to be submitted by industry.

Audit plant records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS) database.

(b) Collection Methodo logy and Management

Following notification of startup, the review ing authority might inspect the source to

determine whether the pollution control devi ces 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 semi-annual reports are used for

problem identification, as a check on source operation and maintenance, and for compliance

determinations.

Information contained in the reports is ente red into the AIRS Facility Subsystem (AFS)

which is operated and maintained by EPA’s Offi ce of Compliance. AFS is EPA’s database for

the collection, maintenance, and retrieval of compliance and annua l emission inventory data for

over 125,000 industrial and government owned facilities. EP A uses the AFS for tracking air

pollution compliance and enforcement by local a nd state regulatory agencies, EPA regional

offices and EPA headquarters. EPA and its delega ted Authorities can edit , store, retrieve, and

analyze the data.

The records required by this regulation must be retained by the owner or operator for five

years.

(c) Small Entity Flexibility

During this rulemaking, the Agency conducted outreach to small en tities and convened a

Small Business Advocacy Review (SBAR) Pane l to obtain advice and recommendations of

representatives of the small entities that potentia lly would be subject to the requirements of the

proposed NESHAP. EPA met with these small en tity representatives (SERs) to discuss the

potential rulemaking approaches and potential options to decreas e the impact of the rulemaking

on their EGUs. Outreach materials were distri buted to the SERs; these materials included

# 7 background, project history, CAA section 112 ov erview, constraints on rulemaking, affected

facilities, data, rulemaking op tions under consideration, poten tial control technologies and

estimated costs, applicable small entity defi nitions, small entities potentially subject to

regulation, and questions for SERs . EPA met with SERs that w ould be impacted directly by the

proposed rule to discuss the outreach material s and receive feedback on the approaches and

alternatives detailed in the out reach materials. The Panel received written comments from the

SERs following the meeting in response to discus sions at the meeting and the questions posed to

the SERs by the Agency. The SERs were specif ically asked to provide comments on regulatory

alternatives that could help to minimize the rule’s impact on small businesses.

(d) Collection Schedule

The specific frequency for each information co llection activity within this request is

shown in Tables 1a-c and Exhibit 2: Res pondent Burden of Reporting and Recordkeeping

Requirements, NESHAP for Coal- and Oil-fire d Electric Utility Steam Generating Units (40

CFR Part 63, Subpart UUUUU).

6. Estimating the Burden and Cost of the Collection

Tables 1a, 1b, and 1c document the com putation of individual burdens for the

recordkeeping and reporting requirements of the proposed NESHAP applicable to the industry

over the period of this information collection (i .e., for each of the first 3 years). Exhibit 2

contains a summary of the respondent burden hour s and costs detailed in Tables 1a, 1b, and 1c.

Exhibit 2. Summary of Respondent Burden

Year Total Annual Labor Burden (h ours) Total Annual Labor Costs ($)

1 317,122 25,977,769

2 318,267 26,071,597

3 353,425 28,951,630

Total 988,814 81,000,996

3-Year Average 329,605 27,000,332



# The individual burdens are expressed under standardized headings believed to be

consistent with the concept of burden under th e 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, a nd a person is not required to respond to, a

collection of information unless it displa ys a currently valid OMB Control Number.

(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 329,605 hours per year (Total Labor Hours from

Tables 1a, 1b, and 1c). These hours are base d on Agency studies and background documents

from the development of the regulation, Agency knowledge, a nd experience with the NESHAP

program, the previously approved IC R, and any comments received.

# 8 (b) Estimating Respondent Costs

Respondent costs are divided in to four categories. These cat egories include labor costs,

capital costs (includes startup costs), operations and maintenan ce costs, and annualized capital

costs. The total respondent costs ($49,445,556) have been calculated as the sum of the

annualized capital costs (including startup and the capitol recovery f actor costs) ($49,148,878)

and the annual operation and maintenance costs ($296,679).

(i) Estimating Labor Costs

Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data.

Technical, management, and clerical average ho urly rates for private industry workers were

taken from United States Department of Labor , Bureau of Labor Statistics for NAICS 221100,

May 2009 information, available at http://www.bls.gov/oes/ current/naics4_221100.htm . Wages

for technical labor are based on "Architectur e and Engineering Occ upations: Environmental

Engineers" with a total comp ensation of $40.04/hour. Wages for management labor are taken

from "Management occupations: Engineeri ng Managers" with a to tal compensation of

$56.31/hour. Wages for clerical labor are ba sed on "Office and administrative support

occupations” with a total compensa tion of $20.04/hour. These rates re present salaries plus fringe

benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to

account for these costs. The fully-burdened hourly wage rates used to represent respondent labor

costs are: technical at $84.08, manage ment at $118.25, and clerical at $42.08.

(ii) Estimating Annua lized Capital Costs

The annualized capital costs associated with the information collection requirements will

include the costs to conduct performance test s and startup costs for continuous emissions

monitoring systems (CEMS). The rule will requir e an initial performance test for each EGU.

Exhibit 3 shows the methods used for performance tests and the CEMS that are expected to be

installed.

