# SUPPORTING STATEMENT

FOR OMB REVIEW OF EPA ICR No. 2362.01 (OMB Control Number 2060-0631):

INFORMATION COLLECTION EFFORT FOR NEW AND EXISTING COAL- AND

OIL-FIRED ELECTRIC UTILITY STEAM GENERATING UNITS

Sector Policies and Programs Division U.S. Environmental Protection Agency Research Triangle Park, North Carolina 27711

December 24, 2009

# 2 SUPPORTING STATEMENT PART A

Part A of the Supporting Statement

1. Identification of the Information Collection

(a) Title of the Information Collection

“Information Collection Effort for New and Ex isting Coal- and Oil-fi red Electric Utility

Steam Generating Units.” This is a new info rmation collection reque st (EPA ICR Number

2362.01 and OMB Control Number 2060-0631).

(b) Short Characterization

This information collection is being conducted by EPA’s Office of Air and Radiation

(OAR) to assist the EPA Administ rator, as required by section 112( d) of the Clean Air Act, as

amended (CAA), to develop an emission standa rd for this source category. CAA section

112(a)(8) defines an electric util ity steam generating unit as

. . . any fossil fuel-fired combustion unit of more than 25 megawatts that serves a generator that produces elec tricity for sale. A unit th at cogenerates steam and electricity and supplies more than one- third of its potenti al electric output capacity and more than 25 MWe output to any utility power distribution system for sale is also considered a utility unit.

The information from this ICR would al so be made available to the public.

Currently, information necessary to identify all coal- and oil-fi red electric utility units is

publicly available for facilities owned and operate d by publicly-owned utility companies, Federal

power agencies, rural electric cooperatives, inve stor-owned utility generating companies, and

nonutility generators (such units include, but may not be limited t o, independent power

producers (IPPs), qualifying facilities, and combin ed heat and power (CHP) units). However,

the most recent data available are for 2005. Also, information on a unit’s permitted emission

limits, and monitoring, recordkeep ing, and reporting requirements for all HAP emissions are not

available from any single source. This informa tion may have been previo usly recorded in both

Federal Title V permits and in certain State’s em issions permits if control of HAP is required.

Additionally, there are no readily available source s for coal- and oil-fired electric utility steam

generating units of fuel amounts received, fuel so urces, fuel shipment methods, and results from

previously conducted fuel analyses for each indi vidual coal and oil shipment received during the

preceding 12 months before this ICR, or for any previously conducted (since January 01, 2005)

# 3 emissions test results that will provide data for emissions of a variety of pollutants, including:

particulate matter (PM), particulate matter smaller than 2.5 microns (PM 2.5 

# ), sulfur dioxide

(SO 2 

# ), hydrogen chloride/hydrogen fluoride/hydr ogen cyanide (HCl/HF/HCN), metal HAP

(including compounds of antimony (Sb), arsenic (A s), beryllium (Be), ca dmium (Cd), chromium

(Cr), cobalt (Co), lead (Pb), manganese (Mn), an d selenium (Se)), mercury (Hg), total organic

hydrocarbons (THC), volatile organic com pounds (VOC), and carbon monoxide (CO).

To obtain the information, this information co llection contains two components. The first

component is soliciting information, under auth ority of CAA section 114, from all potentially

affected units. EPA intends to provide the su rvey in electronic format; however, written

responses will also be accepted. The survey will be submitted to all coal- and oil-fired electric

utility steam generating facilities listed in the 2007 version of the Depart ment of Energy’s (DOE)

Energy Information Administration’s (EIA) Forms 860 and 923, “Annual Electric Generator

Report,” and “Power Plant Operations Report,” respectively.

