1 

SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY 

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

Electric Utility Steam Generating Units and Standards of Performance for Fossil-FuelFired Electric Utility, Industrial-Commercial-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 information collection requirements for the Clean Air 

Mercury Rule (CAMR) in 2005. However, the 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. Circuit 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 information collection was developed explicitly to 

determine compliance with CAMR, it was no longer 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 (EGUs or Utility Units) under Clean Air Act (CAA) section 112(d) 

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

under CAA section 111(b). 

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

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

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

section 112(d) (see 65 FR 79825). On January 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 alternative, proposed to remove EGUs from the CAA section 112(c) list 

based on a finding that it was neither 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 oil-fired EGUs and removed such units from the 

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

15994). EPA never finalized the proposed CAA section 112(d) standard. The removal of EGUs 
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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 section 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 reflect the application of the maximum achievable 

control technology (MACT) consistent 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 standards require initial notifications, performance tests, and 

periodic reports. These notifications, reports, and records are essential in determining 

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

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

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

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

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

regional office. 

Potential respondents are owners or operators of EGUs. The proposed NESHAP would 

establish emission limits for total particulate matter (PM), hydrogen chloride (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 demonstrate 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 Regulation 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 evaluation test plan 63.10031

Recordkeeping 

Existing Sources - Records of CEMS malfunctions 63.10032

Existing Sources - Records of Startups, Shutdowns, 63.10032
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malfunctions, etc 

Existing Sources - Records of monthly fuel use 63.10032

EPA estimates that approximately 1,257 existing 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 matter (PM), sulfur dioxide (SO2), and nitrogen oxides (NOX) 

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 amendments. On September 2, 2009, EPA was granted a 

voluntary remand without vacatur of the 2006 amendments. 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 fossil 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 reporting 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 requirements 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 subject to the standards, and identify new or 

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

achieved on a continuous basis. These recordkeeping 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. Based 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 same information requested under this ICR 

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

Electric Utility, Industrial-Commercial-Institutional, and Small Industrial-CommercialInstitutional Steam Generating Units. In the event that certain reports required by State or local 

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

submitted to the State or local agency can be provided to the Administrator in lieu of the 
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information that would be required in the semi-annual compliance report. Therefore, no 

duplication exists. 

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

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

(c) Consultations 

EPA met with 10 national organizations representing State and local elected officials to 

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

State/local governments. EPA also consulted with Tribal officials early 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 were 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 compliance 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 which a claim of confidentiality is made will 

be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, part 2, subpart 

B–Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 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 will be subject to the monitoring, recordkeeping, and reporting 

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

Transmission and Distribution. There are no respondents under the proposed NSPS amendments 

because no new EGUs are projected to be built. 
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(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 proposed NESHAP are introduced in section 

6(a). 

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

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

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

alternatives and whether the proposed standards adequately take into consideration the 

incremental effects in terms of emission reductions, energy, and other effects of these 

alternatives. EPA will consider the available information in developing the final rule. 

The costs, environmental, energy, and economic impacts are typically expressed as 

incremental differences between the 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 requirements of the Clean Air Transport Rule will 

likely elect to minimize operating costs by operating at SO2 and NOX emission rates lower than 

what is required by the existing NSPS. Finally, the EGU NESHAP PM and SO2 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 those amendments. In addition, no 

new EGUs are projected to be built during the 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 subject 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 cycle 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 the option of submitting to an EPA electronic 

database an electronic copy of their required stack test. This electronic database should become 

available as of December 31, 2011. Currently, sources are using monitoring equipment that 
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provides automated parameter data (e.g., continuous opacity monitoring). Although personnel at 

the affected facility must evaluate these data, this type of monitoring equipment has significantly 

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

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

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

percent of the respondents currently use electronic reporting. 

5. The Information Collected: Agency Activities, 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 repeat performance tests, if necessary. 

Review notifications and reports, 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 Methodology and Management 

Following notification of startup, the reviewing authority might inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The 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 entered into the AIRS Facility Subsystem (AFS) 

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

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

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

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

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

analyze the data. 

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

years. 

(c) Small Entity Flexibility 

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

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

representatives of the small entities that potentially would be subject to the requirements of the 

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

potential rulemaking approaches and potential options to decrease the impact of the rulemaking 

on their EGUs. Outreach materials were distributed to the SERs; these materials included 
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background, project history, CAA section 112 overview, constraints on rulemaking, affected 

facilities, data, rulemaking options under consideration, potential control technologies and 

estimated costs, applicable small entity definitions, small entities potentially subject to 

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

proposed rule to discuss the outreach materials and receive feedback on the approaches and 

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

SERs following the meeting in response to discussions at the meeting and the questions posed to 

the SERs by the Agency. The SERs were specifically 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 collection activity within this request is 

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

Requirements, NESHAP for Coal- and Oil-fired 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 computation 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 hours and costs detailed in Tables 1a, 1b, and 1c. 