Exhibit 3. Performance Test Methods and CEMS Equipment by Pollutant

Pollutant Performance Test

Method CEMS

PM EPA Method 5

EPA Method 202

Method 29 (liquid oil

fired EGUs only) New beta gauge PM CEMS

HCl Method 320 New FTIR CEMS

Hg Method 29 New Hg CEMS

HF Method 320 (liquid oil

fired EGUs only) New FTIR CEMS

# 9 The annual total capital (includi ng startup) costs for CEMS that will be used to monitor

PM, Hg, HF and HCl is $49,148,878 per year. The cost s will be incurred for each year of the

three-year period. Note that th ese costs are considered “annualiz ed” as they include the cost

recovery factor costs in th eir individual CEMs costs.

The continuous monitoring costs that are incl uded in this section consist only of those

capital costs that a source incurs as a result of the standard. Some continuous monitoring costs

may not be included in this section. For instance , if a particular industr y typically utilizes a

control device that must have a continuous mon itor (e.g., temperature, pressure drop, etc.) to

function properly, and the recordation of a dditional measurements beyond the minimum are

required by the standard, then there is no capital cost; but, there is a labor cost to record the

additional readings. Such a cost would not app ear in this section, but in the industry burden

Section 6(d) below.

Performance testing is usually conducted by a contractor such th at the cost of the

emissions testing is a capital co st. It is anticipated that existing EGUs will use CEMS for

compliance with the proposed PM, HF, Hg, and HCl emission limits. Initial CEMS testing is

usually conducted by an installati on contractor such that the cost of the emissions testing is a

capital cost. The total costs fo r performance testing were calcula ted for this industry sector.

The number of existing and new sources in this sector combined with the number of tests

required for each type of model plant resulted in a total annualized capital cost of approximately

$49,148,878 per year for CEMS testing over the next three years.

(iii) Estimating Operations and Maintenance (O&M) Costs

The annual operation and maintenance cost s are the ongoing costs to maintain the

monitors and other costs such as photocopying and postage. The tota l annual operations and

maintenance costs for CEMS that will be used to monitor PM, HF, Hg, and HCl is $296,679 per

year.

The continuous monitoring costs that are incl uded in this section consist only of those

O&M costs that a source incurs as a result of the standard. Some continuous monitoring costs

may not be included in this section. For instance , if a particular industr y typically utilizes a

control device that must have a continuous mon itor (e.g., temperature, pressure drop, etc.) to

function properly, and the recordation of a dditional measurements beyond the minimum are

required by the standard, then there is no O&M co st, but there is a labor cost to record the

additional readings. Such a cost would not app ear in this section, but in the industry burden

Section 6(d) below.

(iv) Annualizing Capital Costs

Under this memo, the annualiz ed capital costs are includ ed in the costs of the

performance tests and CEMS (see explanation in Section 6(b)( ii )). The annualized capital costs

total $49,148,878.

(c) Estimating Agency Burden and Cost

Because the information collecti on requirements were developed as an incidental part of

standards development, no costs can be attrib uted to the development of the information

collection requirements. Because reporting and recordkeeping requirements on the part of the

# 10 respondents are required under the NESHAP Gene ral Provisions, no opera tional costs will be

incurred by the Federal Government . Publication and distribution of the information are part of

the Compliance Data System, with the result that no Federal costs can be di rectly attributed to

the ICR. Examination of records to be mainta ined by the respondents will occur incidentally as

part of the periodic inspecti on of sources that is part of EPA's overall compliance and

enforcement program, and, therefore, is not attr ibutable to the ICR. The only costs that the

Federal government will incur are user costs a ssociated with the analysis of the reported

information, as presented in Tables 2a, 2b, and 2c . Exhibit 4 contains a summary of the agency

burden costs and hours detailed in Tables 2a, 2b, and 2c. The average annual Agency costs

during the three years of the ICR is estimated to be $877,188.

Exhibit 4. Summary of the Agency Burden

Year Total Annual Labor Burden (Hours) Total Annual Costs ($)

1 17,965 $ 873,768

2 18,039 $ 877,188

3 18,112 $ 880,608

Total 54,116 $ 2,631,564

3-Year Average 18,039 $ 877,188



# The Agency labor rates are from the Office of Personnel Management (OPM) 2003

General Schedule which excludes locality rates of pay. These rates can be obtained from Salary

Table 2011-GS available on the OPM website

( http://www.opm.gov/oca/11tables/html/gs_h.asp ). The government employee labor rates are

$15.63/hour for clerical (GS-6, St ep 3), $28.88 for technical (GS- 12, Step 1), and $38.92/hr for

management (GS-13, Step 5). These rates represen t salaries plus fringe benefits and do not

include the cost of overhead. An overhead rate of 60 percent is used to account for these costs.

The fully-burdened wage rates used to represen t Agency labor costs ar e: clerical at $25.01;

technical at $46.21, and management at $62.27.

(d) Estimating the Respondent Uni verse and Total Burden and Costs.

Approximately 1,257 existing EGUs would be s ubject to the proposed NESHAP. It is

estimated that no new EGUs will become subject to the regulation during the period of this

information collection.