The second component is requiring, again throug h the issuance of a le tter pursuant to the

authority of CAA section 114, the owners/operato rs of a limited number of coal-and oil-fired

electric utility steam generating units to c onduct stack testing in accordance with an EPAapproved protocol. Units selected to be tested will be identified through factors believed to place

them among the top performing 15 percent of sources in the coal and oil subcategories of electric

utility steam generating units, and from among any further potential subcategories, based on the

currently available data. Coal-fired units to be tested will also be selected to cover three

potential categories of HAP that may be addresse d through the use of surr ogates. These potential

categories of HAP are mercury and non-mercur y metallic HAP (e.g., As, Pb, Se), acid gas HAP

(e.g., HCl, HF, HCN), and non-dioxin/furan organi c HAP. Fifty coal-fired units each will also

be selected at random from the entire populati on of coal-fired EGUs; these 50 units will be

required to test for dioxin/furan organic HAP. An additional 50 coal-fired units will be selected

at random from among those units not selected as being “top performing” units to represent those

coal-fired units not comprising th e top-performing units; these 50 ra ndomly selected units will be

required to test for all HAP except dioxin/furan organic HAP. Data from this last grouping will

be used to assess the impact of the standards. Oil- fired units to be tested will also be selected to

cover the same three potential ca tegories of HAP noted above th at may be addressed through the

use of surrogates as well as the dioxin/furan organic HAP. The testi ng is to consist of three runs

# 4 at the sampling location and is to be in accordan ce with a specified emission test method. The

owner/operator of each selected electric utility steam generating unit will also be required to

collect and analyze, in accordance with an acceptable procedure, three fuel samples from the fuel

fed to the boiler during each stack test. The resu lts of the stack tests and the fuel analyses will

again be required to be submitted to the EPA. Owner/operators of oil-fired units and of coalfired units selected for testing for dioxin/furan organic HAP and chosen to represent those coalfired units not comprising the top-performing uni ts may offer for EPA approval alternative units

for testing as long as the potential substitution unit is of similar size and type, fires a similar coal,

and has similar control equipment.

EPA estimates the cost of the gathering, en tering, and quality a ssuring (QA) of data

submitted in response to the survey will be 100,802 hours and $9,534,450; and the cost of the

stack testing and fuel sampling component to be 24,296 hours and $66,438,308, for a total cost

of $75,972,758. In developing the cost totals fo r gathering, entering, and quality assuring the

data submitted in response to the survey, EPA estimated costs assuming 45 and 65 hours to

complete these tasks. The difference in the total cost between the 2 separate estimates was an

additional $2,897,731. To address concerns rais ed by commenters, EPA used 65 hours in its

total cost estimate above.

The owner/operator of each coal- and oil-fi red electric utility steam generating unit is

required to enter all data through the web site data co llection tool, enter th ese data using proper

unit terminology, and to QA/QC the da ta entered into the web site.

The owner/operator of each coal- and oil- fired electric utility steam generating unit

required to conduct stack testing and concurrent fuel sampling and analysis will be required to

keep records: i) documenting that fuel sample s taken during each stack te st run were obtained in

accordance with an approved sampling protocol; ii) establishing proper chain of custody for each

fuel sample; iii) describing the QA/QC procedures followed in preparing each fuel sample for

analysis and performing the required analysis; iv) setting forth the results of the analyses

performed on each fuel sample; v) documenting that each stack test was conducted in accordance

with an approved testing protocol; and, vi) se tting forth the results of each stack test.

All records required under the proposed info rmation collection must be retained for

3 years.

# 5 2. Need for and Use of the Collection

(a) Need/Authority for the Collection

The Agency acquired unit-specific data and data on mercury from coal-fired units in an

ICR approved on November 13, 1998 (OMB Contro l No. 2060-0396; “1999 ICR”). These data

were gathered in advance, and in support, of the December 20, 2000, regulatory finding (65 FR

79825). Using these and other data, on Ma y 18, 2005 (70 FR 28606), EPA promulgated the

Clean Air Mercury Rule (CAM R) establishing emission limits under CAA section 111. In

addition, on March 29, 2005 (70 FR 15994), EPA pub lished a notice revising its December 2000

determination that regulation of coal- and oil-fi red electric utility steam generating units under

CAA section 112 was appropriate and necessary (S ection 112(n) Revision Rule). On February

08, 2008, the U.S. Court of Appeals for the Distri ct of Columbia Circuit vacated the Section

112(n) Revision Rule. As a part of the decision, the Court also vacated CAMR, reverting to the

December 2000 regulatory determination and requ iring the development of emission standards

under CAA section 112 (maximum achievable contro l technology, or MACT, standard) for coaland oil-fired electric utility steam generating units. EPA subsequently asked the Court for a

rehearing, which was denied. The Department of Justice (DOJ), at EPA’s request, filed a

petition for certiorari with the Supreme C ourt on November 17, 2008; on January 29, 2009, EPA

requested of the DOJ that the petition be w ithdrawn. On December 20, 2008, EPA was sued by

several environmental and health organizations for failing to meet a mandatory duty under CAA

section 112 to set emission standards for coal- and oil-fired power plants by December 20, 2002.

