## 1 **SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 
**National Emission Standards for Hazardous Air Pollutants from Coal**
**- and Oil** 
**- fired** 

**Electric Utility Steam Generating Units (40 CFR part 63, subpart UUUUU**  **)**

**December 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 Of fice 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 b y the United States (U.S.) Court of Appeals for the District of Columbia Circuit (D.C. Circuit Court) on February 8, 2008. Because that information collection was developed explicitly to determine compliance with CAMR, it was no longer needed. Thus, a new information collection request (I CR) was prepared in support of the national emission standards for hazardous air pollutants from coal

- and oil

- fired EGUs that were proposed earlier in 2011 (76 FR 24976, May

3, 2011). This I CR is in support of the standards being promulgated. The OMB control number is 2 060

- 0567. The EPA I CR tracking number is 2137.06

. (b ) Short Characterization On May 3, 2011, under authority

of Clean Air Act (CAA) section 112, the EPA proposed national emission standards for hazardous air pollutants (NESHAP) from coal

- and oil

- fired el ectric utility

steam generating units (EGUs) (76 FR 24976). After consideration of public com ments, the EPA is finalizing the rule in this action. Pursuant to CAA section 112, the EPA is establishing NESHAP that will require coal

and oil

- fired EGUs to mee t hazardous air pollutant (HAP) standards reflecting the application of the maximum achievable control technology . This rule protects air quality and promotes public health by reducing emissions of the HAP listed in CAA section 112(b)(1). 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, an d retain the file for at least 5 years following the date of such measurements, maintenance reports, and records

. All reports are sent to the delegated state or local authorit y. In the event that there is no such delegated authorit y, the reports are sent directly to the U .S. Environmental Protection Agency (EPA) regional office. Potential respondents are owners and operators of coal

- and oil

- fired EGUs . The final rule regulates H Cl, filterable PM, Hg, and organic HAP from coal

- fired EGUs. For oil

- fired

## 2

EGUs, the final rule regulates HCl, HF, filterable PM, and organic HAP. Following initial performance tests, owners/operators of EGUs will be required to demonstrate compliance with emission limits through continuously monitoring PM, Hg, HCl, and HF (oil

- fired EGUs) emissions. The final rule includes a work practice standard for organic HAP; the work practice standard requires the implementation of periodic burner tune

- up procedures. Respondents will be required to notify the EPA of performance tests and CEMS demonstrations, and to maintain records demonstrating compliance with each emission limit and work practice standard. These requirements are listed in Table 1. Approximately

1,2 4 4 electric generating units are currentl y subject to the regulation, and it is estimated that 2 new electric generating units will be built each year. The Office of Management and Budget (OMB) approved the currentl y active Information Collection Request ( IC R) without any “Terms of Clearance.” **2. Need for and Use of the Collection**  (a ) Need/Authority for the Collection Section 112 of the CAA requires that the 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

an y non - major sources not subject to the standards, and identify new or reconstructed sources subject to th e standards; and (2) ensure that the MACT standards are being achieved on a continuous basis. These recordkeeping and reporting requirements are specificall y authorized by

section 114 of the CAA (42 U.S.C. 7414) and set out in the General Provisions for NE SHAP in 40 CFR part 63, subpart A. (b ) Use/Users of the Data The additional information will be used by a gency 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, the 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 I CR from owners/operators of c oal

- and o il

- fired E GUs. In the event that certain reports required by s tate or local agencies may duplicate information required by the proposed requirements , a copy of the report submitted to the s tate or local agency can be provided to the Administrator in lieu of the information that would be required in the semi

- annual co mpliance 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 IC R.

## 3

(c) Consultations The EPA met with 10 national organizations representing s tate and local elected officials to provide general background on the proposal, answer questions, and solicit input from s tate/local governments. The EPA also consulted with Tribal officials early in the process of developing the proposed rule to permit them t o have meaningful and timely input into its development. Consultation letters were sent to 584 Tribal leaders. The letters provided information regarding the EPA’s development of NESHAP for EGUs and offered consultation. Three consultation meetings were re quested and held. We conducted outreach and information sharing with tribal environmental staff through the monthly National Tribal Air Association calls, at the National Tribal Forum, and a webinar targeting tribal environmental professionals on the conte nt of the proposal. Because of concerns raised b y several tribes, and in order to help us better understand their concerns, we also participated in a face

- to
- face meeting with tribes in Arizona who were concerned about the potential impact of this rule on their income and water rights. Following that meeting, we held an additional technical meeting on how the EPA’s integrated planning model ( IP M ) is used in the regulatory impact anal ys is ( RI A ) and provided one - on - one consultation with the Navajo Nation, Gi la River Indian Community and the Ak

- Chin Indian Community

. (d ) Effects of Less Frequent Collection If the relevant information were collected less frequently , the EPA would not be reasonabl y assured that a plant is in compliance with the standards. (e) G eneral Guidelines None of the guidelines in 5 CFR 1320.5 are being exceeded. (f ) Confidentiality All information submitted to the a gency for which a claim of confidentiality is made will be safeguarded according to the a gency policies set forth in Title 40 , Chapter 1, part 2, subpart B

– Confidentiality

of Business I nformation (see 40 CFR 2; 41 FR 36902, September 01, 1976; amended b y 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979). (g ) Sensitive Questions This s ection is not applicable because this ICR does not involve matters of a sensitive nature. **4. The Respondents and the Information Requested**  (a ) Respondents/NAICS C odes In the amendments, respondents are 1,2 44 owners or operators of existing electric generating units

. It is estimated that 2 new electric generating units will be built each year . All respondents will be subject to the monitoring, recordkeeping, and reporting requirements

. The NAI CS code for this industry is 221100, Electric Power Generation, Transmission and Distribution.

## 4

(b ) Information Requested (i ) Data Items, Including Recordkeeping Requirements. Table 1 summarizes the final recordkeeping and reporting requirements. The EPA is including in Ex hibit 1a, Exhibit 1b, and Exhibit 1c, an estimate of the burden associated with performing an affirmative defense. The EPA is providing this as an illustrative example of the potential additional administrative burden a source may incur to assert in an Aff irmative Defense in response to an action to enforce the standards set forth in the applicable subpart. This illustrative estimate is not considered a duplicate estimate of cost under the General Duty to Minimize Emissions clause under 63.6(e)(1)(i), whic h states: “At all times, the owner and operator must operate and maintain an y affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safet y and good air pollution control practices for m inimizing emissions. Determining whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.” To provide the public with an estimate of the relative magnitude of the burden associated with an assertion of the affirmative defense position adopted by a source, t he EPA provides an administrative adjustment to this I CR that estimates the costs of the notification, recordkeeping and reporting requirements associated with the assertion of the affirmative defense. The EPA’s estimate for the required notification, repo rts and records, including the root cause anal ys is, associated with a single incident totals approximately $3,141 and is based on the time and effort required of a source to review relevant data, interview plant employees, and document the events surroundi ng a malfunction that has caused an exceed a nce of an emission limit. The estimate also includes time to produce and retain the records and reports for submission to the EPA. The EPA provides this illustrative estimate of this burden because these costs are only incurred if there has been a violation and a source chooses to take advantage of the affirmative defense. Of the number of excess emission events reported by source operators, onl y a small number would be expected to result from a malfunction, and only a subset of excess emissions caused b y malfunctions would result in the source choosing to assert the affirmative defense. Thus we believe the number of instances in which source operators might be expected to avail themselves of the affirmative de f ense will be extremely

small. For this reason, we estimate no more than 2 or 3 such occurrences for all sources within a given category over the 3