The total annual number of responses for the monitoring, recordkeeping, and reporting

requirements in 40 CFR part 63 subpart UUUUU is 3,807 for the existing 1,257 EGUs that will

follow the proposed NESHAP requirements.

The total annual labor cost s are $27,000,332. Details upon whic h this estimate is based

appear in Tables 1a, 1b, and 1c.

(e) Bottom Line Burden Hours and Cost Tables

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

attached. The annual public reporting and recordkeeping bur den for this collection of

information is estimated to average 87 hours per response. The total a nnual average burden for

the rule will be 329,605 person hours with a to tal annualized capital /startup cost of $49,148,878.

# 11 (f) Reasons for Change in Burden.

The increase in burden is due to informati on collection activities that would be imposed

by the NESHAP for Coal- and Oil-fired EGUs.

(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 87 hours per response. Bu rden means the total time, effort, or financial

resources expended by persons to generate, maintai n, retain, or disclose or provide information

to or for a Federal agency. This includes th e time needed to review instructions; develop,

acquire, install, and utilize technology and syst ems for the purposes of collecting, validating, and

verifying information, processing and maintain ing information, and disclosing and providing

information; adjust the existing ways to comply with any previously appl icable instructions and

requirements; train personnel to be able to respond to a collecti on of information; search data

sources; complete and review the collection of informa tion; and transmit or otherwise disclose

the information.

An agency may not conduct or sponsor, a nd a person is not required to respond to a

collection of information unless it displays a currently valid OMB control number. The OMB

control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

To comment on the Agency's need for this information, the accuracy of the provided

burden estimates, and any 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- OAR-2009-0234, which is available for online viewing at

www.regulations.gov, or in person viewing at the Air and Radiation Docket and Information

Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution

Avenue, NW, 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, ex cluding legal holidays. The telephone number

for the Reading Room is (202) 566-1744, and th e telephone number for the Air and Radiation

Docket and Information Center is (202) 566-1742. An electronic version of the public docket is

available at www.regulati ons.gov. This site can be used to submit or view public comments,

access the index listing of the contents of the publ ic 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, NW,

Washington, D.C. 20503, Attention: Desk Officer for EPA. Pleas e include the EPA Docket ID

Number EPA-HQ-OAR-2009-0234 in any correspondence.

Part B of the Supporting Statement

This section is not applicable because statistical methods ar e not used in data collection

