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Appendix B: SUMMARY OF COMMENTS ON THE PUBLIC NOTICE FOR THE PROPOSED INFORMATION COLLECTION FOR THE STEAM ELECTRIC POWER GENERATING EFFLUENT GUIDELINES AND EPA’S RESPONSE

LIST OF TABLES

Page

Table 2-1. Number of Questionnaire Respondents (Plant Level Counts) 2-2

Table 4-1. Steam Electric Power Plant Operations Question Justifications 4-2

Table 4-2. FGD System Question Justifications 4-9

Table 4-3. Ash Handling Question Justifications 4-13

Table 4-4. Pond/Impoundment Systems and Other Wastewater Treatment Operations Question Justifications 4-22

Table 4-5. Wastes from Cleaning Metal Process Equipment Question Justifications 4-26

Table 4-6. Management Practices for Pond/Impoundment Units and Landfills Question Justifications 4-28

Table 4-7. Leachate Sampling Data for Pond/Impoundments and Landfills Question Justifications 4-32

Table 4-8. Nuclear Power Question Justifications 4-33

Table 4-9. Economic and Financial Data Question Justifications 4-35

Table 4-10. Number of Questionnaire Respondents 4-36

Table 5-1. NAICS Codes and SBA Size Standards for Entities with a Primary Business Other Than Electric Power Generation 5-3

Table 5-2. Collection Schedule 5-4

Table 6-1. Economic and Financial Data Burden Estimates for Part I 6-3

Table 6-2. Estimated Respondent Hours per Section of the Questionnaire 6-4

Table 6-3. Estimated Respondent Hours per Part of the Questionnaire 6-7

Table 6-4. Estimated Respondent Burden (Hourly) per Type of Plant 6-7

Table 6-5. 2009 Labor Rate Data 6-8

Table 6-6. Total Estimated Respondent Burden 6-9

Table 6-7. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire 6-10

Table 6-8. Total Capital/Start-up Operating and Maintenance Costs for Sampling 6-10

Table 6-9. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire 6-10

Table 6-10. Agency Burden and Costs 6-11

Table 6-11. Total Estimated Respondent Burden and Cost Summary 6-12

Table 6-12. Total Estimated Agency Burden and Cost Summary 6-12

Table 6-13. Annual Estimated Burden and Cost Summary 6-12

PART A OF THE SUPPORTING STATEMENT

1.IDENTIFICATION OF THE INFORMATION COLLECTION

1.a)Title of the Information Collection

U.S. Environmental Protection Agency

Questionnaire for Steam Electric Power Generating Effluent Guidelines

EPA ICR No. 2368.01

OMB Control No. 2040-NEW

1.b)Short Characterization/Abstract

The United States Environmental Protection Agency (EPA), through this Information Collection Request (ICR) package, requests that the Office of Management and Budget (OMB) review and approve the ICR for Steam Electric Power Generating Effluent Guidelines. Through this collection, EPA will obtain data essential to the review and revision of the Steam Electric Power Generating effluent limitations guidelines and standards (ELGs) (40 CFR Part 423).

EPA first identified the industry during its 2005 annual review of discharges from categories with existing effluent guidelines regulations, when publicly available data indicated that this industry ranked high in discharges of toxic and nonconventional pollutants. Because of these findings, EPA initiated a more detailed study of the industry and collected data through site visits, wastewater sampling, a limited data request, and secondary sources of data. EPA determined that steam electric power plants are responsible for a significant amount of the toxic pollutant loadings discharged to surface waters by point sources. Further information regarding these conclusions can be found in EPA’s study, Steam Electric Power Generating Point Source Category: Final Detailed Study Report (EPA 821-R-09-008). This ICR will support the review and revision of the Steam Electric ELGs.

EPA’s Office of Water will administer the Steam Electric ICR (questionnaire) to power plants regulated by the steam electric ELGs codified at 40 CFR Part 423. The questionnaire (located in Appendix A) will be distributed to all coal- and petroleum coke-fired power plants and a statistically sampled subset of the rest of the steam electric industry, including oil-fired, gas-fired, and nuclear power plants. Therefore, many power plants will not receive the questionnaire. The questionnaire consists of several sections that have been tailored to address specific processes, specific data needs, or types of power plants. Parts A and I of the questionnaire will be sent to all questionnaire recipients; the remaining sections will be sent to discrete subpopulations of questionnaire recipients. By structuring the questionnaire in this manner, EPA will obtain information on specific aspects of power plant operations, while at the same time balancing the need for data with minimizing the number of respondents and the burden imposed by the questionnaire.

Part A of the questionnaire will collect general plant information and selected technical information about the plant processes and the electric generating units. Additional sections of the questionnaire are designed to collect economic data and to collect technical information on flue gas desulfurization (FGD) wastewater, ash handling, cleaning of metal process equipment, wastewater treatment, surface impoundment and landfill operations, and nuclear operations. One section of the questionnaire will also require certain power plants to collect and analyze samples of leachate from ponds/surface impoundments and landfills containing coal combustion residues. All respondents will be required to complete and submit an electronic version of the questionnaire.

EPA has identified approximately 1,200 fossil- and nuclear-fueled steam electric power plants that are potentially within scope of the data collection objectives of the questionnaire. To reduce burden on the industry, EPA intends to distribute the questionnaire to a statistically-sampled subset of these facilities. Approximately 734 fossil- or nuclear-fueled steam electric plants will be required to complete Parts A and I of the questionnaire. This total includes approximately 495 coal-fired, 9 petroleum coke-fired, 20 oil-fired, 168 gas-fired, 20 nuclear power plants, and 22 combination power plants. For the purpose of this data collection, combination power plants refer to plants that have at least two generating units that have different unit-level fuel classifications (e.g., gas and oil, gas and gas-combined cycle) and do not operate generating units fueled by coal or petroleum coke. One or more of these subpopulations will also be required to fill out certain additional detailed sections (for some sections of the questionnaire, the coal-fired respondents will be reduced to a subset of approximately 94 plants).

EPA has determined that the data obtained through the Steam Electric ICR is necessary for EPA to review and revise the ELGs for the steam electric industry. The ICR will obtain information about steam electric power generating industry operations for use in characterizing waste streams and the processes that generate the wastes, environmental data, and the availability and affordability of technologies that may be used to reduce wastewater pollutant discharges associated with this industry. These data will be used to perform detailed technical and economic analyses that will support EPA’s potential development of numerical limitations or best management practices for wastewaters generated by steam electric plants.

The steam electric industry will devote time and resources to respond to the Steam Electric ICR. EPA estimates that the total burden to the 734 steam electric power plants for responding to the questionnaire will be approximately 144,451 hours, or $ 9,228,948 (including labor and O&M costs). The collection design represents EPA’s efforts to gather sufficient data to perform the analysis required to accurately review and revise the steam electric ELGs, yet at the same time administer an ICR that limits the burden placed on respondents.

2.NEED FOR AND USE OF THE INFORMATION COLLECTION

2.a)Need/Authority for the Information Collection

The objective of the Clean Water Act is to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters. To help meet this objective, the CWA directs EPA to develop and issue ELGs for categories of point sources discharging to waters of the U.S.

Under the authority of Section 308 of the Clean Water Act (Federal Water Pollution Control Act, 33 U.S.C. Section 1318), EPA’s Office of Water has begun an effort to develop revised ELGs for wastewater discharges from the steam electric power generating industry. The steam electric industry has undergone significant changes since the ELGs were last revised in 1982. For example, since that time, many power plants have installed FGD scrubbers to treat flue gas from their coal-fired units, generating a scrubber purge waste stream containing high concentrations of selenium, mercury, arsenic, and other pollutants of concern. EPA plans to administer a questionnaire to a statistical subset of the steam electric industry to collect general plant information, as well as additional economic and detailed technical data necessary to support technical analyses that will be used to develop revised ELGs.

EPA will use the questionnaire data (along with information obtained from other sources consulted over the course of the rulemaking) to develop an industry profile, and to assess the pollutant reductions, costs, and economic achievability of candidate pollution control technologies, management practices, and process changes. This information is necessary to fulfill requirements established by the Clean Water Act and to inform Agency decision making about the appropriate course of regulatory action to address the pollutants present in wastewater discharges from power plants. EPA compiled certain information through a recently-completed study of the steam electric power generating industry and through public sources of information, but was not able to obtain the detailed plant-level and generator-level data that will be collected through this questionnaire.