Exhibit 2. Summary of Respondent Burden 

Year Total Annual Labor Burden (hours) 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 the Paperwork Reduction Act. Where appropriate, 

specific tasks and major assumptions have been identified; responses to this information 

collection are mandatory. 

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

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

(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 based on Agency studies and background documents 

from the development of the regulation, Agency knowledge, and experience with the NESHAP 

program, the previously approved ICR, and any comments received. 
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(b) Estimating Respondent Costs 

Respondent costs are divided into four categories. These categories include labor costs, 

capital costs (includes startup costs), operations and maintenance 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 factor 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 hourly 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 "Architecture and Engineering Occupations: Environmental 

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

from "Management occupations: Engineering Managers" with a total compensation of 

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

occupations” with a total compensation of $20.04/hour. These rates represent 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, management at $118.25, and clerical at $42.08. 

(ii) Estimating Annualized Capital Costs 

The annualized capital costs associated with the information collection requirements will 

include the costs to conduct performance tests and startup costs for continuous emissions 

monitoring systems (CEMS). The rule will require 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 
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The annual total capital (including startup) costs for CEMS that will be used to monitor 

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

three-year period. Note that these costs are considered “annualized” as they include the cost 

recovery factor costs in their individual CEMs costs. 

The continuous monitoring costs that are included 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 industry typically utilizes a 

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

function properly, and the recordation of additional 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 appear in this section, but in the industry burden 

Section 6(d) below. 

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

emissions testing is a capital cost. 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 installation contractor such that the cost of the emissions testing is a 

capital cost. The total costs for performance testing were calculated 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 costs are the ongoing costs to maintain the 

monitors and other costs such as photocopying and postage. The total 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 included 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 industry typically utilizes a 

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

function properly, and the recordation of additional measurements beyond the minimum are 

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

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

Section 6(d) below. 

(iv) Annualizing Capital Costs 

Under this memo, the annualized capital costs are included 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 collection requirements were developed as an incidental part of 

standards development, no costs can be attributed to the development of the information 

collection requirements. Because reporting and recordkeeping requirements on the part of the 
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respondents are required under the NESHAP General Provisions, no operational costs will be 

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

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

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

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

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

Federal government will incur are user costs associated 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, Step 3), $28.88 for technical (GS-12, Step 1), and $38.92/hr for 

management (GS-13, Step 5). These rates represent 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 represent Agency labor costs are: clerical at $25.01; 

technical at $46.21, and management at $62.27. 

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

Approximately 1,257 existing EGUs would be subject 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 costs are $27,000,332. Details upon which 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 burden for this collection of 

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

the rule will be 329,605 person hours with a total annualized capital/startup cost of $49,148,878. 
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(f) Reasons for Change in Burden. 

The increase in burden is due to information 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. Burden means the total time, effort, or financial 

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

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

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

verifying information, processing and maintaining information, and disclosing and providing 

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

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

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

the information. 

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

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

control numbers for EPA’s regulations 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, excluding legal holidays. The telephone number 

for the Reading Room is (202) 566-1744, and the 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.regulations.gov. This site can be used to submit or view public comments, 

access the index listing of the contents of the public docket, and to access those documents in the 

public docket that are available electronically. When in the system, select “search,” then key in 

the Docket ID Number identified above. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 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 are not used in data collection 

associated with the final amendments. 
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Table 1a. Year 1 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Elec

Units (40 CFR part 63, subpart UUUUU) 

Year 1 (A) Hours 

per 

Occurrence 

(B) 

Occurrences/ 

Respondent/Year 

(C) Hours/ 

Respondent/ 

Year (A x B) 

(D) 

Respondents/ 

Year 

(E) 

Technical 

Hours/Year 

(C x D) 

(F) 

Managerial 

Hours/Year (E 

x 0.05) 

1. APPLICATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS a 16 1 16 419 6,704.0 335.2 4. REPORT REQUIREMENTS  A. Read Instructions  Existing Sources 1 1 1 419 419.0 21.0  New Sources 1 1 1 2 2.0 0.1  B. Required Activities 