- ye ar period covered b y this ICR. For the purpose of this estimate, we are adding two (2) instances of affirm ative defense. We expect to gather information on such events in the future and will revise this estimate as better information becomes available. **Table 1. Source Data and Information Requirements**

**Requirement Regulation Citation**  **Notifications** Notification of Demonstration of CEMS 63.10030 Notification of Initial Performance Test 63.10030 Quality Assurance Program Notification 63.10030

## 5

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 Sem i

- 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, malfunctions, etc 63.10032 Existing Sources

- Records of monthly fuel use 63.10032 

## (ii) Respondent Activities. The respondent activities required b y the final NESHAP are introduced in section 6(a). While multiple coal

- fired EGUs have recently commenced operation and several are presentl y 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 In formation 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 in dication that in the near term few new coal

- fired EGUs will be subject to the N ESHAP. For the electric utility sector, the EPA used the IP M to project the number of new coal

- fired power plants that will be installed in the next decade

. The current version of I PM used for the C ross - State Air Pollution Rule (CSAPR) and the EGU NESHAP rules predicts 2,000 MW of new near term (i.e., b y 2015) coal

- fired capacity additions

. All of this capacity is assumed to include carbon capture and storage that is funded by so me government mechanism

. Although none of this capacit y is specifically identified, to be consistent with the various regulations impacting the utility sector we project that two new 500 MW coal

- fired facilities will be subject to the standards for new EGU s.. We used engineering judgment to predict that these new units are likel y to be one pulverized coal bituminous coal

fired unit and one pulverized coal subbituminous coal

- fired unit . B ecause of fuel supply availability

and cost considerations, we assumed that no new oil

- fired electric utility steam generating units will be built during the next 5 y ears. (iii) Electronic Reporting. U tility units have the option of submitting to an EPA electronic database an electronic copy of their required stack test

. Th is electronic database should become available as of December 31, 2011

. Currently , sources are using monitoring equipment that provides automated parameter data (e.g., continuous opacity monitoring)

. Although personnel at the affected facility must evaluat e these data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping

. In addition, some regulatory agencies are setting up electronic reporting sy stems to allow sources to report such data electr onically which also reduces the reporting burden

. It is estimated that approximately 10 percent of the respondents currentl y use electronic reporting.

## 6

**5. The Information Collected: Agency Activities, Collection Methodology, and**  **Information Management** (a ) Agency Activities The EPA conducts the activities in Table 2 in connection with the acquisition, anal ys is, storage, and distribution of the required information. **Table 2. 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 properl y installed and operated

. Performance test reports are used b y t he a gency 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 id entification, as a check on source operation and maintenance, and for compliance determinations. The i nformation ob tained is then entered into the AI RS Facility Subsy stem (AFS) which is operated and maintained by the EPA’s Office of Compliance

. AFS is the 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

. The EPA uses the AFS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters

. The EPA and its delegated Authorities can edit, store, retrieve, and anal yz e the data. The records required b y t his regulation must be retained by the owner or operator for five ye ars. (c) Small Entity Flexibility During this rulemaking, we conducted outreach to small entities and convened a Small Business Advocacy

Review (SBAR) Panel to obtain advice and recommendation s from representatives of the small entities that potentially would be subject to the requirements of this rule

. As part of the SBAR Panel process we conducted outreach with representatives from various small entities that would be affected b y this proposed rule

. We 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 industries/sectors

. We distributed outreach materials to the SERs; these materials included 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

. We met with SERs that will be impacted directl y b y this proposed rule to discuss the outreach materials and

## 7

receive feedback on the approaches and alternatives detailed in the outreach packet

. The SB AR Panel received written comments from the SE Rs in response to discussions at the meeting and the questions posed to the SERs by the Agency

. The SERs were specifically asked to provide comment on regulatory

alternatives that could help to minimize the rule’s impact on small businesses. (d ) Collection Schedule The specific frequenc ies for each information collection activity within this request are shown in Exhibit 1a, Exhibit 1b, and Exhibit 1c: Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Coal

- and Oil

- fired Electric Util ity Steam Generating Units (40 CFR Part 63, Subpart UUUUU) for the first 3 years after promulgation, respectivel y. **6. Estimating the Burden and Cost of the Collection**  Exhibit 1a, Exhibit 1b, and Exhibit 1c document the computation of individual burdens fo r the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR for each of the first 3 y ears . Table 3 contains a summary of the respondent burden hours and costs detailed in Exhibit 1a, Exhibit 1b, and Exhibi t 1c. **Table 3.**  **Summary of Respondent Burden**

**Year Total Annual Labor Burden (hours)**  **Total Annual Labor Costs ($)** 1 699,511 49,063,227 2 700,296 49,118,248 3 701,080 49,173,269 Total 2,100,887 147,354,744 3

- Year Average 700,296 49,118,248


## 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 a gency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. (a ) Estimating Respondent Burden The average annual burden to industry over the next 3 ye ars from these recordkeeping and reporting requirements is estimated to be 700,296 hours per ye ar ( detailed in Exhibit 1a, Exhibit 1b, and Exhibit 1c). These hours are based on a gency studies and background documents from the de velopment of the regulation, a gency knowledge, and experience with the NESHAP program, the previously

approved ICR, and any

comments received. (b ) Estimating Respondent Costs Respondent costs are divided into three categories. These categories include labor costs, operations and maintenance costs, and annualized capital costs

. The total respondent costs of

## 8

$ 207,563,774 were calculated as the sum of the annualized capital costs of $8 1,906,079 (including startup and t he capitol recovery factor costs), the average annual labor costs of $49,118,248 and the annual operation and maintenance costs of $ 76,539,446

. (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 based on the Bureau of Labor Statistics, Occupational Employ ment Statistics, May

200 7 National Industry

- Specific Occupational Employ ment and Wage Estimates . The appr oximate labor rates are $34.31 per hour for technical, $48.14 per hour for managerial, and $16.91 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 $72.05, management at $101.09, and clerical at $35.51. (ii) Estimating Annualized Capital Costs The annualized capital costs associ ated with the information collection requirements will include the costs to conduct performance tests and startup costs for CEMS

. The rule will require an initial performance test for each electric generating unit