2.b)Practical Utility/Users of the Data

(i)General Use of the Data

EPA plans to use a questionnaire, consisting of multiple detailed sections, to solicit information from the steam electric industry. EPA will use the information collected from the survey to gain knowledge of current steam electric processes, characterize and quantify the pollutants currently discharged by the industry, and assess technical and economic achievability of available controls and potential environmental impacts. The information collected will provide EPA with owner/operator-level, plant-level, and/or generating unit-level data on processes, production, and costs that complement, and go beyond, data that are available from public sources.

The steam electric questionnaire is designed to collect the following information. Part A of the questionnaire focuses on gathering general information from all coal- and petroleum coke-fired power plants and a subset of the oil-, gas-, and nuclear-fueled steam electric plants. Part A gathers information on all steam electric generating units at the surveyed plant, the fuels used to generate electricity, air pollution controls, cooling water, an inventory of ponds/impoundments and landfills used for coal combustion residues, coal storage and processing, and outfall information.

Parts B through I collect economic data and detailed technical information on certain aspects of power plant operations, including requiring some plants to collect and analyze wastewater samples. These parts, depending on the specific section, will be sent to either all or a subset of coal- or petroleum coke-fired plants, and a statistical subset of the oil-, gas-, and nuclear-fueled power plants. The planned distribution of the questionnaire parts to plant respondents is illustrated by Table 2-1. Parts B through I will collect information on the following topics:

Part B: FGD systems;
Part C: Ash handling;
Part D: Pond/impoundment systems and other wastewater treatment operations;
Part E: Wastes from cleaning metal process equipment;
Part F: Management practices for ponds/impoundments and landfills;
Part G: Leachate sampling data for ponds/impoundments and landfills;
Part H: Nuclear power generation; and
Part I: Economic and financial data.

Table 2-1. Number of Questionnaire Respondents (Plant Level Counts)

Questionnaire Part	Steam Electric Power Plants by Fuel Type
Questionnaire Part	Coal	Petroleum Coke	Oil	Gas ^a	Nuclear	Combination ^b	Total
Estimated population of fossil/ nuclear steam electric plants	495	9	43	561	63	32	1,203
Total number of respondents	495	9	20	168	20	22	734
Part A: Power plant operations	495	9	20	168	20	22	734
Part B: FGD systems	495 ^c	9 ^c	20 ^c	—	—	22 ^c	546 ^c
Part C: Ash handling	495	9	20	—	—	22	546
Part D: Ponds/treatment	495	9	20	—	—	22	546
Part E: Cleaning wastes	94	3	20	168	20	22	327
Part F: Management practices	94	3	—	—	—	—	97
Part G: Leachate sampling	94 ^d	3^d	—	—	—	—	97^d
Part H: Nuclear power	495 ^e	9 ^e	20 ^e	168 ^e	20 ^e	22 ^e	734 ^e
Part I: Economic data	495	9	20	168	20	22	734

a – The “Gas” fuel type includes plants classified as “Gas” and plants classified as “Gas Combined Cycle.” See Part B of the Supporting Statement for further information on the different fuel type categories.

b – Combination plants operate at least two generating units that use different types of fuel, but do not operate units fueled by coal or petroleum coke. The specific questionnaire parts that will be completed by these plants are dependent on the operations and types of units present. See Table B-3, in Part B of the Supporting Statement, for a more specific break out of combination plants.

c – Number of plants is a maximum. Part B will only be completed by plants operating or planning to install FGD systems. EPA estimates 242 plants (less than half of coal, petroleum coke, and oil plants) will need to complete Part B.

d – EPA estimates that 97 plants will receive Part G, but only about 30 percent of respondents (~30 plants) actually operate leachate collection systems and would therefore collect and analyze wastewater samples.

e – Part H will be distributed to all respondents in the scope of the questionnaire; however, very few coal-, petroleum coke-, oil-, and gas-fired power plants receiving the questionnaire will also have nuclear generating units (e.g., EPA estimates only two coal-fired power plants have one or more nuclear units).

For EPA to determine appropriate revisions to the steam electric ELGs, EPA needs to gather information on steam electric generating units and the processes currently operated at plants. EPA also needs information on pollutants being discharged in power plants wastewaters, including wastewater from FGD systems, ash handling systems, process equipment cleaning operations, cooling water, and leachate collection systems. EPA also needs information about the wastewater treatment systems operated at power plants, and the availability and pollutant removal efficacy of new technologies or best management practices (BMPs) for the industry. In addition, EPA needs information to determine the costs and affordability of new technologies and/or BMPs, both for existing technologies and technologies implemented in the future. EPA will use the information collected by the questionnaire to address these factors and determine appropriate revisions to the ELGs.

Note that in revising the ELGs, EPA may decide to take different actions for different subcategories or segments of the industry. For example, certain regulations may be revised for a specific segment of the steam electric industry (e.g., regulations for oil-fired plants vs. nuclear plants).

Specifically, EPA will use information gathered throughout the questionnaire to:

Properly characterize and classify the steam electric industry. EPA may determine it is necessary or appropriate to subcategorize the steam electric industry based on fuel type, operational characteristics, location, size, or other factors yet to be determined.
Establish baseline estimates of pollutants discharged in steam electric process wastewater so that the reductions achievable by implementing process changes, treatment technologies, or BMPs can be determined.
Identify BMPs and pollution prevention opportunities that can reduce pollutant discharges.
Identify best available and best demonstrated technologies, as defined by the factors established in the Clean Water Act for effluent limitations guidelines and standards.
Determine potential environmental impacts of steam electric process wastewater.

In addition to supporting a detailed profile of the steam electric industry to inform the rulemaking process, EPA will use the data collected through the questionnaire in conducting the following analyses:

Compliance cost assessment;
Facility-level cost impact analysis;
Parent entity-level cost impact analysis;
Household impact analysis;
Electricity rate impact analysis;
Electricity market analysis;
Regulatory Flexibility Act (RFA) analysis;
Unfunded Mandates Reform Act (UMRA) analysis;
Assessment of short-term reduction in capacity availability due to installation downtime;
Analyses to address executive orders such as Executive Order 12866; and
Assessment of total social costs and benefits.

(ii)Detailed Technical Analyses Supported by the Questionnaire

EPA will conduct a detailed analysis of the technical data gathered in the questionnaire to clearly define the steam electric industry. EPA will also use the data to identify applicable and demonstrated technologies, wastewater treatment options, or BMPs that would substantially reduce pollutant discharges from steam electric power plants. Specific analyses using the technical data are described below.

(a)Identification of Steam Electric Wastewater Characteristics

Wastewater characteristics determine the technologies that can be used for treatment of steam electric generating wastewater. EPA needs to gather information identifying and quantifying the pollutants in wastewater from FGD systems, ash handling operations, leachate collection systems, process equipment cleaning activities, cooling water, and other steam electric processes, in order to identify and evaluate possible treatment solutions. EPA will use the data collected throughout the questionnaire to determine if process changes, BMPs, treatment technologies, or recycle/reuse processes are feasible options to reduce pollutant discharges.

EPA will use data collected by the questionnaire and sampling data to identify pollutants that are commonly found in wastewaters from steam electric processes. EPA will also use the data to compare the performance of the different treatment technologies among steam electric plants to control these pollutants.

(b)Potential Subcategorization of the Steam Electric Industry

The steam electric power generating industry has undergone significant changes since the ELGs were revised in 1982 due to implementation of new technologies that alter existing or create new wastewater streams. Because of the variety of fuel types used to generate steam, a diverse group of technologies, processes, and wastewater treatment systems are used at facilities regulated by the ELGs.

EPA will evaluate the different subsets of the industry to determine if subcategorization is appropriate for the steam electric industry. EPA will consider subcategorizing the industry based on such factors as:

Fuel type;
Plant age;
Plant size;
Steam electric generating process (e.g., combined cycle systems); or
Air pollution controls (e.g., FGD systems).

EPA will use the questionnaire data, site visits, field sampling and other monitoring data, and secondary data to consider appropriate factors for subcategorization.