Existing Sources- Initial Performance Test using M5 and M202 24 1 24 368 8,824.0 441.2 Existing Sources- Initial Performance Test using M29 24 1 24 419 10,056.0 502.8 Existing Sources- Initial Performance Test using M320 24 1 24 419 10,056.0 502.8 Existing Sources- Initial Performance Test using M6A 24 1 24 0 - - Existing Sources - Repeat M5 and 202 performance test every 2 years 24 1 24 0 - - Existing Sources - Repeat M29 performance test every 2 years 24 1 24 0 - - Existing Sources - Repeat M320 Performance Test every 2 years 24 1 24 0 - - Existing Sources - Repeat M6A Performance Test every 2 years 24 1 24 0 - - 

 Existing Sources - CEMS Monitoring 0.5 1 0.5 419 209.5 10.5  Existing Sources - CEMS Quarterly Inspections 2 4 8 419 3,352.0 167.6 

Existing Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 419 41,481.0 2,074.1 

 Existing Sources - Daily monitoring (CEMS) 0.3 330 99 419 41,481.0 2,074.1 
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Year 1 (A) Hours 

per 

Occurrence 

(B) 

Occurrences/ 

Respondent/Year 

(C) Hours/ 

Respondent/ 

Year (A x B) 

(D) 

Respondents/ 

Year 

(E) 

Technical 

Hours/Year 

(C x D) 

(F) 

Managerial 

Hours/Year (E 

x 0.05) 

Existing Sources -- All CEMS must follow appropriate performance specifications 0.3 330 99 419 41,481.0 2,074.1 New Sources- Initial Performance Test using M5 and M202 24 1 24 2 48.0 2.4 

 New Sources- Initial Performance Test using M29 24 1 24 2 48.0 2.4  New Sources- Initial Performance Test using M320 24 1 24 2 48.0 2.4  New Sources- Initial Performance Test using M6A 24 1 24 0 - - 

New Sources - Repeat M5 and 202 performance test every year 24 1 24 0 - - New Sources - Repeat M29 performance test every year 24 1 24 0 - - New Sources - Repeat M320 Performance Test every year 24 1 24 0 - - New Sources - Repeat M6A Performance Test every year 24 0 0 0 - - 

 New Sources - CEMS Monitoring 0.5 1 0.5 2 1.0 0.1  New Sources - CEMS Quarterly Inspections 2 4 8 2 16.0 0.8  New Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 2 198.0 9.9  New Sources - Daily monitoring (CEMS) 0.3 330 99 2 198.0 9.9 

New Sources -- All CEMS must follow appropriate performance specifications 0.3 330 99 2 198.0 9.9 

 C. Create Information (Included in 4B) - -  D. Gather Existing Information (Included in 4E) - -  E. Write Report - - 

Existing Sources - Notification of Demonstration of CEMS 2 1 2 419 838.0 41.9 Existing Sources - Report of Performance Test (included in 4B) - - Existing Sources - Notification of Initial Performance Test 2 1 2 419 838.0 41.9 Existing Sources - Quality Assurance Program Notification 2 1 2 419 838.0 41.9 
14 

Year 1 (A) Hours 

per 

Occurrence 

(B) 

Occurrences/ 

Respondent/Year 

(C) Hours/ 

Respondent/ 

Year (A x B) 

(D) 

Respondents/ 

Year 

(E) 

Technical 

Hours/Year 

(C x D) 

(F) 

Managerial 

Hours/Year (E 

x 0.05) 

Existing Sources - Startup, shutdown, and malfunction Report b 5 1 5 41.9 209.5 10.5 Existing Sources - Semi-Annual Compliance Report 24 2 48 419 20,112.0 1,005.6 Existing Sources - Notification of Compliance Status 4 1 4 419 1,676.0 83.8 Existing Sources - site-specific performance evaluation test plan 40 1 40 419 16,760.0 838.0 Existing Sources - request to use alternative monitoring procedure 5 1 5 41.9 209.5 10.5 

 New Sources - Initial notification 2 1 2 2 4.0 0.2 

New Sources - Notification of Demonstration of CEMS 2 1 2 2 4.0 0.2 New Sources - Quality Assurance Program Notification 2 1 2 2 4.0 0.2 New Sources - Notification of Initial Performance Test 2 1 2 2 4.0 0.2 New Sources - Report of Performance Test (included in 4B) - - New Sources - Startup, shutdown, and malfunction Reportb 5 1 5 0.2 1.0 0.1 

 New Sources - Semi-Annual Compliance Report 24 2 48 2 96.0 4.8  New Sources - Notification of Compliance Status 4 1 4 2 8.0 0.4 