associated with the final amendments.12Table 1a. Year 1 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric GeneratingUnits (40 CFR part 63, subpart UUUUU)Year 1(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A x B)(D)Respondents/Year(E)TechnicalHours/Year(C x D)(F)ManagerialHours/Year (Ex 0.05)(G) ClericalHours/Year(E x 0.10)(H) Cost/Year1. APPLICATIONS (Not Applicable)2. SURVEY AND STUDIES (Not Applicable)3. ACQUISITION, INSTALLATION, ANDUTILIZATION OF TECHNOLOGY AND SYSTEMSa16 1 16 4196,704.0335.2670.4 $631,5504. REPORT REQUIREMENTSA. Read InstructionsExisting Sources 1 1 1 419419.021.041.9 $39,472New Sources 1 1 1 22.00.10.2 $188B. Required ActivitiesExisting Sources- Initial Performance Test usingM5 and M202 24 1 24 3688,824.0441.2882.4 $831,264Existing Sources- Initial Performance Test usingM29 24 1 24 41910,056.0502.81,005.6 $947,325Existing Sources- Initial Performance Test usingM320 24 1 24 41910,056.0502.81,005.6 $947,325Existing Sources- Initial Performance Test usingM6A 24 1 24 0--- $0Existing Sources - Repeat M5 and 202 performancetest every 2 years 24 1 24 0--- $0Existing Sources - Repeat M29 performance testevery 2 years 24 1 24 0--- $0Existing Sources - Repeat M320 Performance Testevery 2 years 24 1 24 0--- $0Existing Sources - Repeat M6A Performance Testevery 2 years 24 1 24 0--- $0Existing Sources - CEMS Monitoring 0.5 1 0.5 419209.510.521.0 $19,736Existing Sources - CEMS Quarterly Inspections 2 4 8 4193,352.0167.6335.2 $315,775Existing Sources - CEMS Daily Calibration DriftTests 0.3 330 99 41941,481.02,074.14,148.1 $3,907,716Existing Sources - Daily monitoring (CEMS) 0.3 330 99 41941,481.02,074.14,148.1 $3,907,71613Year 1(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A x B)(D)Respondents/Year(E)TechnicalHours/Year(C x D)(F)ManagerialHours/Year (Ex 0.05)(G) ClericalHours/Year(E x 0.10)(H) Cost/YearExisting Sources -- All CEMS must followappropriate performance specifications 0.3 330 99 41941,481.02,074.14,148.1 $3,907,716New Sources- Initial Performance Test using M5and M202 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M29 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M320 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M6A 24 1 24 0--- $0New Sources - Repeat M5 and 202 performancetest every year 24 1 24 0--- $0New Sources - Repeat M29 performance test everyyear 24 1 24 0--- $0New Sources - Repeat M320 Performance Testevery year 24 1 24 0--- $0New Sources - Repeat M6A Performance Testevery year 24 0 0 0--- $0New Sources - CEMS Monitoring 0.5 1 0.5 21.00.10.1 $94New Sources - CEMS Quarterly Inspections 2 4 8 216.00.81.6 $1,507New Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 2198.09.919.8 $18,653New Sources - Daily monitoring (CEMS) 0.3 330 99 2198.09.919.8 $18,653New Sources -- All CEMS must follow appropriateperformance specifications 0.3 330 99 2198.09.919.8 $18,653C. Create Information (Included in 4B)--- $0D. Gather Existing Information(Included in 4E)--- $0E. Write Report--- $0Existing Sources - Notification of Demonstration ofCEMS 2 1 2 419838.041.983.8 $78,944Existing Sources - Report of Performance Test(included in 4B)--- $0Existing Sources - Notification of InitialPerformance Test 2 1 2 419838.041.983.8 $78,944Existing Sources - Quality Assurance ProgramNotification 2 1 2 419838.041.983.8 $78,94414Year 1(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A x B)(D)Respondents/Year(E)TechnicalHours/Year(C x D)(F)ManagerialHours/Year (Ex 0.05)(G) ClericalHours/Year(E x 0.10)(H) Cost/YearExisting Sources - Startup, shutdown, andmalfunction Reportb5 1 5 41.9209.510.521.0 $19,736Existing Sources - Semi-Annual ComplianceReport 24 2 48 41920,112.01,005.62,011.2 $1,894,650Existing Sources - Notification of ComplianceStatus 4 1 4 4191,676.083.8167.6 $157,887Existing Sources - site-specific performanceevaluation test plan 40 1 40 41916,760.0838.01,676.0 $1,578,875Existing Sources - request to use alternativemonitoring procedure 5 1 5 41.9209.510.521.0 $19,736New Sources - Initial notification 2 1 2 24.00.20.4 $377New Sources - Notification of Demonstration ofCEMS 2 1 2 24.00.20.4 $377New Sources - Quality Assurance ProgramNotification 2 1 2 24.00.20.4 $377New Sources - Notification of Initial PerformanceTest 2 1 2 24.00.20.4 $377New Sources - Report of Performance Test(included in 4B)--- $0New Sources - Startup, shutdown, and malfunctionReportb5 1 5 0.21.00.10.1 $94New Sources - Semi-Annual Compliance Report 24 2 48 296.04.89.6 $9,044New Sources - Notification of Compliance Status 4 1 4 28.00.40.8 $754New Sources - site-specific performance evaluationtest plan 40 1 40 280.04.08.0 $7,536New Sources - request to use alternative monitoringprocedure 5 1 5 0.21.00.10.1 $945. RECORDKEEPING REQUIREMENTS--- $0A. Read