(c)Technology Analysis

To determine appropriate requirements to include in revised ELGs, EPA will identify available technologies for reducing pollutant discharges associated with waste streams of concern, such as FGD scrubber purge, ash handling, cooling water, and other wastewaters. EPA will also evaluate the feasibility of using these technologies throughout the industry or for certain segments of the industry. EPA will evaluate and compare candidate pollution control technologies, as well as any factors that are relevant to the implementation of treatment technologies, process changes, or BMPs at certain types of facilities or categories of facilities.

(d)Pollutant Loadings and Removals

EPA will calculate baseline pollutant discharges that represent the quantity and nature of pollutants currently discharged by power plants. EPA will also calculate the amount of pollutant reductions that would be achieved if various candidate pollution control technologies, process changes, and/or BMPs were implemented. EPA will use these calculations to evaluate the effectiveness of candidate regulatory options for revised ELGs. EPA also intends to evaluate the benefits that would be realized by implementing candidate regulatory options and the cost effectiveness of the options in reducing pollutant loads. Calculating pollutant loads and removals includes the following:

Calculating baseline discharges for the year 2009 (the pollutant loadings discharges prior to any ELG revisions) using estimates of the volume of water discharged from specific steam electric processes and corresponding pollutant discharges;
Calculating estimated future pollutant loads that reflect how pollutant releases may change due to revised ELG requirements, using estimates of pollutant concentrations/mass and volume of water that would be discharged after implementation of new technologies and/or BMPs; and
Calculating the pollutant reductions that would be attributable to revised ELG requirements, by quantifying the difference between the baseline pollutant loadings and the post-treatment pollutant loadings.

(e)Assessment of Technology Costs and Environmental Impacts

EPA will estimate the incremental investment costs and incremental operating and maintenance costs for operators to implement technologies, process changes, and best management practices. These compliance costs will be used to determine the potential economic impacts on the steam electric industry. In addition, these compliance costs will be weighed against the effluent reductions resulting from each proposed technology/BMP option.

To estimate these incremental costs, EPA will use industry profile information in conjunction with the following information collected with the questionnaire about FGD and ash handling treatment system components, as well as other operations as appropriate: capital costs for direct and indirect costs including, but not limited to, engineering design, construction cost, purchased equipment, and site preparation; and annual operating and maintenance (O&M) costs for equipment and operators. EPA will use the estimated compliance costs in economic analyses to determine the economic achievability of candidate technologies, process changes, and BMPs.

EPA will use data collected from the questionnaire to perform an environmental assessment to identify potentially affected environmental resources and assess the environmental impacts associated with the steam electric industry. The environmental assessment will be used to help characterize any environmental or economic benefits that would be attributable to revised ELG requirements.

(iii)Detailed Economic Analyses Supported by the Questionnaire

EPA will conduct detailed analyses using economic and financial data collected in Part I of the questionnaire. These analyses will be designed to determine if the costs of ELG regulatory control options are affordable to the steam electric industry. In each of these analyses, the survey data may be used as the primary input (e.g., cost information for a given technology is used directly in the cost model), or may be used to identify a subset of facilities for which a given analysis will be conducted. For example, information on revenue, number of employees, and electricity sales for the ultimate parent will be used to identify small entities according to the Small Business Administration (SBA) definition. Consequently, accurately capturing information on who the ultimate parent is and this parent’s revenue, number of employees, and electricity sales in the survey will be crucial for the RFA analysis.

3.NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION EFFORTS

3.a)Nonduplication

(i)Technical

The Engineering and Analysis Division (EAD) of EPA’s Office of Water made every reasonable attempt to ensure that the steam electric power generating effluent guidelines questionnaire does not request data and information currently available through less burdensome mechanisms. Specifically, EAD explored Agency databases, directories, contacts, and sources to locate data and information significant to the regulatory development process. EAD also examined other ongoing or completed EPA information collection efforts. In addition, EAD has conducted a thorough collection and review of secondary sources, which include data, reports, and analyses published by government agencies; reports, data, and analyses published by the steam electric industry and its associated organizations; and publicly available financial information compiled by both government and private organizations. This section summarizes the major data sources that EPA considered using as alternatives to parts of the steam electric questionnaire.

The Energy Information Administration (EIA) is a statistical agency of the Department of Energy that collects information on U.S. electric generating plants and associated equipment to evaluate the current status and potential trends in the industry. During the steam electric detailed study, EPA used the 2005 EIA database as the primary source of data for the Steam Electric Power Generating Point Source Category: Final Detailed Study Report and is currently using the most recent version (2007) of this dataset to define the population to receive the steam electric questionnaire. The EIA data are useful for identifying steam electric generating units and certain aspects about processes at these units, but the data do not provide sufficient information about operations after 2007 or about wastewater generation and management. EIA data will be used to the extent possible to reduce burden on the industry; as such, EPA has developed the questionnaire in such a way to avoid duplication where practical. For example, EPA will use the EIA database to collect information on electric generating units, including the type of boiler, initial date of operation, date of retirement, and total capacity for units operating prior to 2009.

In March 2009, EPA’s Office of Solid Waste and Emergency Response (OSWER) requested information from certain power plants regarding the design and management practices for some waste management units located at the facilities. This included surface impoundments or similar diked or bermed management units or management units designated as landfills that receive (or once received) liquid-borne material for the storage or disposal of residuals or by-products from the combustion of coal, including, but not limited to, fly ash, bottom ash, boiler slag, or flue gas emission control residuals. The OSWER database contains information collected from plants that were identified as potentially operating ash ponds or FGD ponds, using the EIA data described above. The EIA data lacks information about waste disposal practices for some plants, and also omits information about landfills and certain ash/FGD ponds. Since the OSWER information request was based on the EIA data, the information collected does not provide statistically representative data about leachate, the wastes contained in the ponds/landfills, or the management/treatment practices used. For the purpose of the effluent guidelines rulemaking effort, EPA needs additional information that was not obtained by the OSWER information request, such as information about impoundments used to manage residues or by-products from the combustion of other fuels (e.g., oil), impoundments at plants not included in OSWER’s data request effort, financial data, leachate collection and treatment for surface impoundments and landfills, and additional detail regarding surface impoundment BMPs.

In January 2000, EAD distributed a detailed questionnaire to power plants to collect information on cooling water intake structures under Phase II, Section 316(b) of the Clean Water Act. The questionnaire collected information on current and planned operations, such as the number of cooling towers operated at power plants and whether or not the cooling towers were operated as “once-through” systems, and operational data from 1996 to 1998. The 316(b) questionnaire focused on data regarding the intake of cooling water, while the steam electric questionnaire collects data on characteristics and treatment of cooling water discharges, including information on the use of chemicals (e.g., biocides, corrosion control additives) in cooling water systems.

EPA’s Office of Enforcement and Compliance (OECA) submitted an information collection request to 18 power plants in June 2009 requesting information on storage “areas” used to collect, store, treat, or dispose of waste or wastewater generated from the burning of coal. “Areas” in this request included, but were not limited to: underground mines; underground injection wells; landfills; tanks; waste piles; ponds; lagoons; storm drains; pipes; and surface impoundments. The power plants were not selected to be statistically representative and the data collected are not sufficient (i.e., dataset too small and not statistically representative) for extrapolating to industry-wide projections, and do not fulfill the data requirements for the effluent guidelines rulemaking identify to industry trends, evaluate technology options, and analyze the costs and affordability of pollution control options. Also, OECA’s information collection request was limited to coal-fired power plants. These data will not be sufficient for the other parts of the steam electric industry that EAD intends to survey.

EPA’s Office of Air and Radiation is currently collecting information on existing utility steam electric generating units to support the Utility Maximum Achievable Control Technology (“Utility MACT”) rulemaking effort. The Utility MACT questionnaire, approved by OMB on December 31, 2009, collects information on the control of hazardous air pollutants (HAP) from both existing and new electric generating units. EAD will use the particulate matter system and mine location data, previously requested in the Steam Electric questionnaire, from OAR’s information collection effort. EAD also removed the analytical data for fuels by power plants requested in the questionnaire and will use fuel usage information from OAR. However, the scope of the Utility MACT ICR still differs from questionnaire in the following ways:

Although the Utility MACT ICR will collect information about the presence of certain air pollution control equipment, it will not collect information about the wastewaters generated from this equipment, nor will it collect information regarding related operating practices that affect the wastewater pollutant characteristics and generation rate. The Utility MACT ICR also will not collect the plant-level and parent-level financial data needed to assess the affordability of ELG pollution control options.
The effluent guidelines questionnaire will be distributed to plants that operate all types of fossil-fueled (coal, petroleum coke, oil, and gas) and nuclear-fueled steam electric units. The Utility MACT ICR will only collect information on coal- and oil-fired steam electric units.
The Utility MACT ICR will be distributed to coal- and oil-fired generating units producing more than 25 megawatts. The effluent guidelines questionnaire would collect information on steam electric units with capacities greater than 1 MW^¹. Therefore, the effluent guidelines questionnaire includes generating units that are not included in the Utility MACT ICR.