New Sources - site-specific performance evaluation test plan 40 1 40 2 80.0 4.0 New Sources - request to use alternative monitoring procedure 5 1 5 0.2 1.0 0.1 

5. RECORDKEEPING REQUIREMENTS - -  A. Read Instructions (Included in 4A) - -  B. Plan Activities (Included in 4B) - -  C. Implement Activities (Included in 4B) - -  D. Record Data ( Not Applicable) - -  E. Time to Transmit or Disclose Information - - 
15 

Year 1 (A) Hours 

per 

Occurrence 

(B) 

Occurrences/ 

Respondent/Year 

(C) Hours/ 

Respondent/ 

Year (A x B) 

(D) 

Respondents/ 

Year 

(E) 

Technical 

Hours/Year 

(C x D) 

(F) 

Managerial 

Hours/Year (E 

x 0.05) 

 Existing Sources - Records of CEMS malfunctions 1.5 1 1.5 419 628.5 31.4 

Existing Sources - Records of Startups, Shutdowns, malfunctions, etc 1.5 1 1.5 419 628.5 31.4 

 Existing Sources - Records of monthly fuel use 1.5 1 1.5 419 628.5 31.4  New Sources - Records of CEMS malfunctions 1.5 1 1.5 2 3.0 0.2 

New Sources - Records of Startups, Shutdowns, malfunctions, etc 1.5 1 1.5 2 3.0 0.2 

 New Sources - Records of monthly fuel use 1.5 1 1.5 2 3.0 0.2  F. Time to Train Personnel 80 2 160 421 67,360.0 3,368.0  G. Time for Audits (Not Applicable) TOTAL ANNUAL LABOR BURDEN AND COST 2035 8,453 275,758 13,788 

317,122 

ANNUALIZED CAPITAL COSTS  Performance tests  Other Capital Costs of Installation (ODC and Labor)  Total annual capital TOTAL ANNUAL COSTS (O&M) TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) a There are 1,257 existing electric generating units. One third of those are assumed to be tested each year. b 10% of sources are assumed to submit SSM report each year.
16 

Table 1b. Year 2 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Elec

Units (40 CFR part 63, subpart UUUUU) 

Year 2 (A) Hours 

per 

Occurrence 

(B) 

Occurrences/ 

Respondent/Yea

r 

(C) Hours/ 

Respondent

/ 

Year (A x 

B) 

(D) 

Respondents

/ Year 

(E) 

Technical 

Hours/Yea

r (C x D) 

(F) 

Manager

Hours/Y

r (E x 

0.05) 

1. APPLICATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS 16 1 16 421 6,736.0 336.8 4. REPORT REQUIREMENTS  A. Read Instructions  Existing Sources 1 1 1 421 421.0 21.1  New Sources 1 1 1 2 2.0 0.1  B. Required Activities  Existing Sources- Initial Performance Test using M5 and M202 24 1 24 368 8,824.0 441.2  Existing Sources- Initial Performance Test using M29 24 1 24 419 10,056.0 502.8  Existing Sources- Initial Performance Test using M320 24 1 24 419 10,056.0 502.8  Existing Sources- Initial Performance Test using M6A 24 1 24 0 - - 

Existing Sources - Repeat M5 and 202 performance test every 2 years 24 1 24 0 - - 

 Existing Sources - Repeat M29 performance test every 2 years 24 1 24 0 - -  Existing Sources - Repeat M320 Performance Test every 2 years 24 1 24 0 - -  Existing Sources - Repeat M6A Performance Test every 2 years 24 1 24 0 - -  Existing Sources - CEMS Monitoring 0.5 1 0.5 421 210.5 10.5  Existing Sources - CEMS Quarterly Inspections 2 4 8 421 3,368.0 168.4  Existing Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 421 41,679.0 2,084.0  Existing Sources - Daily monitoring (CEMS) 0.3 330 99 421 41,679.0 2,084.0 
17 

Year 2 (A) Hours 

per 

Occurrence 

(B) 

Occurrences/ 

Respondent/Yea

r 

(C) Hours/ 

Respondent

/ 

Year (A x 

B) 

(D) 

Respondents

/ Year 

(E) 

Technical 

Hours/Yea

r (C x D) 

(F) 

Manager

Hours/Y

r (E x 

0.05) 

Existing Sources -- All CEMS must follow appropriate performance specifications 0.3 330 99 421 41,679.0 2,084.0 