Instructions (Included in 4A)--- $0B. Plan Activities (Included in 4B)--- $0C. Implement Activities (Included in 4B)--- $0D. Record Data ( Not Applicable)--- $0E. Time to Transmit or Disclose Information--- $015Year 1(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A x B)(D)Respondents/Year(E)TechnicalHours/Year(C x D)(F)ManagerialHours/Year (Ex 0.05)(G) ClericalHours/Year(E x 0.10)(H) Cost/YearExisting Sources - Records of CEMS malfunctions 1.5 1 1.5 419628.531.462.9 $59,208Existing Sources - Records of Startups, Shutdowns,malfunctions, etc 1.5 1 1.5 419628.531.462.9 $59,208Existing Sources - Records of monthly fuel use 1.5 1 1.5 419628.531.462.9 $59,208New Sources - Records of CEMS malfunctions 1.5 1 1.5 23.00.20.3 $283New Sources - Records of Startups, Shutdowns,malfunctions, etc 1.5 1 1.5 23.00.20.3 $283New Sources - Records of monthly fuel use 1.5 1 1.5 23.00.20.3 $283F. Time to Train Personnel 80 2 160 42167,360.03,368.06,736.0 $6,345,645G. Time for Audits (Not Applicable)TOTAL ANNUAL LABORBURDEN AND COST2035 8,453275,75813,78827,576 $25,977,769317,122 HoursANNUALIZED CAPITAL COSTSPerformance tests $ 19,500,300Other Capital Costs of Installation (ODC and Labor) $29,648,578Total annual capital $49,148,878TOTAL ANNUAL COSTS (O&M) $296,679TOTAL ANNUALIZED COSTS (Annualized capital +O&M costs) $49,445,556aThere are 1,257 existing electric generating units. One third of those are assumed to be tested each year.b10% of sources are assumed to submit SSM report each year.16Table 1b. Year 2 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric GeneratingUnits (40 CFR part 63, subpart UUUUU)Year 2(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A xB)(D)Respondents/ Year(E)TechnicalHours/Year (C x D)(F)ManagerialHours/Year (E x0.05)(G)ClericalHours/Year (E x0.10)(H) Cost/Year1. APPLICATIONS (Not Applicable)2. SURVEY AND STUDIES (Not Applicable)3. ACQUISITION, INSTALLATION, AND UTILIZATION OFTECHNOLOGY AND SYSTEMS 16 1 16 4216,736.0336.8673.6 $634,5654. REPORT REQUIREMENTSA. Read InstructionsExisting Sources 1 1 1 421421.021.142.1 $39,660New Sources 1 1 1 22.00.10.2 $188B. Required ActivitiesExisting Sources- Initial Performance Test using M5 and M202 24 1 24 3688,824.0441.2882.4 $831,264Existing Sources- Initial Performance Test usingM29 24 1 24 41910,056.0502.81,005.6 $947,325Existing Sources- Initial Performance Test using M320 24 1 24 41910,056.0502.81,005.6 $947,325Existing Sources- Initial Performance Test using M6A 24 1 24 0--- $0Existing Sources - Repeat M5 and 202 performance test every 2years 24 1 24 0--- $0Existing Sources - Repeat M29 performance test every 2 years 24 1 24 0--- $0Existing Sources - Repeat M320 Performance Test every 2 years 24 1 24 0--- $0Existing Sources - Repeat M6A Performance Test every 2 years 24 1 24 0--- $0Existing Sources - CEMS Monitoring 0.5 1 0.5 421210.510.521.1 $19,830Existing Sources - CEMS Quarterly Inspections 2 4 8 4213,368.0168.4336.8 $317,282Existing Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 42141,679.02,084.04,167.9 $3,926,368Existing Sources - Daily monitoring (CEMS) 0.3 330 99 42141,679.02,084.04,167.9 $3,926,36817Year 2(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A xB)(D)Respondents/ Year(E)TechnicalHours/Year (C x D)(F)ManagerialHours/Year (E x0.05)(G)ClericalHours/Year (E x0.10)(H) Cost/YearExisting Sources -- All CEMS must follow appropriateperformance specifications 0.3 330 99 42141,679.02,084.04,167.9 $3,926,368New Sources- Initial Performance Test using M5 and M202 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M29 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M320 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M6A 24 1 24 0--- $0New Sources - Repeat M5 and 202 performance test every year 24 1 24 248.02.44.8 $4,522New Sources - Repeat M29 performance test every year 24 1 24 248.02.44.8 $4,522New Sources - Repeat M320 Performance Test every year 24 1 24 248.02.44.8 $4,522New Sources - Repeat M6A Performance Test every year 24 0 0 0--- $0New Sources - CEMS Monitoring 0.5 1 0.5 21.00.10.1 $94New Sources - CEMS Quarterly Inspections 2 4 8 216.00.81.6 $1,507New Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 2198.09.919.8 $18,653New Sources - Daily monitoring (CEMS) 0.3 330 99 2198.09.919.8 $18,653New Sources -- All CEMS must follow appropriate performancespecifications 0.3 330 99 2198.09.919.8 $18,653C. Create Information (Included in 4B)--- $0D. Gather Existing Information(Included in 4E)--- $0E. Write Report--- $0Existing Sources - Notification of Demonstration of CEMS 2 1 2 421842.042.184.2 $79,321Existing Sources - Report of Performance Test (included in 4B)--- $0Existing Sources - Notification of Initial Performance Test 2 1 2 421842.042.184.2 $79,321Existing Sources - Quality Assurance Program Notification 2 1 2 421842.042.184.2 $79,32118Year 2(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A xB)(D)Respondents/ Year(E)TechnicalHours/Year (C x D)(F)ManagerialHours/Year (E x0.05)(G)ClericalHours/Year (E x0.10)(H) Cost/YearExisting Sources - Startup, shutdown, and malfunction Report 5 1 5 42.1210.510.521.1 $19,830Existing Sources - Semi-Annual Compliance Report 24 2 48 42120,208.01,010.42,020.8 $1,903,694Existing Sources - Notification of Compliance Status 4 1 4 4211,684.084.2168.4 $158,641Existing Sources - site-specific performance evaluation test plan 40 1 40 42116,840.0842.01,684.0 $1,586,411Existing Sources - request to use alternative monitoring procedure 5 1 5 42.1210.510.521.1 $19,830New Sources - Initial notification 2 1 2 24.00.20.4 $377New Sources - Notification of Demonstration of CEMS 2 1 2 24.00.20.4 $377New Sources - Quality Assurance Program Notification 2 1 2 24.00.20.4 $377New Sources - Notification ofInitial Performance Test 2 1 2 24.00.20.4 $377New Sources - Report of Performance Test (included in 4B)--- $0New Sources - Startup, shutdown, and malfunction Report 5 1 5 0.21.00.10.1 $94New Sources - Semi-Annual Compliance Report 24 2 48 296.04.89.6 $9,044New Sources - Notification of Compliance Status 4 1 4 28.00.40.8 $754New Sources - site-specific performance evaluation test plan 40 1 40 280.04.08.0 $7,536New Sources - request to use alternative monitoring procedure 5 1 5 0.21.00.10.1 $945. RECORDKEEPING REQUIREMENTS--- $0A. Read Instructions (Included in 4A)--- $0B. Plan Activities (Included in 4B)--- $0C. Implement Activities (Included in 4B)--- $0D. Record Data ( Not Applicable)--- $0E. Time to Transmit or Disclose Information--- $019Year 2(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A xB)(D)Respondents/ Year(E)TechnicalHours/Year (C x D)(F)ManagerialHours/Year (E x0.05)(G)ClericalHours/Year (E x0.10)(H) Cost/YearExisting Sources - Records of CEMS malfunctions 1.5 1 1.5 421631.531.663.2 $59,490Existing Sources - Records of Startups, Shutdowns, malfunctions,etc 1.5 1 1.5 421631.531.663.2 $59,490Existing Sources - Records of monthly fuel use 1.5 1 1.5 421631.531.663.2 $59,490New Sources - Records of CEMS malfunctions 1.5 1 1.5 23.00.20.3 $283New Sources - Records of Startups, Shutdowns, malfunctions, etc 1.5 1 1.5 23.00.20.3 $283New Sources - Records of monthly fuel use 1.5 1 1.5 23.00.20.3 $283F. Time to Train Personnel 80 2 160 42167,360.03,368.06,736.0 $6,345,645G. Time for Audits (Not Applicable)TOTAL ANNUAL LABORBURDEN AND COST2035 8,491276,75413,83827,675 $ 26,071,597318,267 HoursANNUALIZED CAPITAL COSTSPerformance tests $19,500,300Other Capital Costs of Installation (ODC and Labor) $ 29,648,578Total annual capital $ 49,148,878TOTAL ANNUAL COSTS (O&M) $296,679TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $49,445,556aThere are 1,257 existing electric generating units. One third of those are assumed to be tested each year.b10% of sources are assumed to submit SSM report each year.20Table 1c. Year 3 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric GeneratingUnits (40 CFR part 63, subpart UUUUU)Year 3(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A xB)(D)Respondents/ Year(E)TechnicalHours/Year (C x D)(F)ManagerialHours/Year (E x 0.05)(G)ClericalHours/Year (E x0.10)(H) Cost/Year1. APPLICATIONS (Not Applicable)2. SURVEY AND STUDIES (Not Applicable)3. ACQUISITION, INSTALLATION, AND UTILIZATION OFTECHNOLOGY AND SYSTEMS 16 1 16 4236,768.0338.4676.8 $637,5794. REPORT REQUIREMENTSA. Read InstructionsExisting Sources 1 1 1 423423.021.242.3 $39,849New Sources 1 1 1 22.00.10.2 $188B. Required ActivitiesExisting Sources- Initial Performance Test using M5 and M202 24 1 24 3688,824.0441.2882.4 $831,264Existing Sources- Initial Performance Test usingM29 24 1 24 41910,056.0502.81,005.6 $947,325Existing Sources- Initial Performance Test using M320 24 1 24 41910,056.0502.81,005.6 $947,325Existing Sources- Initial Performance Test using M6A 24 1 24 0--- $0Existing Sources - Repeat M5 and 202 performance test every 2years 24 1 24 3688,824.0441.2882.4 $831,264Existing Sources - Repeat M29 performance test every 2 years 24 1 24 41910,056.0502.81,005.6 $947,325Existing Sources - Repeat M320 Performance Test every 2 years 24 1 24 41910,056.0502.81,005.6 $947,325Existing Sources - Repeat M6A Performance Test every 2 years 24 1 24 0--- $0Existing Sources - CEMS Monitoring 0.5 1 0.5 423211.510.621.2 $19,924Existing Sources - CEMS Quarterly Inspections 2 4 8 4233,384.0169.2338.4 $318,790Existing Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 42341,877.02,093.94,187.7 $3,945,021Existing Sources - Daily monitoring (CEMS) 0.3 330 99 42341,877.02,093.94,187.7 $3,945,02121Year 