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 Existing Coal- and Oil-fired Electric Utility 

Steam Generating Units.” This is a new information collection request (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 Administrator, as required by section 112(d) of the Clean Air Act, as 

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

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

. . . any fossil fuel-fired combustion unit of more than 25 megawatts that serves a 

generator that produces electricity for sale. A unit that cogenerates steam and 

electricity and supplies more than one-third of its potential 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 also be made available to the public. 

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

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

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

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

producers (IPPs), qualifying facilities, and combined 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, recordkeeping, and reporting requirements for all HAP emissions are not 

available from any single source. This information may have been previously recorded in both 

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

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

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

previously conducted fuel analyses for each individual 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 (PM2.5), sulfur dioxide 

(SO2), hydrogen chloride/hydrogen fluoride/hydrogen cyanide (HCl/HF/HCN), metal HAP 

(including compounds of antimony (Sb), arsenic (As), beryllium (Be), cadmium (Cd), chromium 

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

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

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

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

affected units. EPA intends to provide the survey 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 Department 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 through the issuance of a letter pursuant to the 

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

electric utility steam generating units to conduct 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 addressed through the use of surrogates. These potential 

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

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

be selected at random from the entire population 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 the top-performing units; these 50 randomly 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 categories of HAP noted above that may be addressed through the 

use of surrogates as well as the dioxin/furan organic HAP. The testing is to consist of three runs 
4

at the sampling location and is to be in accordance 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 results 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 units 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, entering, and quality assuring (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 for 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 raised by commenters, EPA used 65 hours in its 

total cost estimate above. 

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

required to enter all data through the web site data collection tool, enter these data using proper 

unit terminology, and to QA/QC the data 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 samples taken during each stack test 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) setting forth the results of each stack test. 

All records required under the proposed information 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 Control 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 May 18, 2005 (70 FR 28606), EPA promulgated the 

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

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

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

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

08, 2008, the U.S. Court of Appeals for the District 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 requiring the development of emission standards 

under CAA section 112 (maximum achievable control 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 Court on November 17, 2008; on January 29, 2009, EPA 

requested of the DOJ that the petition be withdrawn. 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 section 113(g), EPA published in the Federal Register

for comment a proposed Consent Decree to resolve the litigation. The proposed Consent Decree 

would require the Agency to propose CAA section 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 significant changes have been made in the intervening 

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

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

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

requirements, the Agency believes that it needs additional data from both coal- and oil-fired 
6

electric utility steam generating units. Therefore, the Agency has concluded that obtaining 

updated information will be crucial to informing its decision on the national emission standards 

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

units. 

CAA section 114(a) states that the Administrator 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 intervals, 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 facility 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 under CAA section 112. Specifically, the data will respond in part 

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

number of potentially affected units, available emission test data, and fuel 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 emission inventories, operating permits applications, and initial 

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

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

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

provided to the public as searchable portable document format files (pdfs), many States do not 
7

provide electronic versions of their issued Title V permits. Even when the permit is available, 

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

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

name, location, contact) is available in an electronic format. Other than the emission test data 

submitted prior to the compliance date, information 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 currently be available from other sources. 

(b) Public Notice Required Prior 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 the 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 received are contained in the respective Response to 

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

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

(c) Consultations 

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

meetings were held with representatives of trade associations 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 consumption, available fuel analysis and emissions data. This ICR will 

also 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. In addition, this ICR will require that a number of coaland oil-fired electric utility steam generating 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 Federal data requestors, as provided at 5 CFR 

1320.6. 

(f) Confidentiality 

Respondents will be required to respond under 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 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 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251, 

September 28, 1978; 44 FR 17674, March 23, 1979). Any 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, September 1, 1976). Because CAA section 114(c) 

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

available to the public. Therefore, 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/operators 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, “coal” includes anthracite, bituminous, subbituminous, lignite, and 
9

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

includes distillate, residual, and bunker oils along with petroleum coke. 

The North American Industry Classification 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 gathering effort has two components: 

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

the first component, each owner/operator of each affected 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, available 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 apply 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 facilities designated as major or area sources of HAP in their Title V 

permits that have a coal- and/or oil-fired electric 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 will 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 identification and categorization of the units based on 

unit design and operations, fuel type, and/or boiler design. The survey will also require 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. The 

Agency is requiring emissions test data for all HAP and HAP surrogates including, but not 

limited to: PM, PM2.5, SO2, HCl, HF, metal HAP, Hg, THC, VOC, and CO. 

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

emission test method at a point representing 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 throughout the testing period will be required. The results 

of each series of stack tests and fuel sample analyses 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 advisable for each facility subject to emissions 

testing under Part III of the ICR to devise a quality assurance test plan 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 must undertake to fulfill the 

requirements of the information collection are presented 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, extract 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 selected 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 completeness (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 respondent questions, v) analyze requests for confidentiality, 

vi) review and analyze Part I responses; vii) develop 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 accuracy and completeness; and xii) analyze stack 

sampling data. 

(b) Collection Methodology 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- and oil-fired electric utility steam 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 comply with the coal- and oil-fired electric utility steam 

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

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

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

minimized. The Agency also plans to use an electronic format of the questionnaire 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 determine the small entity status 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 section 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 survey 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 completing the required stack testing and fuel 

sampling and analysis, ii) commence stack testing, including concurrent fuel sampling and 

analysis, by the date specified in the EPA approved 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 for the required data collection activities. 