On October 28, 2009, pursuant to CAA s ection 113(g), EPA published in the Federal Register

for comment a proposed Consent Decree to resolve the litigati on. The proposed Consent Decree

would require the Agency to propose CAA s ection 112(d) standards by March 16, 2011, and

issue final CAA section 112(d) standards by November 16, 2011.

The originally collected data (through the 1999 ICR) are now over 10 years old and

address only coal-fired electric utility steam generating units and only mercury emissions from

such units. The Agency is aware that significan t changes have been made in the intervening

years in the number of operating coal- and oil-fired units, in indus try ownership practices, and in

emission control configurations. Further, in light of the statut ory requirements for establishing

emission standards under CAA section 112(d) and the recent case la w interpreting those

requirements, the Agency believes that it needs additional data from both coal- and oil-fired

# 6 electric utility steam generating units. Theref ore, the Agency has concluded that obtaining

updated information will be crucia l to informing its decision on th e national emission standards

for hazardous air pollutants (NESHAP) for coal- a nd oil-fired electric utility steam generating

units.

CAA section 114(a) states that the Admini strator may require any owner or operator

subject to any requirement of this Act to:

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

(b) Use/Users of the Data

The data collected will be used to revise the population of potentially affected coal- and

oil-fired electric utility steam generating units and update existing faci lity information and

configuration, existing permit emission limits for the data, required monitoring and

recordkeeping data for permitted HAP, and gather fuel analysis information and HAP emission

data. These data will be used by the Agency to develop NESHAP for coal - and oil-fired electric

utility steam generating units unde r CAA section 112. Specifically, th e data will respond in part

to the data needs noted in Section 2(a), provi ding the Agency with updated information on the

number of potentially affected units, available emission test data, and fu el analysis data to

establish NESHAP and to address variability.

3. Non-duplication, Consultations, and Other Collection Criteria

(a) Non-duplication

The Agency recognized that some of the information requested in the information

collection effort may already be included in the submittals made by individual companies,

pursuant to State and national em ission inventories, operating perm its applications, and initial

notification forms. However, the complete extent of the data fi elds requested under this survey

is not available in a consistent and usable format. Additiona lly, none of these three sources

provide any data on fuel analys es or emission test results. Although some State permits are

provided to the public as search able portable document format files (pdfs), many States do not

# 7 provide electronic versions of th eir issued Title V permits. Even when the permit is available,

often the unit-specific fuel and operating data are unavailable. So me of the initial notifications

submitted are available in hard-copy only, whereas only the facility-level information (facility

name, location, contact) is availabl e in an electronic format. Ot her than the emission test data

submitted prior to the compliance date, informa tion requested pursuant to the unit design and

operations, fuel analyses emissions data, and effectiveness of various control devices at

removing HAP is not believed to be available from other sources and, therefore, will be used to

supplement the information which may curr ently be available from other sources.

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

This ICR was submitted for public review on July 2, 2009 (74 FR 31725) as required by

the Paperwork Reduction Act of 1995 (PRA) and th e subsequent rule issued by the Office of

Management and Budget (OMB) on August 29, 1995 (60 FR 44978). EPA addressed the public

comments received, and submitted the ICR to OMB on November 10, 2009 (74 FR 58012).

EPA’s responses to all public comments receive d are contained in the respective Response to

Comments documents for the subject Federal Register notices; thes e documents may be found in

the docket (EPA-HQ-OAR-2009-0234).

(c) Consultations

No representatives of Federal or State agen cies were consulted at this time. Two

meetings were held with repres entatives of trade asso ciations and individual companies. An

opportunity for additional comment was provided by the Federal Register notice concerning the

submittal of the ICR to OMB.