. Table 4 shows the methods used for perfor mance tests and the CEMS that are expected to be installed. **Table 4**  **. Performance Test Methods and CEMS Equipment by Pollutant**  **Pollutant Perform**  **ance Test Method CEMS**  PM EPA Method 5 EPA Method 202 Method 29 N ew beta gauge PM CEMS HCl Method 320 N ew FTIR CEMS Hg Method 30B N ew Hg CEMS 

## The costs related to PM and HCl CEMS were estimated using the CEMS Cost Model, which is . The costs related to Hg CEMS were cems.xls http://www.epa.gov/ttn/emc/cem/ located here: estimated using a report developed b y Northeast States for Coordinated Air Use Management (NESCAUM) . The document is titled “ Technologies for Control and Measurement of Mercury Emissions from Coal

- Fired Power Plants in t he United States: A 2010 Status Report ” and is located in the docket for this rulemaking. The annual ized total capital (including startup) costs for CEMS that will be used to monitor PM, Hg, and HCl is $8 1,906,079 per y ear. The costs will be incurred for each ye ar of the three

- ye ar period. Note that these costs are considered “annualized” as they include the cost recovery factor costs in their individual CEMs costs. The specific costs are shown in Table 5 and Table 6. **Table 5. Annual Capital Costs for Per formance Testing**  **EPA Test Method Cost per test**  **Number of Tests Total** 

## 9 Method 29 $ 16,800 1,244 $ 20,899,200 Method 320 $ 20,444 255 $ 5,213,2 87 Method 5 and 202 $ 1 5,522 1,244 $ 1 9,309,376 Method 30B $ 20,006 1,095 $ 21,906,570 **Total (for 3** 
**- year period of ICR)**  $ 67,328,433

**Totals Per Year $ 2**  **2,442,811**



## Table 6. Other Capital Costs of Installing CEMS (Other Direct Costs and Labor)

**CEMS Type**  **C ost per technology**  **Number of installations Total** 

PM $ 6 5,388 1,244 8 1,342,762 HCl $ 111,045 255 28,316, 3 75 Hg $ 17 4,002 395 6 8,730,668

**Total (for 3**
**- year period of ICR)**  $178,389,805

**Totals Per Year**  **59 ,**  **463,268** 

## 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 ty pically utilizes a control device that must have a continuous monitor (e.g., temperature, pressure drop, etc.) to function properl y, and the recordation of additional measurements bey ond the minimum are required b y 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 suc h that the cost of the emissions testing is a capital cost

. It is anticipated that existing electric generating units will use continuous emission monitoring s ys tems (CEMS) for compliance with the proposed PM, Hg, and HCl emission limits

. In itial CEMS testing is usually conducted b y 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 secto r combined with the number of tests required for each ty pe of model plant resulted in a total annualized capital cost of approximately $8 1,906,079 per year for CEMS testing over the next three ye ars. (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 photocop yi ng and postage

. The total annual operations and maintenance costs for CEMS that will be used to monitor PM, Hg, and HCl is $84,182,9 20 per ye ar.

## 10

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 part icular industry ty pically utilizes a control device that must have a continuous monitor (e.g., temperature, pressure drop, etc.) to function properl y, and the recordation of additional measurements bey ond the minimum are required b y the standard, then ther e is 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. **Table 7. Operation and Maintenance Costs CEMS**  **Capital Costs per**  **monitor Total**  **Annual Costs (w/capital recovery)**  **for all installations**

**Labor Testing**  **ODC's Total**  **Labor Testing**  **ODC's Total**  PM $1 3 , 907 $ 24,164 $51,481 $ 89,552 $ 5,766,652 $1 0,019,939 $21,347,602 $ 37,134,193 HCl $23,218 $23,356 $87,826 $134,400 $1,9 73,559 $1,985,220 $7,465,233 $11,424,011 Hg $25,571 $38,514 $14 8 , 431 $2 12 , 516 $3,3 66 ,8 18 $5,071,019 $19, 543,405 $27, 981,242 TOTALS $6 2 , 696 $ 86 ,0 33 $28 7 , 739 $4 36 , 46 8 $1 1,107,029 $17,076,178 $4 8,356,239 $ 76,539,446 

## (iv) Affirmative Defense/Root Cause Analysis/Malfunction Costs. The EPA’s estimate for an affirmative defense and root cause anal ys is in Table 8 is based on general experience to calculate the time and effort required of a source to review relevant data, inter view plant employ ees, and reconstruct the events prior to a malfunction in order to determine primary

and contributing causes. The level of effort also includes time to produce and retain the report in document form so that the source will have it availabl e should EPA or state enforcement agencies ever request to review it. The labor rates used for these costs are from the United States Department of Labor, Bureau of Labor Statistics, September 2009, Table 2. Civilian Workers, by occupational and industry group. The rates are from column 1, Total compensation. The rates have been increased by 110 percent to account for the benefit packages available to those employ ed by private industry

. **Table 8. Burden Associated with Performing an Affirmative Defense**

**Pers onnel**  **Number of Personnel**  **Time**

**Requirement (hours)**  **Total**

**Hours Hourly Rate** 

**($/hr) Total**  Technical Personnel 3 6 18 97.59 $ 1,757 Managerial Personnel 2 6 12 114.77 $ 1,377 Total 5 30 $ 3,134


## (v) 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 $8 1,906,079

.

## 11

(c) Estimating Agency Burden and Cost Because the information collection require ments 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 respondents are required unde r the NESHAP General Provisions, no operational costs will be incurred b y the Federal Government

. Publication and distribution of the information are part of the Compliance Data S ys tem, with the result that no Federal costs can be directly attributed to th e I CR

. 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 I CR. The on ly costs that the Federal government will incur are user costs associated with the anal ys is of the reported information, as presented in Exhibit 2a, Exhibit 2b, and Exhibit 2c

. Table 8 contains a summary of the agency

burden costs and hou r s detailed in Exh ibit 2a, Exhibit 2b, and Exhibit 2c

. The average annual a gency

costs during the 3 ye ars of the I CR is estimated to be $1,798,905. **Table 8**  **. Summary**  **of the Agency Burden Year**  **Total Annual Labor Burden (Hours) Total Annual Costs ($)**  1 36,987 $1,798,905 2 36,987 $1,798,905 3 36,987 $1,798,905 Total 110 , 960 $5 , 396 , 714 3

- Year Average 36,987 $1 , 798 , 905


## The a gency

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), $2 8.88 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

- burd ened 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 1,244 existing electric generating units are curr entl y subject to the current regulation . It is estimated that an additional 2 new electric generating units per year will become subject to the regulation. The total annual number of responses for the new monitoring, recordkeeping, and reporting requireme nts in subpart UUUUU is 3,768 for the existing 1,244 electric generating units that will follow the amendments and the additional 2 newly constructed electric generating units per y ear . The total annual labor costs are $49,11 8,248. Details appear in Exhibi t 1a, Exhibit 1b, and Exhibit 1c.