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 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 technical, $54.52 per hour for 

managerial, and $23.11 per hour for clerical. 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 $98.20, management at $114.49, and clerical at $48.53. 

(f) Estimating Agency Burden and Costs 

The costs the Federal Government would incur are presented in Attachment 3. The 

Agency labor rates are from the Office of Personnel 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/oca/09tables/html/gs_h.asp. The government 

employee labor rates are $16.04 per hour for clerical (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 benefits and overhead. The fully-burdened wage rates used to represent 

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

(g) Estimating the Respondent Universe 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 “electric utility steam generating unit.” There are 

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

electric cooperatives, and investor-owned utilities located at 537 facilities (or sites). All of these 

units will be required to complete the first component 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 hours 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 manner as the industry burden 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 respondents with electronic return receipt, 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 conducted 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 generating units and to develop emission 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 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 
14

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 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 generating units requiring Part I and II Information 

5. List of oil-fired electric utility steam generating 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, dioxin/furan organic HAP, non dioxin/furan organic HAP, 

and mercury and other non-mercury metallic HAP testing 

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/furan organic HAP, non dioxin/furan organic 

HAP, and mercury and other non-mercury 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 generating 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 generating units selected for mercury and other 

non-mercury metallic HAP testing 

12. List of all oil-fired electric utility steam generating 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 

13. List of 50 additional coal-fired electric utility 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.
18

Attachment 2. 

Industry Burden and Costs for Responding to the Questionnaire 

Activity (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 (Not Applicable)

4. REPORT REQUIREMENTS

A. Read Instructions

Facility 2 1 2 537 1,074.0 53.7 

B. Required Activities

Gather existing reports with requested data 14 1 14 1332 18,648.0 932.4 Extract requested data from reports 14 1 14 1332 18,648.0 932.4 Enter extracted data into Web Site 23 1 23 1332 30,636.0 1,531.8 QA/QC entered data on Web Site 14 1 14 1332 18,648.0 932.4 Read Test Plan provided by EPA for stack testing 0.7 1 0.7 300 210.0 10.5 Procure contractor to perform testing 20 1 20 300 6,000.0 300.0 Submit stack test results through the ERT 2 1 2 300 600.0 30.0 QA/QC entered data on Web Site 1 1 1 300 300.0 15.0 HCl and HF testing from coal‐fired utility units (w/

and w/o FGD)* * 238 

Dioxin/furan emissions from coal‐fired utility

units** 68 

Non‐Dioxin/furan emissions (CO, VOC, and THC)

from coal‐fired utility units** 238 

Hg and non‐Hg Metalic HAP from coal‐fired utility

units** 238 
19

Activity (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)*

All HAP surrogates from oil‐fired utility units** 100 Plant personnel for testing*** 16 3 48 300 14,400.0 144.0 Review the Test Report Data 5 1 5 300 1,500.0 75.0 

C. Create Information (Included in 4B)D. Gather Existing Information (Included in 4E)E. Write Report (Not Applicable)

5. RECORDKEEPING REQUIREMENTS (Not applicable)

110,664 4,957 

TOTAL ANNUAL LABOR BURDEN AND COST

125,098 

ANNUAL CAPITAL COSTS (Not Applicable) ANNUALIZED CAPITAL COSTS (Not Applicable) TOTAL ANNUAL COSTS (O&M) (Not Applicable) TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)

(Not Applicable) 

*We assumed no clerical hours and less managerial hours were needed when plant personnel were working with Contractors to conduct testing**This is the assumed testing costs for facilities when testing is performed by a Contractor

***This assumes 3 facility technical staff over 2 days for working with the Contractor to conduct testing. All administrative work is assumed to be included in the contr

administrative staff is required for testing.
20

Attachment 3. 

Agency Burden and Costs 

Activity 

(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 

Manager

Hours/Ye

Develop questionnaire 80 1 80 1 80.0 Develop web site for data entry from 

facilities 

120 1 120 1 120.0 

Mail out Questionnaire 4 1 4 537 2,148.0 10Answer respondent questions 0.25 1 0.25 53.7 13.4 Analysis request for confidentiality 0.25 1 0.25 133.2 33.3 Review and Analyze responses 4 1 4 1332 5,328.0 26Review the electronically submitted 

stack testing data 

5 1 5 512 2,560.0 12

Total Annual Hours 10,283 514.136 11,8Expenses  Printing Questionnaire $ 671  Postage to mail Questionnaire 

Registered Mail/Receipt 

 $ 6,551 

 Computer Storage of data and web 

interface 

 $ 1,200 

Total Expenses  We 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 the units will have confidential data. 
21

Attachment 4. 

List of coal-fired electric utility steam generating units requiring Part I and II Information 

See separate document. 

Attachment 5. 

List of oil-fired electric utility steam generating units requiring 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 organic 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/furan 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 utility steam generating units selected 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 generating units selected for mercury and other nonmercury metallic HAP testing 

See separate document. 

Attachment 12. 

List of all oil-fired electric utility steam generating 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-fired electric utility 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" 

See separate document.