In August 2008, EPA’s Office of Air and Radiation distributed an information collection request to facilities operating industrial, commercial, and institutional boilers and process heaters to support the Boiler Maximum Achievable Control Technology (“Boiler MACT”) rulemaking effort. The Boiler MACT questionnaire collected information for units not covered by the Utility MACT ICR (i.e., units under 25 megawatts that produce less than one-third of its potential electrical output capacity for sale). The Boiler MACT ICRs did not collect information from generating units that are subject to the effluent guidelines; therefore, the data collected are not useful for the effluent guidelines rulemaking.

(ii)Financial and Economic

EPA reviewed existing data sources to determine whether publicly available economic and financial data are available for steam electric entities regardless of their regulatory status and that these data are consistent and comparable.

Publicly available economic and financial information for potential survey respondents differs depending on the regulatory status of the facility or generation unit, and on the ownership and operating structure. Furthermore, the level of detail at which information is provided (e.g., at the level of the owner rather than the generating unit) often differs from that which is needed by EPA. EPA has identified several sources that provide economic and financial data for steam electric utilities. Utilities are currently subject to annual reporting requirements by various government entities, including the Federal Energy Regulatory Commission (FERC) and EIA. In reviewing these data, EPA determined that the information available for regulated utilities are generally not sufficiently detailed and complete to support the plant level economic/financial impact analyses that will be conducted for the effluent guidelines rulemaking. Further, EPA determined that even less data are available for non-utilities (e.g., independent power producers). Therefore, EPA determined it is necessary to obtain financial data from both regulated utilities and non-utilities to ensure sufficient data consistency and comparability.

To reduce respondents’ burden, however, EPA plans to use data already available from public government and other public sources wherever possible, including when the data are the same as requested by the Agency in this questionnaire for some respondents. For example, EPA plans to use information major utilities provide to FERC to support analyses of the potential impacts of ELG revisions on these entities.

In general, the questionnaire asks for three years of financial and operational information. The three-year period was selected to allow for the characterization of the industry and its level of activity over a period of more than one year, and thus avoid potentially anomalous observations about a given plant, entity, or even the industry, based on a single year of data – while keeping respondent burden to a practical minimum.

Below, EPA describes sources of data and information that were reviewed to identify existing sources of economic and financial data to reduce duplication of effort and minimize burden on survey respondents.

FERC compiles information relating to such matters as financial operations, energy production or supply, and compliance with applicable regulations. FERC Forms 1 and 1-F collect accounting, financial, and operating data from major and nonmajor privately-owned electric utilities, respectively.^² Neither form collects information for non-regulated entities (i.e., nonutilities), and the data collected do not include sufficient generating unit-level information and/or information for the ultimate parent. Further, Form 1-F data are much less detailed than data collected by Form 1, limiting their usefulness for the economic/financial impacts analyses EPA anticipates conducting for the effluent guidelines rulemaking. EPA plans to use information collected through Form 1 as a primary source of data for major utilities; respondents from plants owned by major utilities are therefore exempt from providing the information already reported on FERC Form 1.^³ Considering the limitations of the FERC Form 1 data set, EPA is requesting that nonmajor utilities and nonutilities provide the necessary information using this questionnaire.

EPA reviewed data collection forms used by the EIA and identified several forms that are potentially relevant to ELG economic analyses. Relevant EIA data forms include Form EIA-860, EIA-861, and EIA-923. Neither form provides data sufficient for EPA’s economic analyses to assess impacts of potential ELG options on individual plants or companies. The data are useful, however, to help identify potential recipients for the questionnaire and will be used in selecting a statistically representative subset of facilities for the questionnaire.

The Rural Utility Service (RUS) is a program within the U.S. Department of Agriculture that provides rural infrastructure assistance in electricity, water and telecommunications. Rural utilities that borrow from RUS are subject to annual reporting requirements administered by RUS. The information collected is similar to data collected from major privately-owned electric utilities in FERC Form 1, albeit only for a subset of rural utilities. The limitations of these data are similar to those of the FERC Form 1 regarding the ability to relate financial information to specific plants and/or generating units. This data source is therefore not comprehensive enough to support the analyses EPA intends to complete. Additionally, the RUS data are not readily available, which further limits their usefulness with respect to the ELG economic analyses.

The Nuclear Regulatory Commission compiles and publishes data and reports regarding the nuclear sector of the electric power industry. However, these data and reports are based on information collected by other agencies and do not overlap with information requested in the detailed questionnaire.

The Securities and Exchange Commission (SEC) administers federal securities law. Information filed with the SEC, such as standard financial statements, is made available through the Electronic Data Gathering, Analysis, and Retrieval system (EDGAR). Reports available through the SEC do not contain detailed site-specific information, but they have firm-specific data that may be useful. EPA will use these data as a secondary source of parent firm-specific data. However, widespread use of these data will be limited because the SEC only collects information for publicly traded companies. In addition, the lack of facility-specific financial, engineering, and environmental data, the lack of unit level data, and the difficulty of accurately relating data to specific entities limit the use of this data source for effluent guidelines rulemaking.

Edison Electric Institute (EEI) maintains comprehensive statistical data on shareholder-owned electric companies and the electricity industry. This includes an annual financial review of shareholder-owned electric companies and key statistics for various aspects of the industry as a whole, including capacity, transmission, generation, fuel mix, emission reductions, and sales. While some data presented in the EEI annual financial review report duplicate data requested in the detailed questionnaires, the EEI data are considered confidential and EEI will only disseminate information in an aggregated form. In order for the information to be useful for this rulemaking effort, EPA must have the raw data on a facility-specific basis.

To support analyses for revised effluent guidelines EPA has determined that, used alone, the sources discussed in this section are generally insufficient to meet its needs, and that more comprehensive, consistent, and statistically representative information on steam electric power plant operations is needed.

3.b)Public Notice Required Prior to ICR Submission to OMB

(i)Publication of the Federal Register Notice

On October 29, 2009 (74 FR 55837), EPA published a notice in the Federal Register, announcing the Agency’s intent to submit a request for a new ICR and to collect comments on the Draft Questionnaire for the Steam Electric Power Generating Effluent Guidelines. EPA plans to publish a second notice in the Federal Register announcing the Agency’s intent to submit a request for a new ICR and to collect comments on a revised version of the Draft Questionnaire for the Steam Electric Power Generating Effluent Guidelines that incorporates comments received from the first comment period. The notice will include a description of the entities to be affected by the proposed questionnaire, a brief explanation of the need for the questionnaire, identification of the authority under which the questionnaire will be issued, and an estimate of burden to be incurred by questionnaire respondents. By means of this notice, the Agency will request any further comments and suggestions regarding the questionnaire and the reduction of data collection burden, and ask that the public submit all final comments and suggestions within 30 days of the Federal Register notice publication.

Pursuant to section 3506(c)(2)(A) of the Paperwork Reduction Act, EPA will specifically solicit comments and information to enable it to:

Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the Agency, including whether the information will have practical utility.

Evaluate the accuracy of the Agency’s estimate of burden of the proposed collection of information, including the validity of the methodology and assumptions used.

Enhance the quality, unity, and clarity of the information to be collected.

Evaluate and test the MS Excel electronic format questionnaire that will be implemented for this information collection request.

Minimize the burden of the collection of information on those who are to respond.

(ii)Public Response to the Federal Register Notice

EPA received public comments from a variety of interested stakeholders following publication of the 1^st FR Notice (October 2009). EPA received comments from power companies, industry trade associations, and an environmental group. These comments addressed general aspects of the ICR, and specific questions included in each part of the questionnaire. In addition to publishing the Federal Register notice, EPA informed trade associations and other industry contacts, environmental groups, and state and interstate regulatory authorities of the notice publication via phone and e-mail.