## 12

(e) Bottom Line Burden Hours and Cost Tables The bottom line burden hours and cost tables for both the a gency and the respondents are attached. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 186 hours per response. The total annual average burden for the rule will be 700,2 9 6 person hours with a total annualized capital/startup cost of $8 1,906,079 and O&M costs of $76,530,446

. (f ) Reasons for Change in Burden. The increase in burden is due to the performance testing, monitoring, recordkeeping, and reporting costs attributable to the new standards for EGUs. The EPA also provides an adjustment to this I CR that estimates the costs of the notification, recordkeeping and reporting requirements associated with the assertion of the affirmative defense. The EPA’s estimate for the required notification, re ports and records, including the root cause anal ys is, associated with a single incident totals approximately $3,141 and is based on the time and effort required of a source to review relevant data, interview plant employ ees, and document the events surroun ding a malfunction that has caused an exceedance of an emission limit. The estimate also includes time to produce and retain the records and reports for submission to the EPA. For the purpose of estimating the annual burden, the EPA is attributing a total of 2 instances of affirmative defense over a 3 ye ar period across all sources in the category

. The EPA is using this frequency of 2 events in 3 ye ars, because of the number of excess emission events reported b y source operators, only a small number would b e expected to result from a malfunction, and only a subset of excess emissions caused by malfunctions would result in the source choosing to a ssert the affirmative defense. Thus we believe the number of instances in which source operators might be expected to avail themselves of the affirmative defense will be extremely small. (g ) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 186 hours per response. Burden means the total tim e, effort, or financial resources expended b y 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 sy stems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 re quired to respond to a collection of information unless it display s 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 a gency '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, the EPA has established a public docket for this ICR under D ocket 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 I nformation

## 13

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 holiday s . The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Air and Rad iation 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 electronicall y . When in the sy stem, select “search,” then key in the Docket ID Number identified above

. Also, y ou can send comments to the Office of In formation and Regulatory Affairs, O ffice 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

- 200 9

- 0 234 in an y correspondence. **PART B** This section is not applicable because statistical meth ods are not used in data collection associated with the final amendments.

## 14 ATTACHMENTS

Exhibit 1a. Year 1 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric Generating Units (40 CFR part 63, subpart UUUUU) Exhibit 1b. Yea r 2 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric Generating Units (40 CFR part 63, subpart UUUUU) Exhibit 1c. Year 3 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric Generating Units (40 CFR part 63, subpart UUUUU) Exhibit 2a. Year 1 Agency Burden and Cost, NESHAP for Electric Generating Units (40 CFR part 63, subpart UUUUU) Exhibit 2b. Year 2 Agency Burden and Cost, NESHAP for Electric Generating Units (40 CFR part 63, subpart UUUUU ) Exhibit 2c. Year 3 Agency Burden and Cost, NESHAP for Electric Generating Units (40 CFR part 63, subpart UUUUU)

## 15

**Exhibit 1a**  **Year 1 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric Generating** 

**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)

Respon dents/ Year (E)

Technical Hours/Year (C x D) (F)

Managerial Hours/Year (E x 0.05) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year 1. APPLI CATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3

. ACQUI SI TI ON, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS a 16 0.6 1 16 0.6 631 101 , 392 .1 5 , 06 9.6 10 , 1 39.2 $ 8 , 1 77 , 965 4. REPORT REQUI REMENTS A. Read In structions Existing Sources 1 1 1 86 5 86 5 43.2 86. 5 $ 69 , 741 New So urces 1 1 1 2 2.0 0.1 0.2 $1 61 B. Required Activities Existing Sources

- In itial Performance Test using M5 and M202 2 7.8 1 2 7.8 415 11 , 527.7 576.4 1 , 152.8 $ 929 , 790 Exi sting Sources

- In itial Performance Test using M29 2 7.8 1 2 7.8 41 5 11 , 527.7 5 76.4 1 , 152.8 $ 929 , 790 Existing Sources

- In itial Performance Test using M320 2 6. 4 1 2 6. 4 85 2 , 2 44 11 2.2 22 4.4 $ 1 80,994 Exi sting Sources

- In itial Performance Test using M 30B 2 7.8 1 2 7.8 365 10 , 147 .0 507.4 1 , 014.7 $ 818 , 425 Existing Sources

- Repeat M5 and M 202 performance test every year 2 7.8 1 2 7.8 415 11,5 27.7 576.4 1,15 2.8 $ 9 29,790 Exi sting Sources

- Repeat M29 performance test every year 2 7.8 1 2 7.8 0

- - - $0 Existing Sources

- Repeat M320 Performance Test every year 2 6. 4 1 2 6. 4 8 5 2,2 44 11 2.2 22 4.4 $ 1 80 , 994 Exi sting Sources

- Repeat M 30B Performance Test every year 2 7.8 1 2 7.8 365 10,147 507.4 1 , 014.7 $ 818,425 Exi sting Sourc es - CEMS Quarterly Inspections 2 .5 4 10 865 8 , 64 6.7 432 .3 864 .7 $ 69 7 , 412 Existing Sources

- CEM S Daily Calibration Drift Tests 0. 4 3 65 146 865 126 , 241 6 , 3 12.1 12 , 6 24.1 $ 10 , 1 82,222 Existing Sources

- Daily monitoring (CEMS) 0. 25 3 65 9 1.25 865 78 , 900.8 3 , 94 5 7 , 8 90.1 $ 6 , 3 63,889 Exi sting Sources

-- All CEMS must follow appropr iate performance specifications 14 1 14 865 12, 105.3 60 5.3 1 , 2 10.5 $ 97 6 , 377

## 16 **Year 1** (A) Hours per Occurrence (B)

Occurrences/ Respondent/Year (C) Hours/

Respondent/ Year (A x B) (D)

Respon dents/ Year (E)

Technical Hours/Year (C x D) (F)

Managerial Hours/Year (E x 0.05) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year New Sources

- In itial Performance Test using M5 and M202 2 7.8 1 2 7.8 2 55.6 2. 78 5.56 $4, 485 New Sources

- In itial Performance Test using M29 2 7.8 1 2 7.8 2 55.6 2. 78 5.56 $4, 485 New Sources

- In itial Performance Test using M 26A 2 6.4 1 2 6.4 2 52.8 2. 6 5.3 $4, 259 New Sources

- In itial Performance Test using M6A 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Repeat M5 and 202 performance test every year 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Repeat M29 performance test every year 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Repeat M 26A Performance Test every year 2 6. 4 1 2 6. 4 0

- - - $0 New Sources

- Repeat M6A Performance Test every year 2 7.8 0 0 0

- - - $0 New Sources

- CEMS Monitoring 0 1 0 2

- - - $ 0 New Sources

- CEMS Quarterly I nspections 2 .46 4 9.84 2 1 9.7 1 2 $1,5 8 7 New Sources

- CEMS Daily Calibration Drift Tests 0. 121 3 65 44.165 2 88.3 4.4 8 .8 $ 7 , 124 New Sources