(d) Effects of Less Frequent Collection

This ICR will require the owner/operator of each facility at which a potentially affected

coal- and oil-fired electric utility steam generating unit is located to complete a survey of the unit

design, operations, fuel consumpti on, available fuel analysis and emissions data. This ICR will

also require that the most rece nt 12 months of fuel analysis data (where that data contain

information on chloride and HAP metal content) and emissions test data for all tests conducted

since January 01, 2005, be submitted. In addition, th is ICR will require that a number of coaland oil-fired electric utility steam generati ng units conduct stack testing. EPA expects the

information requested in this survey to be a one-time effort.

# 8 (e) General Guidelines

This ICR will adhere to the guidelines for Fede ral data requestors, as provided at 5 CFR

1320.6.

(f) Confidentiality

Respondents will be required to respond unde r the authority of CAA section 114. If a

respondent believes that disclosure of certain information requested would compromise a trade

secret, it should be clearly identified as such and will be treated as confidential until and unless it

is determined in accordance with established EPA procedure as set forth in 40 CFR Part 2 not to

be entitled to confidential treatment. All inform ation submitted to the Agency for which a claim

of confidentiality is made will be safeguarded acc ording to the Agency policies set forth in Title

40, Chapter 1, Part 2, Subpart B – Confidentiality of Business Information (see 40 CFR 2; 41 FR

36902, September 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251,

September 28, 1978; 44 FR 17674, March 23, 1979). A ny information subsequently determined

to constitute a trade secret will be protected under 18 U.S.C. 1905. If no claim of confidentiality

accompanies the information when it is received by EPA, it may be made available to the public

without further notice (40 CFR 2.203, Septem ber 1, 1976). Because CAA section 114(c)

exempts emission data from claims of confiden tiality, the emission data provided will be made

available to the public. Theref ore, emissions data should not be marked confidential. A

definition of what EPA considers emissions data is provided in 40 CFR 2.301(a)(2)(i).

Additionally, the planned electronic questionnaire will be stored on a secure server which

will ensure that all data provided is encrypted.

(g) Sensitive questions

This section is not applicable because this ICR will not involve matter of a sensitive

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Respondents affected by this action are owners/o perators of coal- and oil-fired electric

utility steam generating units as defined in CAA section 112(a)(8) as noted earlier. Natural gasfired electric utility steam generating units are not affected by this action. For the purposes of

this information collection, “co al” includes anthracite, bitumi nous, subbituminous, lignite, and

# 9 coal refuse (generally termed culm and gob bit also including subbituminous refuse); and “oil”

includes distillate, residu al, and bunker oils along with petroleum coke.

The North American Industry Classificati on System (NAICS) codes for respondents

affected by the standards are listed in the following table.

Category NAICS Code

Industry Fossil Fuel Electric Power Generation 221112

Federal/State/local government Electric Power Distribution 221122

Tribal government American Indian and Alaska Native Tribal Governments 921150



# (b) Information Collected

(i) Data Items. The proposed emissions data gather ing effort has two components:

i) confirmation of certain information from all co al- and oil-fired units; and ii) stack testing. In

the first component, each owner/operator of each a ffected unit will be required to complete a

survey that will have the following components: identification and confirmation of existing unit,

the unit design, operations, fuel consumption, availa ble fuel analysis and emissions data. This

ICR will require that the most recent 12 months of fuel analysis data (where that data contain

information on chloride and HAP metal content) and emissions test data for all tests conducted

since January 01, 2005, be submitted. This will appl y to all coal- and oil- fired electric utility

steam generating units meeting the definition of “electric utility steam generating unit” in CAA

section 112(a)(8) and fac ilities designated as major or area sources of HAP in their Title V

permits that have a coal- and/or oil-fired el ectric utility steam generating unit meeting the

definition in CAA section 112(a )(8) listed as one of their emission sources. The draft

questionnaire content can be found in Attachment 1. The survey wi ll require each facility with

potentially affected units to provide information to the Agency within 90 days of the receipt of

the CAA section 114 letter that allows for identi fication and categorizatio n of the units based on

unit design and operations, fuel t ype, and/or boiler design. The surv ey will also require the most

recent 12 months of fuel analysis data (where th at data contain information on chloride and HAP

metal content) and emissions test data fo r all tests conducted since January 01, 2005. The

Agency is requiring emissions test data fo r all HAP and HAP surr ogates including, but not

limited to: PM, PM 2.5 

# , SO 2 

# , HCl, HF, metal HAP, Hg, THC, VOC, and CO.

The second component, stack testing, will re quire triplicate sampling with a specified

emission test method at a point repr esenting the flue gas stream as it enters the atmosphere. This

# 10 sampling will be done on one occasion. During the stack testing, collection and analyses of three

as-fired fuel samples taken at intervals throughou t the testing period will be required. The results

of each series of stack tests and fuel sample an alyses will be required to be reported to the EPA

by using a specified standardized electronic format within 6 to 8 months of the receipt of the

CAA section 114 letter. Specified QA/QC procedures will be required for each part of the

emissions data collection effort.