3(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A xB)(D)Respondents/ Year(E)TechnicalHours/Year (C x D)(F)ManagerialHours/Year (E x 0.05)(G)ClericalHours/Year (E x0.10)(H) Cost/YearExisting Sources -- All CEMS must follow appropriateperformance specifications 0.3 330 99 42341,877.02,093.94,187.7 $3,945,021New Sources- Initial Performance Test using M5 and M202 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M29 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M320 24 1 24 248.02.44.8 $4,522New Sources- Initial Performance Test using M6A 24 1 24 0--- $0New Sources - Repeat M5 and 202 performance test every year 24 1 24 496.04.89.6 $9,044New Sources - Repeat M29 performance test every year 24 1 24 496.04.89.6 $9,044New Sources - Repeat M320 Performance Test every year 24 1 24 496.04.89.6 $9,044New Sources - Repeat M6A Performance Test every year 24 0 0 0--- $0New Sources - CEMS Monitoring 0.5 1 0.5 21.00.10.1 $94New Sources - CEMS Quarterly Inspections 2 4 8 216.00.81.6 $1,507New Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 2198.09.919.8 $18,653New Sources - Daily monitoring (CEMS) 0.3 330 99 2198.09.919.8 $18,653New Sources -- All CEMS must follow appropriate performancespecifications 0.3 330 99 2198.09.919.8 $18,653C. Create Information (Included in 4B)--- $0D. Gather Existing Information(Included in 4E)--- $0E. Write Report--- $0Existing Sources - Notification of Demonstration of CEMS 2 1 2 423846.042.384.6 $79,697Existing Sources - Report of Performance Test (included in 4B)--- $0Existing Sources - Notification of Initial Performance Test 2 1 2 423846.042.384.6 $79,697Existing Sources - Quality Assurance Program Notification 2 1 2 423846.042.384.6 $79,69722Year 3(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A xB)(D)Respondents/ Year(E)TechnicalHours/Year (C x D)(F)ManagerialHours/Year (E x 0.05)(G)ClericalHours/Year (E x0.10)(H) Cost/YearExisting Sources - Startup, shutdown, and malfunction Report 5 1 5 42.3211.510.621.2 $19,924Existing Sources - Semi-Annual Compliance Report 24 2 48 42320,304.01,015.22,030.4 $1,912,737Existing Sources - Notification of Compliance Status 4 1 4 4231,692.084.6169.2 $159,395Existing Sources - site-specific performance evaluation test plan 40 1 40 42316,920.0846.01,692.0 $1,593,948Existing Sources - request to use alternative monitoring procedure 5 1 5 42.3211.510.621.2 $19,924New Sources - Initial notification 2 1 2 24.00.20.4 $377New Sources - Notification of Demonstration of CEMS 2 1 2 24.00.20.4 $377New Sources - Quality Assurance Program Notification 2 1 2 24.00.20.4 $377New Sources - Notification ofInitial Performance Test 2 1 2 24.00.20.4 $377New Sources - Report of Performance Test (included in 4B)--- $0New Sources - Startup, shutdown, and malfunction Report 5 1 5 0.21.00.10.1 $94New Sources - Semi-Annual Compliance Report 24 2 48 296.04.89.6 $9,044New Sources - Notification of Compliance Status 4 1 4 28.00.40.8 $754New Sources - site-specific performance evaluation test plan 40 1 40 280.04.08.0 $7,536New Sources - request to use alternative monitoring procedure 5 1 5 0.21.00.10.1 $945. RECORDKEEPING REQUIREMENTS--- $0A. Read Instructions (Included in 4A)--- $0B. Plan Activities (Included in 4B)--- $0C. Implement Activities (Included in 4B)--- $0D. Record Data ( Not Applicable)--- $0E. Time to Transmit or Disclose Information--- $023Year 3(A) HoursperOccurrence(B)Occurrences/Respondent/Year(C) Hours/Respondent/Year (A xB)(D)Respondents/ Year(E)TechnicalHours/Year (C x D)(F)ManagerialHours/Year (E x 0.05)(G)ClericalHours/Year (E x0.10)(H) Cost/YearExisting Sources - Records of CEMS malfunctions 1.5 1 1.5 423634.531.763.5 $59,773Existing Sources - Records of Startups, Shutdowns, malfunctions,etc 1.5 1 1.5 423634.531.763.5 $59,773Existing Sources - Records of monthly fuel use 1.5 1 1.5 423634.531.763.5 $59,773New Sources - Records of CEMS malfunctions 1.5 1 1.5 23.00.20.3 $283New Sources - Records of Startups, Shutdowns, malfunctions, etc 1.5 1 1.5 23.00.20.3 $283New Sources - Records of monthly fuel use 1.5 1 1.5 23.00.20.3 $283F. Time to Train Personnel 80 2 160 42568,000.03,400.06,800.0 $6,405,937G. Time for Audits (Not Applicable)TOTAL ANNUAL LABORBURDEN AND COST2035 9,739307,32615,36630,733 $28,951,630353,425 HoursANNUALIZED CAPITAL COSTSPerformance tests $ 19,500,300Other Capital Costs of Installation (ODC and Labor) $ 29,648,578Total annual capital $ 49,148,878TOTAL ANNUAL COSTS (O&M) $296,679TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $49,445,556aThere are 1,257 existing electric generating units. One third of those are assumed to be tested each year.b10% of sources are assumed to submit SSM report each year.24Table 2a. Year 1 Agency Burden and Cost, NESHAP for Electric