- Daily monitoring (CEMS ) 0 3 65 0 2

- - - $ 0 New Sources

-- All CEMS must follow appropriate performance specifications 7 .3 3 65 2 , 664.5 2 5 , 329 266.5 532.9 $ 429 , 820 C. Create I

nformation (I

ncluded in 4B)

- - - $0 D. Gather Existing I

nformation (I

ncluded in 4E)

- - - $0 E. Write Report

- - - $0 Existing Sources

- Notification of Demonstration of CEMS 5 1 5 865 4 , 32 3.3 216 .2 432 .3 $ 348 , 706 Exi sting Sources

- Report of Performance Test (included in 4B)

- - - $0 Existing Sources

- Notificat ion of I nitial Performance Test 3 1 3 865 2 , 594 129.7 259.4 $ 209 , 224 Exi sting Sources

- Quality Assurance Program Notification 4 1 4 865 3 , 458.7 172.9 345.9 $ 278 , 965 Existing Sources

- Startup, shutdown, and malfunction Report b 10 1 10 86. 5 864 .7 43.2 86. 5 $ 6 9, 741

## 17 **Year 1** (A) Hours per Occurrence (B)

Occurrences/ Respondent/Year (C) Hours/

Respondent/ Year (A x B) (D)

Respon dents/ Year (E)

Technical Hours/Year (C x D) (F)

Managerial Hours/Year (E x 0.05) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year Exi sting Sources

- Semi

- Annual Compliance Report 75 2 150 865 129 , 7 00 6 , 48 5 12 , 9 7 0 $1 0 , 4 61 , 1 87 Existing Sources

- Notification of Compliance Status 16.5 1 16.5 865 1 4 , 2 67 71 3.4 1 , 42 6.7 $1 , 1 50 , 731 Exi sting Sources

- site

- specific performance evaluation test plan 2 0 1 2 0 865 1 7 , 293 8 64 .7 1 , 72 9.3 $1, 39 4 , 825 Existing Sources

- request to use alternative monitoring procedure 5 1 5 86.5 432 .3 21.6 43.2 $ 34 , 8 71 New Sources

- In itial notification 3 1 3 2 6 0. 3 0. 6 $ 484 New Sources

- Notification of Demonstration of CEMS 5 1 5 2 10 0. 5 1 $ 807 New Sources

- Quality Assurance Program Notification 3 1 3 2 6 0 .3 0. 6 $ 484 New Sources

- Notification of I nitial Performance Test 4 1 4 2 8 0. 4 0. 8 $ 645 New Sources

- Report of Performance Test (included in 4B)

- - - $0 New Sources

- Startup, shutdo wn, and malfunction Report b 10 1 10 0.2 2 0.1 0. 2 $ 161 New Sources

- Semi

- Annual Compliance Report 75 2 150 2 300 15 30 $ 24 , 197 New Sources

- Notification of Compliance Status 16.5 1 16.5 2 33 1.7 3.3 $ 2 , 662 New Sources

- site

- specific performance evaluation test plan 2 0 1 2 0 2 40 2 4 $ 3 , 226 New Sources

- request to use alternative monitoring procedure 5 1 5 0.2 1.0 0.1 0.1 $ 81 Af firmative Defense 30 1 30 2.0 36 24

- $6,268 5. RECO RDKEEPI

NG REQUI REMENTS

- - - $0 A. Read I nstructions (I

ncluded in 4A)

- - - $0 B. Plan Activities (I

ncluded in 4B)

- - - $0 C. I mplement Activities (I

ncluded in 4B)

- - - $0 D. Record Data ( Not Applicable)

- - - $0 E. Time to Transmit or Disclose I nformation

- - - $0 Existing Sources

- Records of CEMS malfunctions 1 1 2 1 2 865 10 , 3 76 518. 8 1 , 03 7.6 $ 836 , 895

## 18 **Year 1** (A) Hours per Occurrence (B)

Occurrences/ Respondent/Year (C) Hours/

Respondent/ Year (A x B) (D)

Respon dents/ Year (E)

Technical Hours/Year (C x D) (F)

Managerial Hours/Year (E x 0.05) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year Existing Sources

- Records of Startups, Shutdowns, malfunctions, etc 1 1 2 1 2 865 10 , 376 518.8 1,03 7. 6 $ 836, 895 Existing Sources

- Records of monthly fuel use 2 1 2 24 865 20 , 7 52 1,03 7

. 6 2,07 5.2 $ 1,67 3 , 790 New So urces - Records of CEMS malfunctions 1 1 2 12 2 24 1 .2 2.4 $ 1,936 New Sources

- Records of Startups , Shutdowns, malfunctions, etc 1 1 2 1 2 2 24 1 .2 2.4 $ 1,936 New Sources

- Records of monthly fuel use 2 1 2 24 2 48 2 .4 4.8 $ 3,872 F. Time to Train Personnel 80 1 8 0 2 160 8 1 6 $ 12,905 G. Time for Audits (Not Applicable)
TOTAL ANNUAL LABOR BURDEN AND COST 1 , 94 6 15, 09 6 608,2 55 30, 4 35 60, 822 $ 49,0 63 , 227 69 9 , 5 1 1 Hours ANNUAL IZED CA PI TAL COSTS Performance tests $ 22,442,811 Other Capital Costs of I

nstallation (ODC and Labor) $ 59,463,268 Total annual capital $ 81,906,079 TOTAL ANNUAL COSTS (O&M) $ 76,539,446 TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $ 158,445,526 a 

### There are 1,2 4 4 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.

## 19

**Exhibit 1b**  **Year 2 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric Generating** 

**Units (40**  **CFR part 63, subpart UUUUU)** 

**Year 2** (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) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year 1. APPLI CATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3

. ACQUI SI TI ON, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS a 16 0.6 1 16 0.6 63 3 101, 606 5,0 80 10,1 61 $ 8,1 95,236 4. REPORT REQUI REMENTS A. Read I nstructions Existing Sources 1 1 1 865 865 43 86.5 $ 69,795 New So urces 1 1 1 2 2.0 0.1 0.2 $1 61 B. Required Activities Existing Sources

- In itial Performance Test using M5 and M202 2 7.8 1 2 7.8 415 11,5 46 57 7.3 1,15 5 $ 9 31 , 285 Existing Sources

- In itial Performance Test using M29 2 7.8 1 2 7.8 41 5 11,5 46 5 7 7.3 1 ,15 5 $ 9 31 , 285 Existing Sources

- In itial Performance Test using M320 2 6. 4 1 2 6. 4 85 2,2 62 11 3.1 22 6 $ 18 2,413 Exi sting Sources

- In itial Performance Test using M 30B 2 7.8 1 2 7.8 36 6 10,1 66 50 8.3 1,01 7 $ 81 9,919 Exi sting Sources

- Repeat M5 and M 202 performance test every year 2 7.8 1 2 7.8 415 11,5 46 57 7.3 1,15 5 $ 9 31,285 Exi sting Sources