For this effort, EPA believes it is highly a dvisable for each facility subject to emissions

testing under Part III of the ICR to devise a quality assurance test pl an that is specific to each

facility. Such a plan could include the project elements as enumerated in chapter 3 of the EPA

quality assurance document. The existence of such a plan would provide a means to verify that

the quality assurance protocols as contained in the various test methods are met. Note, however,

that these quality assurance test plans will not be reviewed or approved by EPA.

(ii) Respondent Activities. The activities a respondent mu st undertake to fulfill the

requirements of the information collection are presen ted in Attachment 2. These include: i) read

instructions; ii) provide source, permit, emission, etc., information (e.g., gather existing reports

with requested data for each affected source, ex tract requested data from reports, enter extracted

data into Web Site, and perform quality checks on data entered into the Web Site); iii) procure a

stack test contractor and review proposal (if one of the units was selected for stack testing); iv)

conduct fuel sampling (if one of the units was sele cted for stack testing); v) conduct stack testing

(if one of the units was selected); vi) monitor stack testing (if one of the units was selected); vii)

review stack sampling data for accuracy and comple teness (if one of the units was selected); and

viii) submit stack sampling data (if one of the units was selected).

5. The Information Collected – Agency Activities, Collection Methodology, and

Information Management

(a) Agency Activities

A list of activities required of the EPA is provided in Attachment 3. These include:

i) develop questionnaire; ii) develop and deploy web site for data entry from facilities, iii) mail

out questionnaire, iv) answer re spondent questions, v) analyz e requests for confidentiality,

vi) review and analyze Part I responses; vii) de velop generic QAPP; viii) determine sites to be

emission tested; ix) review and comment on stack sampling test plans and QAPPs; x) audit stack

# 11 tests; xi) review stack sampling data for accur acy and completeness; and xii) analyze stack

sampling data.

(b) Collection Methodo logy and Management

In collecting and analyzing the information associated with this ICR, EPA will use

personal computers and applicable database software. EPA will ensure the accuracy and

completeness of the collected information by reviewing each submittal. The information

collected pursuant to the coal- a nd oil-fired electric utility stea m generating units’ data gathering

effort will be maintained in a computerized database. To better facilitate uniformity in the

format of the requested data and increase the ease of database entry, standardized survey

questions will be developed and distributed to respondents.

(c) Small Entity Flexibility

All respondents required to co mply with the coal- and oil- fired electric utility steam

generating units’ data gathering effort will be su bject to the same requirements. EPA expects

that a portion of the respondents may be sma ll entities; however, any individual small entity

would be expected to receive only one CAA sec tion 114 letter so their response burden will be

minimized. The Agency also plans to use an elec tronic format of the que stionnaire in order to

reduce the burden and improve the data accuracy from all respondents, including small entities.

In addition, the survey will contain a question to de termine the small entity st atus of a facility.

This question will help to identify, quantify, and minimize the burden on small entities during

the revised rulemaking process.

(d) Collection Schedule

EPA anticipates issuing the first CAA sec tion 114 letters in late 2009. These CAA

section 114 letters will require the owner/operator of each coal- and oil-fired electric utility

steam generating units’ data gathering effort to complete the su rvey within 90 days of receipt of

the survey. EPA will compile and analyze survey response data. The owner/operator of each of

the electric utility steam generating units selected to conduct emission testing will, in the same

letter, be required to: i) submit to EPA for approval any additions and modifications to the

QAPP supplied by EPA and a schedule for comp leting the required stack testing and fuel

sampling and analysis, ii) commence stack test ing, including concurrent fuel sampling and

analysis, by the date specified in the EPA approve d facility-specific schedule; and iii) complete

# 12 stack testing and concurrent fuel sampling and analysis within 6 to 8 months of receipt of the

CAA section 114 letter.