EPA is appreciative of the efforts made by stakeholders to support and improve the focus and content of the draft questionnaire. EPA has benefited from this input and used the information gained to improve the ICR and the overall approach to developing revised effluent guidelines. An overview of the comments received and changes EPA has made to the questionnaire is presented below. Additional information about the comments received is presented in Appendix B at the end of this document.

(a)General Comments

Several comments noted that some data requested by EPA are available through other sources. In response, EPA has carefully reviewed the questionnaire to identify opportunities to obtain data from government databases and other EPA information collection efforts. EPA has revised the questionnaire to substantially reduce the reporting requirement, where possible, to eliminate requests for data that EPA can retrieve from the 2007 EIA, FERC data, and a questionnaire EPA distributed for the Utility MACT rule. Specific changes that were made in this respect are discussed more fully in Appendix B.

Comments submitted by industry representatives stated a preference for EPA to distribute the questionnaire in Microsoft Excel format. The questionnaire previously made available for review and comment was prepared as a Microsoft Word document and EPA solicited comment on the preferred format. EPA revised the questionnaire to the MS Excel format, to acknowledge the stated preference and to lessen the burden associated with data entry and data collection.

The instructions for the previous version of the questionnaire included a requirement for respondents to include information providing justification for any claims that the data submitted with the completed questionnaire should be afforded protections as confidential business information (CBI). EPA included this requirement in the draft questionnaire to discourage unjustifiable CBI claims and because any requests for information claimed as CBI would necessitate EPA contacting the respondent for information to justify the claim. In general, it is more efficient for the respondents to provide justification information at the same time they are completing the questionnaire, rather than doing so at a later date. Nevertheless, EPA recognizes that supplying these justifications does impose a burden on respondents and that, unless subsequently requested to justify the CBI claim, this may be an unnecessary burden. EPA considered establishing up-front categorical CBI protection for certain categories of data, but determined this approach would not sufficiently reduce unnecessary burden on respondents. Therefore, EPA has amended the requirement to simply allow answers to be marked as CBI according to practices familiar to the industry. Respondents will not be required to provide CBI justifications when they submit the completed questionnaire. Should EPA receive a request for information claimed CBI, the respondent will need to justify the CBI claim in accordance with procedures outlined in 40 CFR Part 2.

Industry stakeholders commented that a glossary of key terms and definitions should be developed and included in the questionnaire to reduce potential ambiguities and confusion. EPA agrees that a glossary would improve understanding of the terms used in specific questions and would likely improve the quality of the data obtained. EPA prepared a glossary and, in advance of the public comment period for the second Federal Register notice, shared this draft glossary with interested stakeholders (industry and environmental groups) and offered them the opportunity to provide early feedback on the terms defined, as well as to identify other terms that should be included. EPA considered this feedback in revising the glossary, which is included in the current version of the questionnaire.

Industry and trade associations commented that the initial hourly burden for this ICR was underestimated. EPA carefully reviewed each comment regarding the burden and thoroughly explored suggested burden estimates received from industry. The burden estimate was revised in response to industry comment, as well as the changes made to questionnaire since the publication of the first Federal Register notice. In order to revise the burden, EPA compared the first burden estimate and the suggested estimate from industry to develop a more accurate hourly burden. For example, EPA revised the burden estimate of each part to allow for upfront coordination time required to gather information for and review the questionnaire. Additions and revisions to questionnaire parts (e.g., Parts C, F, and H) also increased the hourly burden. EPA did not increase the legal hourly burden as the requirement for CBI justifications was removed from the questionnaire. Decreases in hourly burden estimates resulted from removing burdensome questions, as suggested in public comment, such as the request for analytical coal data and mine location data. In many questions, the number of years for which data was requested was decreased (e.g., all revenue questions throughout the questionnaire only request data from three years instead of the five consecutive years previously requested). The adjustments made to the burden estimate increased the hourly burden per part; however, the changes in the number of respondents decreased the overall hourly burden originally estimated for the industry.

Industry and trade associations commented that the 60 day response period for the questionnaire is insufficient, especially if the questionnaire will be sent to facilities in Spring 2010. Commenters specifically expressed concern about overlapping reporting requirements (in terms of timeframe) with annual reporting for EPA’s Toxics Release Inventory, DOE’s Energy Information Administration, and the Federal Energy Regulatory Commission. EPA does not agree that additional time should be provided for responding to the questionnaire. EPA is aware that the questionnaire requests a substantial amount of detailed information; however, the Steam Electric questionnaire will be distributed to industry after these other annual reporting requirements are due and therefore they should not interfere with this questionnaire. Facilities should answer the questionnaire with the best available information provided the scope and time constraint of the ICR. In addition, EPA will distribute the questionnaire electronically and provide separate files for each part to allow facilities to distribute the questionnaire to appropriate personnel. Respondents that have individual circumstances affecting their ability to respond within the 60 day response time should apply individually for an extension, as described in the instructions for the questionnaire. EPA’s decision to grant any extensions will be based upon consideration of an individual plant’s or company’s situation.

EPA reviewed public comment regarding the scope of the questionnaire and decided that the facilities included in the scope will provide the best information to aid EPA in this rulemaking effort. All coal-, petroleum coke-, oil-, gas-fired and nuclear steam electric power plants identified by the 2007 EIA database will be included in the industry population and used to select the specific questionnaire recipients. EPA did not elect to statistically sample a subset of the coal-fired power industry for Parts A through D and I due to the number and types of factors to be considered regarding FGD and ash operations, and the limited data available for identifying these factors at power plants to the extent necessary for establishing and defining strata for statistical sampling, as well as the individual plants that populate each sampling strata. Throughout the detailed study and during initial rulemaking activities, stakeholders have stressed the need to evaluate how variability in equipment and operating practices between plants affect wastewater discharges. In addition, stakeholders expressed concern over properly accounting for the financial conditions at each plant, considering ownership of individual generating units including, in a number of instances, multiple partial owners. The types of operations and the associated process wastewaters can change from facility to facility depending on factors, such as the type of coal burned, air pollution controls in place, type of wet FGD absorber design, FGD wastewater treatment, type of ash handling system, ash pond management, type of cooling water system, and the water source. Considering the large number of characteristics to be evaluated and the limited data currently available, EPA will distribute Parts A through D and I of this questionnaire to all coal-fired power plants.

However, to reduce overall burden, EPA selected a statistical subset of coal-fired plants to receive more detailed parts of the questionnaire, including parts requiring sampling of collected leachate. EPA eliminated small entities from the subset of plants selected to sample leachate from ponds/impoundments and landfills to reduce the overall burden to small businesses. In addition, EPA removed any plants that will be permanently retired by December 31, 2011 from the scope to reduce overall industry burden. Information from plants that do not discharge wastewater is relevant to the rulemaking process because it provides valuable insight to approaches to reduce or eliminate pollutant discharges and it will be factored into the development and consideration of effluent guidelines options for other plants. Therefore, these plants remain in the scope of this ICR. Commenters also requested that EPA exempt those nine companies that responded to the 2007 data request used to support EPA’s detailed study. However, this ICR collects more broad operational data that was not obtained by the 2007 data request and that is not obtainable through publicly available sources, therefore EPA has retained those facilities in the potential pool of respondents.

EPA reviewed and considered comments requesting that EPA allow the submittal of data for 2008 versus 2009. Due to ongoing changes in the industry with respect to installation of air pollution controls, treatment systems, and other technology improvements, EPA needs the most current data available in order to best determine if revisions need to be made to the effluent guidelines. EPA has also reviewed comments regarding cost information requested in the questionnaire. EPA is aware that gathering capital cost information for systems that are several or more decades old may take some effort and has limited the cost requests to a reasonable timeframe, to include systems that are technologically relevant and for which data should be available. Depending on the data requested, EPA asks for plants to provide cost information for systems installed since 1985 or 1990. Relatively few plants have installed treatment systems since then, therefore EPA has selected these dates to obtain the data necessary to evaluate potential technology options.

(b)Comments Related to Specific Parts of the Questionnaire

EPA reviewed comments submitted to the docket during the first comment period for each specific part of the questionnaire. The following paragraphs summarize EPA’s responses and major changes made to questionnaire since the publication of the first Federal Register notice. See Appendix B for a more detailed discussion of changes made to the questionnaire.