- Repeat M29 performance test every year 2 7.8 1 2 7.8 0

- - - $0 Exi sting Sources

- Repeat M320 Performance Test every year 2 6. 4 1 2 6. 4 85 2,2 62 11 3.1 22 6 $ 18 2,413 Exi sting Sources

- Repeat M 30B Performance Test every year 2 7.8 1 2 7.8 36 6 10,1 66 50 8.3 1,01 7 $ 81 9,919 Exi sting Sourc es - CEMS Quarterly Inspections 2 .5 4 10 865 8, 653 432. 7 86 5 $ 697, 950 Exi sting Sources

- CEM S Daily Calibration Drift Tests 0. 4 3 65 146 865 126, 339 6,31 7 12,6 34 $ 10,1 90,073 Exi sting Sources

- Daily monitoring (CEMS) 0. 25 3 65 9 1.25 865 78,9 62 3,94 8.1 7,89 6 $ 6,36 8,795 Existing Sources

-- All CEMS must follow appropr iate performance specifications 14 1 14 865 12,1 15 60 6 1,21 2 $ 97 7,130

## 20 **Year 2** (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) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year New Sources

- In itial Performance Test using M5 and M202 2 7.8 1 2 7.8 2 55.6 2. 78 5.56 $4, 485 New Sources

- In itial Performance Test using M29 2 7.8 1 2 7.8 2 55.6 2. 78 5.56 $4, 485 New Sources

- In itial Performance Test using M 26A 2 6.4 1 2 6.4 2 52.8 2. 6 5.3 $4, 259 New Sources

- In itial Performance Test using M6A 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Repeat M5 and 202 performance test every year 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Re peat M29 performance test every year 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Repeat M 26A Performance Test every year 2 6. 4 1 2 6. 4 0

- - - $0 New Sources

- Repeat M6A Performance Test every year 2 7.8 0 0 0

- - - $0 New Sources

- CEMS Monitoring 0 1 0 2

- - - $ 0 New Sources

- CEMS Quarterly I nspections 2 .46 4 9.84 2 1 9.7 1 2 $1,5 8 7 New Sources

- CEMS Daily Calibration Drift Tests 0. 121 3 65 44.165 2 88.3 4.4 8 .8 $ 7,124 New Sources

- Daily monitoring (CEMS ) 0 3 65 0 2

- - - $ 0 New Sources

-- All CEMS must follow appropriate performance specifications 7 .3 3 65 2,664.5 2 5,329 266.5 532.9 $ 429,820 C. Create I

nformation (I

ncluded in 4B)

- - - $0 D. Gather Existing I

nformation (I

ncluded in 4E)

- - - $0 E. Write Report

- - - $0 Existing Sources

- Notification of Demonstration of CEMS 5 1 5 865 4,32 6 216 433 $ 348, 975 Existing Sources

- Report of Performance Test (included in 4B)

- - - $0 Existing Sources

- Notificat ion of I nitial Performance Test 3 1 3 865 2,59 6 1 30 2 60 $ 209, 385 Exi sting Sources

- Quality Assurance Program Notification 4 1 4 865 3,4 61 17 3 34 6 $ 27 9 , 180 Exi sting Sources

- Startup, shutdown, and malfunction Report b 10 1 10 86.5 86 5 43 86.5 $ 6 9, 7 95

## 21 **Year 2** (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) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year Exi sting Sources

- Semi

- Annual Compliance Report 75 2 150 865 129, 80 0 6,4 90 12,9 8 0 $1 0 , 46 9,253 Exi sting Sources

- Notification of Compliance Status 16.5 1 16.5 865 1 4,2 78 71 4 1,42 8 $1 ,15 1 , 618 Exi sting Sources

- site

- specific performance evaluation test plan 2 0 1 2 0 865 1 7, 307 8 6 5 1,7 31 $1, 39 5 , 900 Exi sting Sources

- request to use alternative monitoring procedure 5 1 5 86.5 433 21.6 43 $ 34 , 8 98 New Sources

- In itial notification 3 1 3 2 6 0. 3 0. 6 $ 484 New Sources

- Notification of Demonstration of CEMS 5 1 5 2 10 0. 5 1 $ 807 New Sources

- Quality Assurance Program Notification 3 1 3 2 6 0 .3 0. 6 $ 484 New Sources

- Notification of I nitial Performance Test 4 1 4 2 8 0. 4 0. 8 $ 645 New Sources

- Report of Performance Test (included in 4B)

- - - $0 New Sources

- Startup, shutdo wn, and malfunction Report b 10 1 10 0.2 2 0.1 0. 2 $ 161 New Sources

- Semi

- Annual Compliance Report 75 2 150 2 300 15 30 $ 24,197 New Sources

- Notification of Compliance Status 16.5 1 16.5 2 33 1.7 3.3 $ 2,662 New Sources

- site

- specific performance evaluation test plan 2 0 1 2 0 2 40 2 4 $ 3,226 New Sources

- request to use alternative monitoring procedure 5 1 5 0.2 1.0 0.1 0.1 $ 81 Af firmative Defense 30 1 30 2.0 36 24

- $6,268 5. RECO RDKEEPI

NG REQUI REMENTS

- - - $0 A. Read I nstructions (I

ncluded in 4A)

- - - $0 B. Plan Activities (I

ncluded in 4B)

- - - $0 C. I mplement Activities (I

ncluded in 4B)

- - - $0 D. Record Data ( Not Applicable)

- - - $0 E. Time to Transmit or Disclose I nformation

- - - $0 Existing Sources

- Records of CEMS malfunctions 1 1 2 1 2 865 10,3 84 51 9 1,03 8 $ 83 7 , 540

## 22 **Year 2** (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) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year Existing Sources

- Records of Startups, Shutdowns, malfunctions, etc 1 1 2 1 2 865 10,3 84 51 9 1,03 8 $ 83 7 , 540 Existing Sources

- Records of monthly fuel use 2 1 2 24 865 20,7 68 1,03 8 2,07 7 $ 1,67 5 , 080 New Sources

- Records of CEMS malfunctions 1 1 2 12 2 24 1 .2 2.4 $ 1,936 New Sources

- Records of Startups , Shutdowns, malfunctions, etc 1 1 2 1 2 2 24 1 .2 2.4 $ 1,936 New Sources

- Records of monthly fuel use 2 1 2 24 2 48 2 .4 4.8 $ 3,872 F. Ti me to Train Personnel 80 1 8 0 2 160 8 1 6 $ 12,905 G. Time for Audits (Not Applicable)
TOTAL ANNUAL LABOR BURDEN AND COST 1,94 6 15, 1 11 608, 9 37 30,4 69 60,8 90 $49, 11 8 , 248 700,2 9 6 Hours ANNUAL IZED CA PI TAL COSTS Performance tests $ 22,442,811 Other Capital Costs of I

nstallation (ODC and Labor) $ 59,463,268 Total annual capital $ 81,906,079 TOTAL ANNUAL COSTS (O&M) $76,539,446 TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $ 158,445,526 a 