(e) Estimating Respondent Costs

Attachments 2 and 3 present estimated costs fo r the required data co llection activities.

Labor rates and associated costs are based on Bureau of Labor Statistics (B LS) data. Technical,

management, and clerical average hourly rates fo r private industry workers and were taken from

the United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2.

Civilian Workers, by occupational and industry group,” available at

www.bls.gov/news.release/ecec.t02. htm. Wages for occupational groups are used as the basis

for the labor rates with a total compensation of $46.76 per hour for te chnical, $54.52 per hour for

managerial, and $23.11 per hour for clerical. These ra tes represent salaries plus fringe benefits

and do not include the cost of overhead. An overh ead 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 $98.20, management at $114.49, and clerical at $48.53.

(f) Estimating Agency Burden and Costs

The costs the Federal Govern ment would incur are presen ted in Attachment 3. The

Agency labor rates are from the Office of Pe rsonnel Management (OPM) 2009 General Schedule

which excludes locality rates of pay. These rates can be obtained from Salary Table 2009-GS,

available on the OPM website at www.opm.gov/o ca/09tables/html/gs_h.asp. The government

employee labor rates are $16.04 per hour for cleri cal (GS-7, Step 1), $33.84 for technical (GS13, Step 1), and $47.03 for managerial (GS-15, Step 1). These rates were increased by 60

percent to include fringe benef its and overhead. The fully-burdene d wage rates used to represent

Agency labor costs are: cler ical at $25.66, technical at $54.14, and managerial at $75.25.

(g) Estimating the Respondent Uni verse and Total Burden and Costs

The potential respondent universe consists of coal- and oil-fired utility facilities meeting

the CAA section 112(a)(8) definition of “electri c utility steam generating unit.” There are

approximately 1,332 coal- and oil-fired publicly-o wned units, Federal power agencies, rural

electric cooperatives, and investo r-owned utilities locate d at 537 facilities (or s ites). All of these

units will be required to complete the first compone nt of the ICR (i .e., the survey). Note that it

is common for more than one unit to be located at a facility. The second component (i.e., the

required emission testing) will have 512 (nominal) respondents.

# 13 (h) Bottom Line Burden Hours and Costs Tables

(i) Respondent tally. The bottom line industry burden hour s and costs, presented in

Attachment 2, are calculated by summing the person-hours column and by summing the cost

column. The burden and cost to the industry is 125,098 hours and $75,972,758.

(ii) Agency tally. The bottom line Agency burden and cost, presented in Attachment

3 is calculated in the same manne r as the industry burde n and cost. The estimated burden and cost

are 11,825 hours and $630,248, which includes $8,423 in O&M costs to send certified CAA

section 114 letters to all respondent s with electronic return recei pt, questionnaire printing costs,

and computer storage of data received through the web site.

(iii) The complex collection. This ICR is a simple collection; therefore, this section

does not apply.

(iv) Variations in the annual bottom line. This section does not apply as this is a onetime collection.

(i) Reasons for Change in Burden

This is a new information collection conduc ted by EPA’s Office of Air and Radiation

(OAR) to assist the Administrator of EPA to determine the current population of affected coal- and

oil-fired electric utility steam ge nerating units and to develop emi ssion standards for this source

category as required by CAA section 112(d). The original burden estimates have changed as a

result of comments received and EPA’s actions to respond to the issues raised in some of those

comments.

(j) Burden Statement

The total burden for the coal- and oil-fired electric utility steam generating units’ data

gathering effort is estimated to be 125,098 hours and $75,972,758 (103 hours and $82,485 per

respondent for approximately 1,332 units).

Burden means the total time, effort, or financial resources expended by persons to

generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This

includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology

and systems for the purposes of collecting, valida ting, and verifying information, processing and

maintaining information, and disclosing and provi ding information; adjust the existing ways to

comply with any previously applic able instructions and requirements; train personnel to be able to

respond to a collection of information; search da ta sources; complete and review the collection of

# 14 information; and transmit or otherwise disclose the information. An agency may not conduct or

sponsor, and a person is not requir ed to respond to, a collection of information unless it displays a

currently valid OMB control numb er. The OMB control numbers for EPA’s regulations are listed

in 40 CFR part 9 and 48 CFR chapter 15.