 New Sources- Initial Performance Test using M5 and M202 24 1 24 2 48.0 2.4  New Sources- Initial Performance Test using M29 24 1 24 2 48.0 2.4  New Sources- Initial Performance Test using M320 24 1 24 2 48.0 2.4  New Sources- Initial Performance Test using M6A 24 1 24 0 - -  New Sources - Repeat M5 and 202 performance test every year 24 1 24 2 48.0 2.4  New Sources - Repeat M29 performance test every year 24 1 24 2 48.0 2.4  New Sources - Repeat M320 Performance Test every year 24 1 24 2 48.0 2.4  New Sources - Repeat M6A Performance Test every year 24 0 0 0 - -  New Sources - CEMS Monitoring 0.5 1 0.5 2 1.0 0.1  New Sources - CEMS Quarterly Inspections 2 4 8 2 16.0 0.8  New Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 2 198.0 9.9  New Sources - Daily monitoring (CEMS) 0.3 330 99 2 198.0 9.9 

New Sources -- All CEMS must follow appropriate performance specifications 0.3 330 99 2 198.0 9.9 

 C. Create Information (Included in 4B) - -  D. Gather Existing Information (Included in 4E) - -  E. Write Report - -  Existing Sources - Notification of Demonstration of CEMS 2 1 2 421 842.0 42.1  Existing Sources - Report of Performance Test (included in 4B) - -  Existing Sources - Notification of Initial Performance Test 2 1 2 421 842.0 42.1  Existing Sources - Quality Assurance Program Notification 2 1 2 421 842.0 42.1 
18 

Year 2 (A) Hours 

per 

Occurrence 

(B) 

Occurrences/ 

Respondent/Yea

r 

(C) Hours/ 

Respondent

/ 

Year (A x 

B) 

(D) 

Respondents

/ Year 

(E) 

Technical 

Hours/Yea

r (C x D) 

(F) 

Manager

Hours/Y

r (E x 

0.05) 

 Existing Sources - Startup, shutdown, and malfunction Report 5 1 5 42.1 210.5 10.5  Existing Sources - Semi-Annual Compliance Report 24 2 48 421 20,208.0 1,010.4  Existing Sources - Notification of Compliance Status 4 1 4 421 1,684.0 84.2  Existing Sources - site-specific performance evaluation test plan 40 1 40 421 16,840.0 842.0  Existing Sources - request to use alternative monitoring procedure 5 1 5 42.1 210.5 10.5  New Sources - Initial notification 2 1 2 2 4.0 0.2  New Sources - Notification of Demonstration of CEMS 2 1 2 2 4.0 0.2  New Sources - Quality Assurance Program Notification 2 1 2 2 4.0 0.2  New Sources - Notification of Initial Performance Test 2 1 2 2 4.0 0.2  New Sources - Report of Performance Test (included in 4B) - -  New Sources - Startup, shutdown, and malfunction Report 5 1 5 0.2 1.0 0.1  New Sources - Semi-Annual Compliance Report 24 2 48 2 96.0 4.8  New Sources - Notification of Compliance Status 4 1 4 2 8.0 0.4  New Sources - site-specific performance evaluation test plan 40 1 40 2 80.0 4.0  New Sources - request to use alternative monitoring procedure 5 1 5 0.2 1.0 0.1 5. RECORDKEEPING REQUIREMENTS - -  A. Read Instructions (Included in 4A) - -  B. Plan Activities (Included in 4B) - -  C. Implement Activities (Included in 4B) - -  D. Record Data ( Not Applicable) - -  E. Time to Transmit or Disclose Information - - 
19 

Year 2 (A) Hours 

per 

Occurrence 

(B) 

Occurrences/ 

Respondent/Yea

r 

(C) Hours/ 

Respondent

/ 

Year (A x 

B) 

(D) 

Respondents

/ Year 

(E) 

Technical 

Hours/Yea

r (C x D) 

(F) 

Manager

Hours/Y

r (E x 

0.05) 

 Existing Sources - Records of CEMS malfunctions 1.5 1 1.5 421 631.5 31.6 

Existing Sources - Records of Startups, Shutdowns, malfunctions, etc 1.5 1 1.5 421 631.5 31.6 

 Existing Sources - Records of monthly fuel use 1.5 1 1.5 421 631.5 31.6  New Sources - Records of CEMS malfunctions 1.5 1 1.5 2 3.0 0.2  New Sources - Records of Startups, Shutdowns, malfunctions, etc 1.5 1 1.5 2 3.0 0.2  New Sources - Records of monthly fuel use 1.5 1 1.5 2 3.0 0.2  F. Time to Train Personnel 80 2 160 421 67,360.0 3,368.0  G. Time for Audits (Not Applicable) TOTAL ANNUAL LABOR BURDEN AND COST 2035 8,491 276,754 13,838 