### There are 1,2 4 4 existing electric generating units

. One third of those are assumed to be tested each year. b 

### There are 2 additional existing electric generating units that w ere new sources in Year 1. c 

### 10% of sources are assumed to submit SSM report each year.

## 23

**Exhibit 1c**  **Year 3 Respondent Burden of Reporting and Recordkeeping Requirements, NESHAP for Electric Generating** 

**Units (40 CFR part 63, subpart**  **UUUUU )** 

**Year 3** (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) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year 1. APPLI CATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3

. ACQUI SI TI ON, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS a 16 0.6 1 16 0.6 63 4 101, 820 5,0 91 10,1 82 $ 8, 212 , 508 4. REPORT REQUI REMENTS A. Read I nstructions Existing Sources 1 1 1 866 866 43 8 7 $ 69, 849 New Sources 1 1 1 2 2.0 0.1 0.2 $1 61 B. Required Activities Existing Sources

- In itial Performance Test using M5 and M202 2 7.8 1 2 7.8 416 11,5 65 57 8 1,15 7 $ 9 32,780 Existing Sources

- In itial Performance Test using M29 2 7.8 1 2 7.8 41 6 11,5 65 5 7 8 1 ,15 7 $ 9 32,780 Existing Sources

- In itial Performance Test using M320 2 6. 4 1 2 6. 4 86 2,2 79 11 4 22 8 $ 18 3,833 Exi sting Sources

- In itial Performance Test using M 30B 2 7.8 1 2 7.8 366 10,1 8 4 50 9 1,01 8 $ 8 21,414 Exi sting Sources

- Repeat M5 and M 202 performance test every year 2 7.8 1 2 7.8 416 11,5 65 57 8 1,15 7 $ 9 32,780 Exi sting Sources

- Repeat M29 performance test every year 2 7.8 1 2 7.8 0

- - - $0 Exi sting Sources

- Repeat M320 Performance Test every year 2 6. 4 1 2 6. 4 86 2,2 79 11 4 22 8 $ 18 3,833 Exi sting Sources

- Repeat M 30B Performance Test every year 2 7.8 1 2 7.8 366 10,1 84 50 9 1,01 8 $ 8 21,414 Exi sting Sourc es - CEMS Quarterly Inspections 2 .5 4 10 866 8,6 60 433 86 6 $ 69 8,488 Existing Sources

- CEM S Daily Calibration Drift Tests 0. 4 3 65 146 866 126, 436 6,32 2 12,6 44 $ 10,1 97,923 Existing Sources

- Daily monitoring (CEMS) 0. 25 3 65 9 1.25 866 7 9023 3,9 51 7, 902 $ 6,3 7 3, 702 Exi sting Sources

-- All CEMS must follow appropr iate performance specifications 14 1 14 866 12,124 60 6 1,21 2 $ 97 7 , 883 New Sources

- In itial Performance Test using M5 and M202 2 7.8 1 2 7.8 2 55.6 2. 8 5.6 $4, 485

## 24 **Year 3** (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) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year New Sources

- In itial Performance Test using M29 2 7.8 1 2 7.8 2 55.6 2. 8 5.6 $4, 485 New Sources

- In itial Performance Test using M 26A 2 6.4 1 2 6.4 2 52.8 2. 6 5.3 $4, 259 New Sources

- In itial Performance Test using M6A 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Repeat M5 and 202 performance test every year 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Repeat M29 performance test every year 2 7.8 1 2 7.8 0

- - - $0 New Sources

- Repeat M 26A Performance Test every year 2 6. 4 1 2 6. 4 0

- - - $0 New Sources

- Repeat M6A Performance Test every year 2 7.8 0 0 0

- - - $0 New Sources

- CEMS Monitoring 0 1 0 2

- - - $ 0 New Sources

- CEMS Quarterly I nspections 2 .46 4 9.84 2 1 9.7 1 2 $1,5 8 7 New Sources

- CEMS Daily Calibration Drift Tests 0. 121 3 65 44.165 2 88.3 4.4 8 .8 $ 7,124 New Sources

- Daily monitoring (CEMS ) 0 3 65 0 2

- - - $ 0 New Sources

-- All CEMS must follow appropriate performance specifications 7 .3 3 65 2,664.5 2 5,329 266.5 532.9 $ 429,820 C. Cr eate I

nformation (I

ncluded in 4B)

- - - $0 D. Gather Existing I

nformation (I

ncluded in 4E)

- - - $0 E. Write Report

- - - $0 Existing Sources

- Notification of Demonstration of CEMS 5 1 5 866 4,3 30 21 7 433 $ 34 9,244 Exi sting Sources

- Report of Performance Test (included in 4B)

- - - $0 Existing Sources

- Notificat ion of I nitial Performance Test 3 1 3 866 2,59 8 1 30 2 60 $ 209, 546 Existing Sources

- Quality Assurance Program Notification 4 1 4 866 3,4 64 17 3 34 6 $ 27 9 , 395 Exi sting Sources

- Startup, shutdown, and malfunction Report b 10 1 10 86.6 86 6 43 86.6 $ 6 9, 849 Exi sting Sources

- Semi

- Annual Compliance Report 75 2 150 866 129, 9 00 6,4 9 5 12,99 0 $1 0 , 4 77,318

## 25 **Year 3** (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) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year Exi sting Sources

- Notification of Compliance Status 16.5 1 16.5 86 6 1 4,289 71 5 1,42 9 $1 ,15 2 , 505 Exi sting Sources

- site

- specific performance evaluation test plan 2 0 1 2 0 866 1 7, 320 8 6 6 1,7 32 $1, 39 6 , 976 Exi sting Sources

- request to use alternative monitoring procedure 5 1 5 86.6 433 2 2 43 $ 34 , 924 New Sources

- In itial notification 3 1 3 2 6 0. 3 0. 6 $ 484 New Sources

- Notification of Demonstration of CEMS 5 1 5 2 10 0. 5 1 $ 807 New Sources

- Quality Assurance Program Notification 3 1 3 2 6 0 .3 0. 6 $ 484 New Sources

- Notification of I nitial Performance Test 4 1 4 2 8 0. 4 0. 8 $ 645 New Sources

- Report of Performance Test (included in 4B)

- - - $0 New Sources

- Startup, shutdo wn, and malfunction Report b 10 1 10 0.2 2 0.1 0. 2 $ 161 New Sources

- Semi

- Annual Compliance Report 75 2 150 2 300 15 30 $ 24,197 New Sources

- Notification of Compliance Status 16.5 1 16.5 2 33 1.7 3.3 $ 2,662 New Sources

- site

- specific performance evaluation test plan 2 0 1 2 0 2 40 2 4 $ 3,226 New Sources

- request to use alternative monitoring procedure 5 1 5 0.2 1.0 0.1 0.1 $ 81 Af firmative Defense 30 1 30 2.0 36 24

- $6,268 5. RECO RDKEEPI

NG REQUI REMENTS

- - - $0 A. Read I nstructions (I

ncluded in 4A)