EPA revised questions in all questionnaire parts regarding the request for marketing and revenue data for each of the past five years (found in Parts B and C). EPA has determined that sufficient information can be obtained using data reported for three years of the five-year period and has changed these questions to request information for years 2005, 2007, and 2009.

Part A. Steam Electric Power Plant Operations

EPA revised questions to help clarify the information requested in the ICR. For example, the directions and format of Table A-5 were revised to make it more apparent what plants should be included in the table. Questions on fuel usage were revised so that plants only had to indicate the total amount of fuel used and not specify how much was used for startup versus normal operations.

EPA also evaluated questions in all questionnaire parts identified as overlap with other industry ICRs (e.g., EIA, Utility MACT), as noted in the General Comment Response section. EPA removed questions from Part A, where possible, to decrease the burden on the industry. For example, the questions asking for analytical data and mine location information for coal sources were removed because similar information is being obtained from the Utility MACT ICR. EPA recognizes that this change will not collect information on boilers less than 25 MW, but believes information on larger boilers will provide sufficient information to evaluate this population of boilers. Additionally, the tables requesting information on particulate matter and sulfur dioxide control systems were removed from Part A.

As a result of industry comment, EPA revised or removed several questions from the questionnaire to decrease burden on plants. For example, the requirements for the property map and water balance diagram were revised to decrease the burden on plants. To compensate for the removal/revision of certain questions, EPA added some questions into the ICR. For example, questions about the plant’s permitted outfalls were added so the question asking plants to identify all plant waste streams and flow rates in 2009 could be removed. EPA also added/revised questions to help clarify who should complete the questionnaire. For example, EPA added a question so plants that will be permanently retired by December 31, 2011 would not need to complete the ICR. EPA also added questions based on public comments. For example, EPA added questions about SCR catalyst washing based on a commenter’s suggestion.

Part B. Flue Gas Desulfurization (FGD) Systems

EPA revised questions in Part B to help clarify the information requested in the questions and reduce the burden on the industry. EPA consulted industry representatives in revising the FGD system terminology used in the section and to make changes to Figure B-1, the example FGD system diagram, to include all wastewaters associated with the FGD system operation. Additionally, to reduce burden on respondents, EPA revised several questions that previously requested five years of data to request only three years of data. EPA also deleted a table that obtained detailed information on materials of construction for the FGD system.

Part C. Ash Handling

After reviewing public comment and researching ash handling techniques in further detail, EPA restructured the sections within Part C. EPA revised Part C to gather information from plants based on an ash handling system level, rather than a steam electric generating unit level. This approach is more consistent with the manner the systems are operated and the change should help plants provide EPA with a more complete picture of ash handling systems, while avoiding having to report certain information more than once. EPA also restructured the ash handling cost sections to respond to industry comment on the best way to collect this information, as well as to collect the information necessary to evaluate costs accurately (e.g., costs for combined storage and disposal of fly and bottom ash).

Part D. Pond/Impoundment Systems and Other Wastewater Treatment Operations

EPA revised questions and instructions in Part D in response to public comment. General instructions for Part D were revised to provide clarity and direction for respondents. EPA also revised questions to address potential differences in plant responses (e.g., added more options for responses regarding chemical addition, flow rate) to reduce the potential for inconsistent answers, pointed out as a potential issue in public comment. In addition to these revisions, EPA added questions to collect improved compliance cost data for treatment systems. These questions, which include effects on the plant and/or wastewater treatment system due to climate and space availability, will ultimately provide EPA with more accurate cost information to develop potential technology options for the industry. EPA also revised the capital cost table for ponds/impoundments and wastewater treatment systems to distinguish plants that hired an outside contractor to construct/install the wastewater treatment system.

Part E. Wastes from Cleaning Metal Process Equipment

EPA revised Part E to require plants to provide information on each type of cleaning operation that was performed within the last 10 years, and to provide “typical” values such as volume of wastewater per cleaning event, instead of requiring plants to provide data for every process cleaning option since January 1, 2000. After reviewing information collected from the 2007 data request for the Steam Electric Power Generating Industry and site visits, EPA concluded that cleanings are sporadic in nature and long periods of time pass between each cleaning. EPA also defined terms throughout Part E to improve the questionnaire.

Part F. Management Practices for Ponds/Impoundments and Landfills

EPA reduced the information in Part F requesting previously-conducted impoundment inspections as these data would not have a significant impact on the revisions to the effluent guidelines. EPA reconsidered information requesting respondents to provide BMP information for planned ponds/impoundments and landfills and eliminated the requests to further reduce industry burden.

In order to collect all information necessary to accurately revise the effluent guidelines, EPA added questions to request information on segregated leachate treatment systems, if the plant has not already provided information about those systems in Part D. This segregated leachate treatment information will be used to develop potential options for treatment of the leachate waste stream.

As a result of public comment, EPA also revised the stormwater runoff questions to request information on stormwater that contacts the capped portion separately from the questions requesting information on stormwater that contacts the uncapped portion to remove any confusion regarding the definition of stormwater.

Part G. Leachate Sampling data for Ponds/Impoundments and Landfills

EPA recognizes the costs associated with the sampling requirement in this part and has accounted for the costs in the overall burden of the ICR. However, EPA did not remove the sample collection requirement because these data are necessary for characterizing leachate streams and evaluating potential revisions to the ELG.

To reduce burden on small entities, EPA intends to exclude plants operated by small entities from the requirement to collect and analyze leachate samples. EPA is providing substantial flexibility to those firms selected to complete Part G. First, the plants are allowed to submit previously-collected data in lieu of sampling, if the prior data includes all information requested by Part G. Second, EPA is allowing plants to collect samples from a single “representative” leachate collection point for each individual pond or landfill, rather than every leachate collection point that may be present at the pond or landfill. Third, EPA is providing additional flexibility in the analytical method that may be used to analyze the samples, for certain parameters.

Leachate sample instructions were revised to clarify how to select the leachate sample location and how to complete the sample collection if the facility does not generate leachate weekly. EPA considered comments about laboratory availability for analysis by low level methods (e.g., Method 1631 E) and determined that laboratory availability will not cause a significant problem due to the limited number of plants expected to complete Part G. In addition, the holding time for EPA Method 1631E is 90 days; therefore, samples will not need to be analyzed immediately. This holding time will allow laboratories time to receive and preserve the samples in order to handle the required analyses within the timeframe required by Part G.

Part H. Nuclear Power Generation

After reviewing public comment, EPA reduced burden by removing requested information that can be found using other data sources (e.g., information about the type of reactor is publicly available from NRC). EPA also added a list of process wastewaters expected to be generated nuclear plants to help plants understand what should be reported in the questionnaire and to ensure that all plants respond consistently. EPA also added a new section called “Wastewater Treatment Systems” to Part H. EPA will use information in this section to better characterize how process wastewater associated with nuclear generating units is treated and handled.

Part I. Economic and Financial Data

EPA received comments pertaining specifically to Part I. In addition to concerns regarding certain specific questions, commenters raised several substantive general concerns regarding: the duplication of data currently provided to other regulatory agencies; EPA’s request for certain data not currently compiled by facilities under customary business practices; the challenge of coordination of responses from multiple plant owners; and the need to clarify terms used in the questionnaire. In response to these comments, EPA made several changes to Part I of the questionnaire to reduce the respondent burden and/or clarify the data request. For example, EPA reduced burden by allowing respondents who submit data to FERC in Form 1 to skip questions and by eliminating or reducing the number of items or years for which respondents are asked to provide data. In response to comments received by EPA regarding the availability of certain data, the Agency revised its burden estimate to account for the potentially higher level of effort involved in compiling certain financial information that may not be readily available. For example, EPA increased the burden estimate for compiling information regarding the share of electricity sold under different pricing conditions and for estimating plant-level financial data when such data are not already reported under customary business practice by the plant.

3.c)Consultations

The Agency will continue to solicit comments from industry and other stakeholders following publication of the second Federal Register Notice. Following the first Federal Register Notice, EPA hosted a number of teleconferences and meetings with representatives from the Utility Water Act Group (UWAG), Electric Power Research Institute (EPRI), other industry trade associations, individual power plants, state regulatory authorities, and environmental groups to solicit input and better understand stakeholder comments. EPA presented information about the effluent guidelines regulatory process and schedule, data collection objectives, and various aspects of the draft questionnaire. Discussions about the questionnaire addressed topics such as the terminology for FGD systems and throughout the questionnaire, structure and format of the questionnaire, and specific matters such as ash handling, leachate collection, and FGD operations. EPA also shared a draft glossary and mailing list of power plants with industry and environmental group representatives to obtain feedback in advance of the second Federal Register notice. EPA plans to conduct additional teleconferences and meetings with industry, other government agencies, and other interested stakeholders, as needed, to solicit any further input on the steam electric effluent guidelines questionnaire.