318,267 

ANNUALIZED CAPITAL COSTS  Performance tests  Other Capital Costs of Installation (ODC and Labor)  Total annual capital TOTAL ANNUAL COSTS (O&M) TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) a There are 1,257 existing electric generating units. One third of those are assumed to be tested each year. b 10% of sources are assumed to submit SSM report each year.
20 

Table 1c. Year 3 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Elec

Units (40 CFR part 63, subpart UUUUU) 

Year 3 

(A) Hours 

per 

Occurrenc

e 

(B) 

Occurrences/ 

Respondent/Yea

r 

(C) Hours/ 

Respondent

/ 

Year (A x 

B) 

(D) 

Respondents

/ Year 

(E) 

Technical 

Hours/Yea

r (C x D) 

(F) 

Manage

Hours/

r (E x 0

1. APPLICATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS 16 1 16 423 6,768.0 338.4 4. REPORT REQUIREMENTS  A. Read Instructions  Existing Sources 1 1 1 423 423.0 21.2  New Sources 1 1 1 2 2.0 0.1  B. Required Activities  Existing Sources- Initial Performance Test using M5 and M202 24 1 24 368 8,824.0 441.2  Existing Sources- Initial Performance Test using M29 24 1 24 419 10,056.0 502.8  Existing Sources- Initial Performance Test using M320 24 1 24 419 10,056.0 502.8  Existing Sources- Initial Performance Test using M6A 24 1 24 0 - - 

Existing Sources - Repeat M5 and 202 performance test every 2 years 24 1 24 368 8,824.0 441.2 

 Existing Sources - Repeat M29 performance test every 2 years 24 1 24 419 10,056.0 502.8  Existing Sources - Repeat M320 Performance Test every 2 years 24 1 24 419 10,056.0 502.8  Existing Sources - Repeat M6A Performance Test every 2 years 24 1 24 0 - -  Existing Sources - CEMS Monitoring 0.5 1 0.5 423 211.5 10.6  Existing Sources - CEMS Quarterly Inspections 2 4 8 423 3,384.0 169.2  Existing Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 423 41,877.0 2,093.9  Existing Sources - Daily monitoring (CEMS) 0.3 330 99 423 41,877.0 2,093.9 
21 

Year 3 

(A) Hours 

per 

Occurrenc

e 

(B) 

Occurrences/ 

Respondent/Yea

r 

(C) Hours/ 

Respondent

/ 

Year (A x 

B) 

(D) 

Respondents

/ Year 

(E) 

Technical 

Hours/Yea

r (C x D) 

(F) 

Manage

Hours/

r (E x 0

Existing Sources -- All CEMS must follow appropriate performance specifications 0.3 330 99 423 41,877.0 2,093.9 

 New Sources- Initial Performance Test using M5 and M202 24 1 24 2 48.0 2.4  New Sources- Initial Performance Test using M29 24 1 24 2 48.0 2.4  New Sources- Initial Performance Test using M320 24 1 24 2 48.0 2.4  New Sources- Initial Performance Test using M6A 24 1 24 0 - -  New Sources - Repeat M5 and 202 performance test every year 24 1 24 4 96.0 4.8  New Sources - Repeat M29 performance test every year 24 1 24 4 96.0 4.8  New Sources - Repeat M320 Performance Test every year 24 1 24 4 96.0 4.8  New Sources - Repeat M6A Performance Test every year 24 0 0 0 - -  New Sources - CEMS Monitoring 0.5 1 0.5 2 1.0 0.1  New Sources - CEMS Quarterly Inspections 2 4 8 2 16.0 0.8  New Sources - CEMS Daily Calibration Drift Tests 0.3 330 99 2 198.0 9.9  New Sources - Daily monitoring (CEMS) 0.3 330 99 2 198.0 9.9 

New Sources -- All CEMS must follow appropriate performance specifications 0.3 330 99 2 198.0 9.9 

 C. Create Information (Included in 4B) - -  D. Gather Existing Information (Included in 4E) - -  E. Write Report - -  Existing Sources - Notification of Demonstration of CEMS 2 1 2 423 846.0 42.3  Existing Sources - Report of Performance Test (included in 4B) - -  Existing Sources - Notification of Initial Performance Test 2 1 2 423 846.0 42.3  Existing Sources - Quality Assurance Program Notification 2 1 2 423 846.0 42.3 
22 