# 15 SUPPORTING STATEMENT PART B

See separate document.

# 16 List of Attachments

1. Draft Questionnaire Content

2. Industry Burden and Costs for Responding to the Questionnaire

3. Agency Burden and Costs

4. List of coal-fired electric utility steam ge nerating units requiring Part I and II Information

5. List of oil-fired electric utility steam gene rating units requiring Part I and II Information

6. List of all IGCC units requiring Part I, II, and III Information and selected for

HCl/HF/HCN acid gas HAP, dioxi n/furan organic HAP, non dioxin/furan organic HAP,

and mercury and other non-mercury metallic HAP testing

7. List of all petroleum coke-fir ed units requiring Part I, II, a nd III Information and selected

for HCl/HF/HCN acid gas HAP, dioxin/fura n organic HAP, non dioxin/furan organic

HAP, and mercury and other non-me rcury metallic HAP testing

8. List of coal-fired electric utility steam generating units selected for HCl/HF/HCN acid

gas HAP testing

9. List of coal-fired electric utility steam ge nerating units selected for dioxin/furan organic

HAP testing

10. List of coal-fired electric utility steam generating units selected for non-dioxin/furan

organic HAP testing

11. List of coal-fired electric utility steam ge nerating units selected for mercury and other

non-mercury metallic HAP testing

12. List of all oil-fired electr ic utility steam generating units selected for HCl/HF/HCN acid

gas HAP, dioxin/furan organic HAP, non dioxi n/furan organic HAP, and mercury and

other non-mercury metallic HAP testing

13. List of 50 additional coal-fired electric ut ility steam generating units not chosen in

Attachments 8 through 11 selected for HCl/HF/HCN acid gas HAP, non dioxin/furan

organic HAP, and mercury and other non-mercury metallic HAP testing"