- - - $0 B. Plan Activities (I

ncluded in 4B)

- - - $0 C. I mplement Activities (I

ncluded in 4B)

- - - $0 D. Record Data ( Not Applicable)

- - - $0 E. Time to Transmit or Disclose I nformation

- - - $0 Existing Sources

- Records of CEMS malfunctions 1 1 2 1 2 86 6 10,392 5 20 1,03 9 $ 83 8 , 18 5 Exi sting Sources

- Records of Startups, Shutdowns, malfunctions, etc 1 1 2 1 2 86 10,392 5 20 1,039 $ 83 8 , 185

## 26 **Year 3** (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) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/

Year Existing Sources

- Records of monthly fuel use 2 1 2 24 86 6 20,7 84 1,03 9 2,07 8 $ 1,67 6 , 371 New Sources

- Records of CEMS malfunctions 1 1 2 12 2 24 1 .2 2.4 $ 1,936 New Sources

- Records of Startups , Shutdowns, malfunctions, etc 1 1 2 1 2 2 24 1 .2 2.4 $ 1,936 New Sources

- Records of monthly fuel use 2 1 2 24 2 48 2 .4 4.8 $ 3,872 F. Ti me to Train Personnel 80 1 8 0 2 160 8 1 6 $ 12,905 G. Time for Audits (Not Applicable)
TOTAL ANNUAL LABOR BURDEN AND COST 1,94 6 15, 12 7 60 9, 619 30, 503 60,958 $49, 1 73 , 269 701 , 0 8 0 Hours ANNUAL IZED CA PI TAL COSTS Performance tests $ 22,442,811 Other Capital Costs of I

nstallation (ODC and Labor) $ 59,463,268 Total annual capital $ 81,906,079 TOTAL ANNUAL COSTS (O&M) $76,539,446 TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $ 158,445,526 a 

### There are 1,2 4 4 existing electric generating units

. One third of those are assumed to be tested each year. b 

### There are 2 additional existing electric generating units that w ere new sources in Year 1

. c 

### There are 2 additional existing electric generating units that w ere new sources in Year 2

. d 

### 10% of sources are assumed to submit SSM report each year.

## 27

**Exhibit 2a**  **Year 1 Agency Burden and Cost, NESHAP for Electric Generating Units**  **(40 CFR part 63, subpart UUUUU**  **)**

**Activity**
**-- 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) EPA** 

**Clerical Hours/Year**  **(H) Cost, $**  Observe I nitial Performance Tests 24 1 24 173.2 4,156.8 207.84 41.57 $ 206,060 Observe Repeat Performance Tests 24 0.2 4.8 173.2 831.36 41.57 8.31 $ 41 , 212 Review Notifi cation of Demonstration of CEMS 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review Quality Assurance Program Notification 0.5 1 0.5 866 433 21.65 4.33 $ 2 1,465 Review Startup, shutdo wn, and malfunction Report 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review Notification of Compliance Status 0.5 1 0.5 866 433 21.65 4.33 $ 2 1,465 Review requests to use alternative monitoring procedure 0.5 1 0.5 866 433 21.5 4.33 $ 2 1,465 Review I nitial Notifications 0.5 1 0.5 2.00 1 0.05 0.01 $ 50 Review Notification of performance test 0.5 1 0.5 866 433 21.65 4.33 $ 2 1 , 465 Review Test/CEMS Results 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review site specific performance evaluation test plan 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review Semi

- Annual reports 8 1 8 866 6,928 346.4 69.28 $ 343,433 Total Annual Hours 3 4 , 866 1, 743 348 $ 1, 728,374 3 6 , 958 H ours Travel Expenses $ 69 , 2 00 $ 1, 797,574 

### EPA Officials are assumed to attend 20% of performance tests (0.20 * 866 = 173.2) Travel Expenses = (1 person x 173 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 173 plants/year) = $69,200/year Assume visit 173 plants per year

## 28

**Exhibit 2b**  **Year 2 Agency Burden and Cost, NESHAP for Electric Generating Units**  **(40 CFR par t 63, subpart**  **UUUUU )** 

**Activity**
**-- 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) EPA**

**Clerical Hours/Year**  **(H) Cost, $** Observe I nitial Performance Tests 24 1 24 84.13 2019.2 100.96 20.192 $ 100,095 Observe Repeat Performance Tests 24 0.2 4.8 84.13 403.84 20.192 4.0384 $ 20,019 Review Notification of Demonstration of CEMS 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review Quality Assurance Program Notification 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review Startup, shutdown, and malfunction Report 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review Notification of Compliance Status 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review requests to use alternative monitoring procedure 0.5 1 0.5 866 433 21.5 4.33 $ 21,465 Review I nitial Notifications 0.5 1 0.5 2.00 1 0.05 0.01 $ 50 Review Notification of performance test 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review Test/CEMS Results 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review site specific performance evaluation test plan 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review Semi

- Annual reports 8 1 8 866 6,928 346.4 69.28 $ 343,433 Total Annual Hours 32,301 1,615 323 $ 1,601,217 34,239.1 Hours Travel Expenses $ 69,200 $ 1,670,417 

### EPA Officials are assumed to attend 20% of performance tests (0.20 * 866 = 173.2) Travel Expenses = (1 person x 173 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 173 plants/year) = $69,200/year Assume visit 173 plants per year

## 29

**Exhibit 2c**  **Year 3**  **Agency Burden and Cost, NESHAP for Electric Generating Units**  **(40 CFR p art 63, subpart**  **UUUUU )** 

**Activity**
**-- Year**  **3 (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) EPA**  **Clerical Hours/Year**  **(H) Cost, $** Observe I nitial Performance Tests 24 1 24 84.13 2019.2 100.96 20.192 $ 100,095 Observe Repeat Performance Tests 24 0.2 4.8 84.13 403.84 20.192 4.0384 $ 20,019 Review Notification of Demonstration of CEMS 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review Quality Assurance Program Notification 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review Startup, shutdown, and malfunction Report 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review Notification of Compliance Status 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review requests to use alternative monitoring procedure 0.5 1 0.5 866 433 21.5 4.33 $ 21,465 Review I nitial Notifications 0.5 1 0.5 2.00 1 0.05 0.01 $ 50 Review Notification of performance test 0.5 1 0.5 866 433 21.65 4.33 $ 21,465 Review Test/CEMS Results 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review site specific performance evaluation test plan 8 1 8 866 6,928 346.4 69.28 $ 343,433 Review Semi

- Annual reports 8 1 8 866 6,928 346.4 69.28 $ 343,433 Total Annual Hours 32,301 1,615 323 $ 1,601,217 34,239.1 Hours Travel Expenses $ 69,200 $ 1,670,417 

### EPA Officials are assumed to attend 20% of performance tests (0.20 * 866 = 173.2) Travel Expenses = (1 person x 173 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 173 plants/year) = $69,200/year Assume visit 173 plants per year