Year 3 

(A) Hours 

per 

Occurrenc

e 

(B) 

Occurrences/ 

Respondent/Yea

r 

(C) Hours/ 

Respondent

/ 

Year (A x 

B) 

(D) 

Respondents

/ Year 

(E) 

Technical 

Hours/Yea

r (C x D) 

(F) 

Manage

Hours/

r (E x 0

 Existing Sources - Startup, shutdown, and malfunction Report 5 1 5 42.3 211.5 10.6  Existing Sources - Semi-Annual Compliance Report 24 2 48 423 20,304.0 1,015.2  Existing Sources - Notification of Compliance Status 4 1 4 423 1,692.0 84.6  Existing Sources - site-specific performance evaluation test plan 40 1 40 423 16,920.0 846.0  Existing Sources - request to use alternative monitoring procedure 5 1 5 42.3 211.5 10.6  New Sources - Initial notification 2 1 2 2 4.0 0.2  New Sources - Notification of Demonstration of CEMS 2 1 2 2 4.0 0.2  New Sources - Quality Assurance Program Notification 2 1 2 2 4.0 0.2  New Sources - Notification of Initial Performance Test 2 1 2 2 4.0 0.2  New Sources - Report of Performance Test (included in 4B) - -  New Sources - Startup, shutdown, and malfunction Report 5 1 5 0.2 1.0 0.1  New Sources - Semi-Annual Compliance Report 24 2 48 2 96.0 4.8  New Sources - Notification of Compliance Status 4 1 4 2 8.0 0.4  New Sources - site-specific performance evaluation test plan 40 1 40 2 80.0 4.0  New Sources - request to use alternative monitoring procedure 5 1 5 0.2 1.0 0.1 5. RECORDKEEPING REQUIREMENTS - -  A. Read Instructions (Included in 4A) - -  B. Plan Activities (Included in 4B) - -  C. Implement Activities (Included in 4B) - -  D. Record Data ( Not Applicable) - -  E. Time to Transmit or Disclose Information - - 
23 

Year 3 

(A) Hours 

per 

Occurrenc

e 

(B) 

Occurrences/ 

Respondent/Yea

r 

(C) Hours/ 

Respondent

/ 

Year (A x 

B) 

(D) 

Respondents

/ Year 

(E) 

Technical 

Hours/Yea

r (C x D) 

(F) 

Manage

Hours/

r (E x 0

 Existing Sources - Records of CEMS malfunctions 1.5 1 1.5 423 634.5 31.7 

Existing Sources - Records of Startups, Shutdowns, malfunctions, etc 1.5 1 1.5 423 634.5 31.7 

 Existing Sources - Records of monthly fuel use 1.5 1 1.5 423 634.5 31.7  New Sources - Records of CEMS malfunctions 1.5 1 1.5 2 3.0 0.2  New Sources - Records of Startups, Shutdowns, malfunctions, etc 1.5 1 1.5 2 3.0 0.2  New Sources - Records of monthly fuel use 1.5 1 1.5 2 3.0 0.2  F. Time to Train Personnel 80 2 160 425 68,000.0 3,400.0  G. Time for Audits (Not Applicable) TOTAL ANNUAL LABOR BURDEN AND COST 2035 9,739 307,326 15,366 

353,425 

ANNUALIZED CAPITAL COSTS  Performance tests  Other Capital Costs of Installation (ODC and Labor)  Total annual capital TOTAL ANNUAL COSTS (O&M) TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) a There are 1,257 existing electric generating units. One third of those are assumed to be tested each year. b 10% of sources are assumed to submit SSM report each year.
24 

Table 2a. Year 1 Agency Burden and Cost, NESHAP for Electric Generating Units (40 CFR part 63, subActivity -- Year 1 

(A) EPA 

Hours/ 

Occurrence 

(B) 

Occurrences/ 

Plant/Year 

(C) EPA 

Hours/ 

Plant/Year 

(A x B) 

(D) 

Plants/ 

Year 

(E) EPA 

Technical 

Hours/ Year 

(C x D) 