# 17 Attachment 1.

Draft Questionnaire Content

See separate document.18Attachment 2.Industry Burden and Costs for Responding to the QuestionnaireActivity(A)HoursperOccurrence(B)Occurrences/Respondent/Year(C)Hours/Respondent/Year(AxB)(D)Respondents/Year(E)TechnicalHours/Year(CxD)(F)ManagerialHours/Year(Ex0.05)*(G)ClericalHours/Year(Ex0.10)(F)Cost/Year1.APPLICATIONS(NotApplicable)2.SURVEYANDSTUDIES(NotApplicable)3.ACQUISITION,INSTALLATION,ANDUTILIZATIONOFTECHNOLOGYANDSYSTEMS(NotApplicable)4.REPORTREQUIREMENTSA.ReadInstructionsFacility2125371,074.053.7107.4$116,823B.RequiredActivitiesGatherexistingreportswithrequesteddata14114133218,648.0932.41,864.8$2,028,412Extractrequesteddatafromreports14114133218,648.0932.41,864.8$2,028,412EnterextracteddataintoWebSite23123133230,636.01,531.83,063.6$3,332,391QA/QCentereddataonWebSite14114133218,648.0932.41,864.8$2,028,412ReadTestPlanprovidedbyEPAforstacktesting0.710.7300210.010.521.0$22,842Procurecontractortoperformtesting201203006,000.0300.0600.0$652,642SubmitstacktestresultsthroughtheERT212300600.030.060.0$65,264QA/QCentereddataonWebSite111300300.015.030.0$32,632HClandHFtestingfromcoal‐firedutilityunits(w/andw/oFGD)**238$7,711,200Dioxin/furanemissionsfromcoal‐firedutilityunits**68$2,856,000Non‐Dioxin/furanemissions(CO,VOC,andTHC)fromcoal‐firedutilityunits**238$15,761,600Hgandnon‐HgMetalicHAPfromcoal‐firedutilityunits**238$15,822,24019Activity(A)HoursperOccurrence(B)Occurrences/Respondent/Year(C)Hours/Respondent/Year(AxB)(D)Respondents/Year(E)TechnicalHours/Year(CxD)(F)ManagerialHours/Year(Ex0.05)*(G)ClericalHours/Year(Ex0.10)(F)Cost/YearAllHAPsurrogatesfromoil‐firedutilityunits**100$21,908,000Plantpersonnelfortesting***1634830014,400.0144.0‐$1,430,509ReviewtheTestReportData5153001,500.075.0‐$175,378C.CreateInformation(Includedin4B)D.GatherExistingInformation(Includedin4E)E.WriteReport(NotApplicable)5.RECORDKEEPINGREQUIREMENTS(Notapplicable)110,6644,9579,476$75,972,758TOTALANNUALLABORBURDENANDCOST125,098HoursANNUALCAPITALCOSTS(NotApplicable)$‐ANNUALIZEDCAPITALCOSTS(NotApplicable)$‐TOTALANNUALCOSTS(O&M)(NotApplicable)$‐TOTALANNUALIZEDCOSTS(Annualizedcapital+O&Mcosts)(NotApplicable)$‐*WeassumednoclericalhoursandlessmanagerialhourswereneededwhenplantpersonnelwereworkingwithContractorstoconducttesting**ThisistheassumedtestingcostsforfacilitieswhentestingisperformedbyaContractor***Thisassumes3facilitytechnicalstaffover2daysforworkingwiththeContractortoconducttesting.Alladministrativeworkisassumedtobeincludedinthecontractortestingandnofaciliatyadministrativestaffisrequiredfortesting.20Attachment 3.Agency Burden and CostsActivity(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, $Develop questionnaire 80 1 80 1 80.0 4.0 8.0 $ 4,838Develop web site for data entry fromfacilities120 1 120 1 120.0 6.0 12.0 $ 7,257Mail out Questionnaire 4 1 4 5372,148.0 107.4 214.8 $ 129,896Answer respondent questions 0.25 1 0.25 53.713.4 0.7 1.3 $ 812Analysis request for confidentiality 0.25 1 0.25 133.2 33.3 1.7 3.3 $ 2,014Review and Analyze responses 4 1 41332 5,328.0 266.4 532.8 $ 322,199Review the electronically submittedstack testing data5 1 5 512 2,560.0 128.0 256.0 $ 154,810Total Annual Hours 10,283 514.13625 1,028 $ 621,82511,825 hoursExpensesPrinting Questionnaire $ 671Postage to mail QuestionnaireRegistered Mail/Receipt$ 6,551Computer Storage of data and webinterface$ 1,200Total Expenses $ 8,423$ 630,248We assume that EPA will mail one questionnaire to each facility.Assumes that 10 percent of the facilities will have questions.Assumes that 10 percent of theunits will have confidential data.

# 21 Attachment 4.

List of coal-fired electric ut ility steam generating units requi ring Part I and II Information

See separate document.

Attachment 5.

List of oil-fired electric utili ty steam generating units requi ring Part I and II Information

See separate document.

Attachment 6.

List of all IGCC units requiring Part I, II, and III Information and selected for HCl/HF/HCN acid gas HAP, dioxin/furan orga nic HAP, non-dioxin/furan organic HAP, and mercury and other non-mercury metallic HAP testing

See separate document.

Attachment 7.

List of all petroleum coke-fired units requiring Part I, II, and III Information and selected for HCl/HF/HCN acid gas HAP, dioxin/fura n organic HAP, non-dioxin/furan organic HAP, and mercury and other non -mercury metallic HAP testing

See separate document.

Attachment 8.

List of coal-fired electric utility steam generating units selected for HCl/HF/HCN acid gas HAP testing

See separate document.

Attachment 9.

List of coal-fired electric ut ility steam generating units se lected for dioxin/furan organic HAP testing

See separate document.

# 22 Attachment 10.

List of coal-fired electric utility steam generating units selected for non-dioxin/furan organic HAP testing See separate document.

Attachment 11.

List of coal-fired electric utility steam gen erating units selected for mercury and other nonmercury metallic HAP testing

See separate document.

Attachment 12.

List of all oil-fired electric utility steam ge nerating units selected for HCl/HF/HCN acid gas

HAP, dioxin/furan organic HAP, non-dioxin/ furan organic HAP, and mercury and other non-mercury metallic HAP testing

See separate document.

Attachment 13.

List of 50 additional coal-fi red electric utility steam gen erating units not chosen in Attachments 8 through 11 selected for HC l/HF/HCN acid gas HAP, non dioxin/furan organic HAP, and mercury and other no n-mercury metallic HAP testing"

See separate document.