3.d)Effects of Less Frequent Collection

This survey is to be administered one time only. If this survey is not conducted, the specific data sought in this survey will not be available for EPA’s use in decision making about the need for and scope of potential actions to prevent or mitigate the environmental impacts of discharges from steam electric facilities. Reliance on public data alone would significantly impair EPA’s ability to evaluate treatment technologies and analyze the costs and financial impacts of regulatory options on the steam electric industry, as well as to evaluate other factors as established by the Clean Water Act.

3.e)General Guidelines

EPA will conduct data collection activities in accordance with the PRA guidelines in 5 CFR 1320.6 and EPA’s Quality Assurance Guidance. Information to be disseminated will comply with EPA’s Information Quality Guidelines, which were developed for implementing OMB’s Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of the Information Disseminated by Federal Agencies.

3.f)Confidentiality

The questionnaire informs respondents of their right to claim information as confidential in accordance with 40 CFR Part 2, Subpart B, Section 2.203. The questionnaire provides instructions for claiming confidentiality, and informs respondents of the terms and rules governing the protection of Confidential Business Information (CBI) under the Clean Water Act and 40 CFR 2.203(B). Each question which requests potentially confidential information is accompanied by a CBI checkbox. Questionnaire respondents are directed to check the CBI checkboxes which accompany responses they claim as confidential.

EPA and its contractors will follow existing procedures to protect data labeled as CBI. These procedures include the following:

Ensure secure handling of completed questionnaires to preclude access by unauthorized personnel.
Store completed questionnaires and databases in secured areas of offices, and restrict access to authorized EPA and contractor personnel only.
Restrict any publication or dissemination of confidential study results or findings to aggregate statistics and coded listings.

Information covered by a claim of confidentiality will be disclosed by EPA only to the extent of, and by means of, the procedures set forth in 40 CFR Part 2, Subpart B. In general, submitted information protected by a business confidentiality claim may be disclosed to other employees, officers, or authorized representatives of the United States concerned with implementing the Clean Water Act. Exemption 4 of the Freedom of Information Act (FOIA) protects from disclosure "trade secrets and commercial or financial information obtained from a person and privileged or confidential." See 5 U.S.C. 552(b)(4).

Information covered by a claim of confidentiality will be made available to EPA contractors under EPA Contract Numbers No. 68-C-02-095 and EP-C-07-023 to enable the contractors to perform the work required by their contracts with EPA. Each EPA contractor that collects, possesses, or stores CBI is responsible for the proper handling of that data. Each contractor will safeguard information as described in Section 2.211(d) of Subpart B and is obligated to use or disclose information only as permitted by the contract under which the information is furnished.

3.g)Sensitive Questions

No sensitive questions pertaining to private or personal information, such as sexual behavior or religious beliefs, will be asked in the questionnaire.

4.THE RESPONDENTS AND THE INFORMATION REQUESTED

4.a)Respondents NAICS Codes

The respondents affected by this ICR are classified under the North American Industry Classification System identification number 2211 – Electric Power Generation, Transmission, and Distribution, which includes establishments that may perform one or more of the following activities:

Operate generation plants that produce electric energy;
Operate transmission systems that convey the electricity from the generation plant to the distribution system; and
Operate distribution systems that convey electric power received from the generation plant or the transmission system to the final consumer.

Within NAICS code 2211, the following specific NAICS codes apply to steam electric plants:

221112 – Fossil Fuel Electric Power Generation;
221113 – Nuclear Electric Power Generation; and
221119 – Other Electric Power Generation.

Affected entities may also include immediate and ultimate parent firms in other NAICS codes.

4.b)Information Requested

(i)Detailed Description of the Steam Electric Effluent Guidelines Questionnaire

EPA is planning to conduct a survey of steam electric power plants. The questionnaire is designed to collect technical information related to wastewater generation and treatment, and economic information such as costs of wastewater treatment technologies and financial characteristics of affected companies. It will provide information that will be used to evaluate pollution control options for establishing revisions to the effluent guidelines for the steam electric power generating point source category.

The questionnaire consists of nine parts as described in Section 2(b). EPA will distribute the questionnaire in electronic format, and respondents will be required to submit the completed questionnaire to EPA in electronic format. The electronic questionnaire will be developed to meet the 1998 Government Paperwork Elimination Act (GPEA). Given the level of information technology implementation at electric power generating facilities and requirements established by EIA which require electronic submission of data, EPA anticipates that respondents will be familiar and comfortable with electronic submission forms. Additionally, the electronic questionnaire will allow for automatic population of a database with responses—reducing the potential for errors introduced though key-entry of data.

EPA designed the questionnaire to include many burden-reducing features. For example, it contains many “screening” questions that direct respondents to skip portions or entire sections of the questionnaire containing detailed questions that may not pertain to their company or steam electric power generation operations.

The questionnaire was designed in modular fashion to reduce respondent burden by making it easier for them to separate the questionnaire into sections that can be delegated to various plant and corporate staff. The computer disk that will be distributed to questionnaire recipients will include both the electronic-fillable questionnaire and a pdf-file that can be printed out and used as a working copy. Copies of selected sections can be made when needed, and selected sections of the working copy distributed to the appropriate staff. The electronic questionnaire format further simplifies this task by allowing facilities to electronically generate the required number of copies of each section.

Some sections will not be applicable to all respondents. General instructions to the questionnaire describe allowable responses for cases in which a facility will be unable to respond to a question. A response of “NA” corresponds to questions that are not applicable.

Justifications for the Questionnaire Questions

The data items requested by the questionnaire and justifications for requesting the information are shown below:

Part A: Steam Electric Power Plant Operations

Part A gathers information on all steam electric generating units, the fuels used to run the units, air pollution controls, cooling water, coal storage and processing, and pilot studies.