(F) EPA 

Managerial 

Hours/Year 

(G

Cl

Hou

Observe Initial Performance Tests 24 1 24 84.13 2019.2 100.96 Observe Repeat Performance Tests 24 0.2 4.8 84.13 403.84 20.192 Review Notification of Demonstration of CEMS 0.5 1 0.5 421.00 210.5 10.525 Review Quality Assurance Program Notification 0.5 1 0.5 421.00 210.5 10.525 Review Startup, shutdown, and malfunction Report 8 1 8 421.00 3368 168.4 Review Notification of Compliance Status 0.5 1 0.5 421.00 210.5 10.525 Review requests to use alternative monitoring procedure 0.5 1 0.5 421.00 210.5 10.525 Review Initial Notifications 0.5 1 0.5 2.00 1 0.05 Review Notification of performance test 0.5 1 0.5 421.00 210.5 10.525 Review Test/CEMS Results 8 1 8 421.00 3368 168.4 Review site specific performance evaluation test plan 8 1 8 421.00 3368 168.4 Review Semi-Annual reports 8 1 8 421.00 3368 168.4 Total Annual Hours 16,949 847.427 1 17,965.45 hourTravel Expenses  EPA Officials are assumed to attend 20% of performance tests Travel Expenses = (1 person x 84 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 84 plants/year) = $33,600/year Assume visit 84 plants per year 
25 

Table 2b. Year 2 Agency Burden and Cost, NESHAP for Electric Generating Units (40 CFR part 63, subActivity -- Year 2 

(A) EPA 

Hours/ 

Occurrence 

(B) 

Occurrences/ 

Plant/Year 

(C) EPA 

Hours/ 

Plant/Year 

(A x B) 

(D) 

Plants/ 

Year 

(E) EPA 

Technical 

Hours/ Year 

(C x D) 

(F) EPA 

Managerial 

Hours/Year 

(G

Cl

Hou

Observe Initial Performance Tests 24 1 24 84.13 2019.2 100.96 Observe Repeat Performance Tests 24 0.2 4.8 84.13 403.84 20.192 Review Notification of Demonstration of CEMS 0.5 1 0.5 423.00 211.5 10.575 Review Quality Assurance Program Notification 0.5 1 0.5 423.00 211.5 10.575 Review Startup, shutdown, and malfunction Report 8 1 8 423.00 3384 169.2 Review Notification of Compliance Status 0.5 1 0.5 423.00 211.5 10.575 Review requests to use alternative monitoring procedure 0.5 1 0.5 423.00 211.5 10.575 Review Initial Notifications 0.5 1 0.5 2.00 1 0.05 Review Notification of performance test 0.5 1 0.5 423.00 211.5 10.575 Review Test/CEMS Results 8 1 8 423.00 3384 169.2 Review site specific performance evaluation test plan 8 1 8 423.00 3384 169.2 Review Semi-Annual reports 8 1 8 423.00 3384 169.2 Total Annual Hours 17,018 850.877 1 18,038.59 hourTravel Expenses  EPA Officials are assumed to attend 20% of performance tests Travel Expenses = (1 person x 84 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 84 plants/year) = $33,600/year Assume visit 84 plants per year 
26 

Table 2c. Year 3 Agency Burden and Cost, NESHAP for Electric Generating Units (40 CFR part 63, sub

Activity -- Year 3 

(A) EPA 

Hours/ 

Occurrenc

e 

(B) 

Occurrences

/ Plant/Year 

(C) EPA 

Hours/ 

Plant/Yea

r (A x B) 

(D) 

Plants

/ Year 

(E) EPA 

Technical 

Hours/ Year 

(C x D) 

(F) EPA 

Managerial 

Hours/Year 

(G

Cl

Hou

Observe Initial Performance Tests 24 1 24 84.13 2019.2 100.96 Observe Repeat Performance Tests 24 0.2 4.8 84.13 403.84 20.192 Review Notification of Demonstration of CEMS 0.5 1 0.5 425.00 212.5 10.625 Review Quality Assurance Program Notification 0.5 1 0.5 425.00 212.5 10.625 Review Startup, shutdown, and malfunction Report 8 1 8 425.00 3400 170 Review Notification of Compliance Status 0.5 1 0.5 425.00 212.5 10.625 Review requests to use alternative monitoring procedure 0.5 1 0.5 425.00 212.5 10.625 Review Initial Notifications 0.5 1 0.5 2.00 1 0.05 Review Notification of performance test 0.5 1 0.5 425.00 212.5 10.625 Review Test/CEMS Results 8 1 8 425.00 3400 170 Review site specific performance evaluation test plan 8 1 8 425.00 3400 170 Review Semi-Annual reports 8 1 8 425.00 3400 170 Total Annual Hours 17,087 854.327 1

18,111.73 hour

Travel Expenses  EPA Officials are assumed to attend 20% of performance tests Travel Expenses = (1 person x 84 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 84 plants/year) = $33,600/year Assume visit 84 plants per year