Generating Units (40CFR part 63, subpart UUUUU)Activity -- Year 1(A) EPAHours/Occurrence(B)Occurrences/Plant/Year(C) EPAHours/Plant/Year(A x B)(D)Plants/Year(E) EPATechnicalHours/ Year(C x D)(F) EPAManagerialHours/Year(G) EPAClericalHours/Year (H) Cost, $Observe Initial Performance Tests 24 1 24 84.13 2019.2 100.96 20.192 $ 100,095Observe Repeat Performance Tests 24 0.2 4.8 84.13 403.84 20.192 4.0384 $ 20,019Review Notification of Demonstration of CEMS 0.5 1 0.5 421.00210.5 10.525 2.105 $ 10,435Review Quality Assurance Program Notification 0.5 1 0.5 421.00 210.5 10.525 2.105 $ 10,435Review Startup, shutdown, and malfunction Report 8 1 8 421.00 3368 168.4 33.68 $ 166,957Review Notification of Compliance Status0.5 1 0.5 421.00 210.5 10.525 2.105 $ 10,435Review requests to use alternative monitoring procedure 0.5 1 0.5 421.00 210.5 10.525 2.105 $ 10,435Review Initial Notifications 0.5 1 0.5 2.00 1 0.05 0.01 $ 50Review Notification of performance test0.5 1 0.5 421.00 210.5 10.525 2.105 $ 10,435Review Test/CEMS Results 8 1 8 421.00 3368 168.4 33.68 $ 166,957Review site specific performance evaluation test plan 8 1 8 421.00 3368 168.4 33.68 $ 166,957Review Semi-Annual reports 8 1 8 421.00 3368 168.4 33.68 $ 166,957Total Annual Hours 16,949 847.427 169.4854 $ 840,16817,965.45 hoursTravel Expenses $ 33,600$ 873,768EPA Officials are assumed to attend 20% of performance testsTravel Expenses = (1 person x 84 plants/year x 3 days/plantx $50 per diem) + ($250 round trip/plant x 84 plants/year) = $33,600/yearAssume visit 84 plants per year25Table 2b. Year 2 Agency Burden and Cost, NESHAP forElectric Generating Units (40 CFR part 63, subpart UUUUU)Activity -- Year 2(A) EPAHours/Occurrence(B)Occurrences/Plant/Year(C) EPAHours/Plant/Year(A x B)(D)Plants/Year(E) EPATechnicalHours/ Year(C x D)(F) EPAManagerialHours/Year(G) EPAClericalHours/Year (H) Cost, $Observe Initial Performance Tests 24 1 24 84.13 2019.2 100.96 20.192 $ 100,095Observe Repeat Performance Tests 24 0.2 4.8 84.13 403.84 20.192 4.0384 $ 20,019Review Notification of Demonstration of CEMS 0.5 1 0.5 423.00211.5 10.575 2.115 $ 10,484Review Quality Assurance Program Notification 0.5 1 0.5 423.00 211.5 10.575 2.115 $ 10,484Review Startup, shutdown, and malfunction Report 8 1 8 423.00 3384 169.2 33.84 $ 167,751Review Notification of Compliance Status0.5 1 0.5 423.00 211.5 10.575 2.115 $ 10,484Review requests to use alternative monitoring procedure 0.5 1 0.5 423.00 211.5 10.575 2.115 $ 10,484Review Initial Notifications 0.5 1 0.5 2.00 1 0.05 0.01 $ 50Review Notification of performance test0.5 1 0.5 423.00 211.5 10.575 2.115 $ 10,484Review Test/CEMS Results 8 1 8 423.00 3384 169.2 33.84 $ 167,751Review site specific performance evaluation test plan 8 1 8 423.00 3384 169.2 33.84 $ 167,751Review Semi-Annual reports 8 1 8 423.00 3384 169.2 33.84 $ 167,751Total Annual Hours 17,018 850.877 170.1754 $ 843,58818,038.59 hoursTravel Expenses $ 33,600$ 877,188EPA Officials are assumed to attend 20% of performance testsTravel Expenses = (1 person x 84 plants/year x 3 days/plantx $50 per diem) + ($250 round trip/plant x 84 plants/year) = $33,600/yearAssume visit 84 plants per year26Table 2c. Year 3 Agency Burden and Cost, NESHAP forElectric Generating Units (40 CFR part 63, subpart UUUUU)Activity -- Year 3(A) EPAHours/Occurrence(B)Occurrences/ Plant/Year(C) EPAHours/Plant/Year (A x B)(D)Plants/ Year(E) EPATechnicalHours/ Year(C x D)(F) EPAManagerialHours/Year(G) EPAClericalHours/Year (H) Cost, $Observe Initial Performance Tests 24 1 24 84.13 2019.2 100.96 20.192 $ 100,095Observe Repeat Performance Tests 24 0.2 4.8 84.13 403.84 20.192 4.0384 $ 20,019Review Notification of Demonstration of CEMS 0.5 1 0.5 425.00212.5 10.625 2.125 $ 10,534Review Quality Assurance Program Notification 0.5 1 0.5 425.00 212.5 10.625 2.125 $ 10,534Review Startup, shutdown, and malfunction Report 8 1 8 425.00 3400 170 34 $ 168,544Review Notification of Compliance Status0.5 1 0.5 425.00 212.5 10.625 2.125 $ 10,534Review requests to use alternative monitoring procedure 0.5 1 0.5 425.00 212.5 10.625 2.125 $ 10,534Review Initial Notifications 0.5 1 0.5 2.001 0.05 0.01$50Review Notification of performance test0.5 1 0.5 425.00 212.5 10.625 2.125 $ 10,534Review Test/CEMS Results 8 1 8 425.00 3400 170 34 $ 168,544Review site specific performance evaluation test plan 8 1 8 425.00 3400 170 34 $ 168,544Review Semi-Annual reports 8 1 8 425.00 3400 170 34 $ 168,544Total Annual Hours17,087 854.327 170.8654 $ 847,00818,111.73 hoursTravel Expenses $ 33,600$ 880,608EPA Officials are assumed to attend 20% of performancetestsTravel Expenses = (1 person x 84 plants/year x 3 days/plantx $50 per diem) + ($250 round trip/plant x 84 plants/year) = $33,600/yearAssume visit 84 plants per year