Table 4-1. Steam Electric Power Plant Operations Question Justifications
Question Number	Question Description	Purpose of Question
A1-1 through A1-5	Requests plant name and address, and the primary and secondary contacts for the technical and economic questionnaire information.	EPA needs to know the location of the plant to determine any geographic limitations/restrictions for the plant. EPA also needs to know who should be contacted to verify or clarify the technical and economic questionnaire information provided.
A1-6	Asks if the plant will be permanently retired by December 31, 2011.	EPA would use this question to identify plants that should complete the questionnaire; plants that will be permanently retired by December 31, 2011 are exempted from completing the remainder of the questionnaire.
A1-7	Asks if the plant generated electricity or has the potential to generate electricity from a steam electric generating unit.	EPA would use this question to identify plants that should complete the questionnaire; plants that do not generate electricity from a steam electric generating unit would not complete the rest of the questionnaire.
A1-8	Requests the plant to identify the types of fuels used by the plant to generate electricity.	EPA would use this question to identify plants that should complete the questionnaire; plants that do not use a fossil or nuclear fuel to generate electricity would not complete the rest of the questionnaire.
A1‑9	Requests information about end use/handling of the electricity generated at the plant.	EPA would use this question to identify industry trends and in its economic evaluation of the industry.
A1-10 and A1-11	Requests the primary, secondary, and tertiary, six-digit NAICS codes for the plant and asks if the primary purpose of the plant is electricity generation.	EPA would use the responses from these questions to identify the operations occurring at the plants, classify them into specific categories, and identify small businesses (along with economic/financial information). EPA expects that these questions would help identify industrial facilities. EPA would also use this question to identify plants that should complete the questionnaire; plants that do not generate electricity as its primary purpose would not complete the rest of the questionnaire.
A1-12	Asks the plant to identify how it uses the steam generated at the plant.	EPA would use the responses from this question to determine whether the plant is using the steam for purposes other than electricity generation because if it is, the amount of fuel used at the plant may not correlate directly with the amount of electricity produced. This information would be used in developing production-normalized effluent limits.
A1-13	Requests the total nameplate, summer, and winter capacities for the entire plant.	EPA would use this information to classify plants by size, which is a characteristic that will be evaluated for possible subcategorization. This information informs EPA of the non-steam electric plant capacity (when compared to the steam electric capacity obtained later in this part).
A1-14	Requests the net and gross electricity generation for the plant from 2007 to 2009.	EPA would use this information to compare the amount of electricity generated to the total plant capacity and to calculate the parasitic load associated with the plant. Several years of data are requested due to the reduced power generation during the economic recession.
Plant Identification and Information on Permits and Studies
A2-1 and A2‑2	Requests the identification codes of the plant when reporting to Energy Information Administration (EIA) and Rural Utilities Service (RUS).	RUS and EIA both collect data on steam electric power plants relevant to the rulemaking. EPA would use these codes to link the plant to the data collected by RUS and EIA.
A2-3	Request information on any Environmental Assessment (EA) or Environmental Impact Statement (EIS) studies the plant conducted on receiving water or pond/impoundments.	EPA would use this information to assess the environmental impact of discharges from steam electric plants as well as the impacts that pond/impoundments have on the environment.
A2-4	Requests permit IDs, approval dates, and expiration dates for several permitting programs. Also requests whether a new/pending permit is under development. Also directs plants, who do not have a NPDES permit, to skip to Question A3-1.	EPA would use this information to identify the permitting programs under which the plants are permitted. Additionally, EPA would use the permit IDs to be able to obtain specific permits, if desired, instead of requesting that all plants provide all of their permits. EPA would use this question to identify plants that should complete questions A2-5 through A2-10; plants that do not have a NPDES permit would not need to complete questions A2-5 through A2-10.
A2-5 through A2-10	Asks the plant to identify information for all outfalls designated in the plant’s NPDES permit. For each outfall, the plant would be required to specify the outfall name, coordinates, discharge flow, the types of wastewaters discharged in the outfall, and information about the receiving waters.	EPA would use this information to evaluate how plants are impacting receiving waters and to determine if changes have occurred in the industry since the last rulemaking that warrant revisions to the effluent guideline. Additionally, EPA would use this information to characterize the types of surface waters which receive discharges from steam electric power plants and use this information in the industry profile and for assessing environmental benefits.
Ponds/Impoundments
A3-1 through A3-3	Asks the plants to identify any existing or planned ponds/impoundments that are/will be used for the storage or disposal of process wastes, residues, or by-products. Requests information about pond contents, locations, liners, and leachate collection.	EPA would use this information to identify the total number of ponds/impoundments that are operated by the industry respondents and to identify the types of materials that are disposed of in each pond/impoundment. The pond/impoundment liner and leachate questions will be used to identify management practices for ponds operated by the industry. Additionally, the location information would be used to identify transport requirements and possible leaching issues associated with the pond/impoundment.
Landfills
A4-1 through A4-3	Asks the plants to identify any existing or planned landfills that are/will be used for the storage or disposal of process wastes, residues, or by-products. Requests information about landfill contents, locations, liners, and leachate collection.	EPA would use this information to identify the total number of landfills that are operated by the industry respondents and the types of materials that are disposed of in the landfills. The landfill liner and leachate questions will be used to identify management practices for landfills operated by the industry. Additionally, the location information would be used to identify transport requirements and possible leaching issues associated with the landfill.
Plant Property and Water Balance
A5-1	Requests the latitude and longitude of the plant, if not already reported to EIA	The location of the plant would help EPA to determine any geographic limitations/restrictions for the plant.
A5-2	Requests a property map showing the plant boundaries.	EPA would use the property map to better understand the general layout of the plant and the amount of land available for installation of equipment required for compliance with potential regulatory options.
A5-3	Requests a water balance diagram for the plant that shows all process wastewaters generated at the plant, their flow rates and handling/treatment, and plant outfalls.	EPA would use the water balance diagram to assess how wastewaters are generated and how they are handled, treated, and discharged.
Steam Electric Generating Unit Information
A6-1	Requests general information on the steam electric units that have been operated by the plant prior to December 31, 2009.	EPA would use this information to characterize the steam electric units operated in the industry and update the industry profile. EPA would use the information to determine whether the unit characteristics affect the wastewaters generated and use the information to predict the type of wastewaters associated with planned units.
A6-2	Requests general information on the steam electric units that first began operating after January 1, 2010, that the plant is currently constructing/installing, or that the plant is planning to construct/install by December 31, 2015.	EPA would use this information to characterize the planned steam electric units and update the future industry profile. EPA would also use the information to predict the type of wastewaters associated with the units.
Condenser Cooling Water Systems
A7-1	Requests information about the condenser cooling systems operated during 2009 that are associated with steam electric generating units including the type of cooling system (e.g., once through), and information on the chemical additives used in the cooling system.	EPA would use this information to identify industry trends. EPA would also use the information to determine the dilution occurring if the cooling water is commingled with other wastewater streams prior to being discharged. If significant dilution is occurring and commonplace, internal monitoring limits may be warranted.
A7-2	Asks how the plant demonstrates compliance with the current priority pollutant limits for cooling tower blowdown.	EPA would use this information to evaluate the current effluent limitation and determine whether any changes to the limitation or implementation guidance are needed.
Fuel Usage by Steam Electric Generating Unit
A8-1	Requests information about the types and amount of fuels used in the steam electric generating unit during 2009 (including fuels used for start up).	EPA would use this information to classify the units by the type of fuel used. Additionally, EPA would potentially use the amount of fuel as a normalizing factor for the costs and loads models, and possibly for production-normalized effluent limits.
A8-2 and A8‑3	Asks if the total BTUs generated by the fossil/nuclear fuels comprise 50 percent or more of the total BTUs generated by all fuels in 2009 for each steam electric generating unit. Also asks if a fossil or nuclear fuel was reported as the predominant or second most predominant energy source on Form EIA-860 for each generating unit.	EPA would use this information to identify whether a steam electric generating unit is a fossil/nuclear electric generating unit. Plants would not need to complete many questions throughout the questionnaire for units that are not fossil/nuclear electric generating units. Plants that had no fossil/nuclear electric generating units would not be required to complete the remainder of the questionnaire.
NOx Control Systems
A9-1	Requests information about NOx control systems associated with steam electric generating units that the plant is currently operating, currently constructing/installing, or planning to construct/install by December 31, 2020.	EPA would use this information to update the industry profile. The operation of NOx control systems can impact the pollutant characteristics of wastewater streams (e.g., fly ash transport water).
A9-2	Requests information about SCR catalysts sent off site for regeneration.	EPA would use this information to identify companies to contact to determine how the SCR catalysts are regenerated and the wastewaters generated and the characteristics of the wastewater.
A9-3 through A9-11	Requests information about on-site SCR catalyst regeneration and catalyst washing, including any wastewater generated from the process, how the wastewater is handled, if any wastewater treatment techniques are used, and the destination(s) of the wastewater.	EPA would use the information from these questions to identify trends in the industry and characterize the best management practices for the SCR catalyst regeneration wastewaters and catalyst washing wastewaters. EPA would also use the information to identify wastewater treatment systems being used to treat these wastewaters.
Flue Gas Mercury Control Systems
A10-1 and A10-2	Requests information about operating and planned flue gas mercury control systems associated with steam electric generating units, including a description of the process operation and how waste streams are handled.	EPA would use this information to update the industry profile and to determine if any wastewaters are generated that may warrant effluent limitations or if the process operations affect other wastewater streams that may warrant revisions to those wastewaters’ effluent limits.
A10-3 and A10-5	Asks whether the plant has participated in or plans to participate in a pilot study for a flue gas mercury control system(s). Additionally, if the pilot study evaluated wastewaters generated by the technology, EPA requests copies of the technical evaluation report.	EPA would use this information to identify new technologies and processes that are or may be implemented and the wastewaters associated with the operation.
Carbon Capture Systems
A11-1 and A11-2	Requests information about operating and planned carbon capture systems associated with steam electric generating units, including a description of the process operation.	EPA would use this information to update the industry profile and to determine if any wastewaters are generated that may warrant effluent limitations or if the process operations affect other wastewater streams that may warrant revisions to those wastewaters’ effluent limits.
A11-3 and A11-4	Asks whether the plant has participated in or plans to participate in a pilot study for a carbon capture system(s). Additionally, if the pilot study evaluated wastewaters generated by the technology, EPA requests copies of the technical evaluation report.	EPA would use this information to identify new technologies and processes that are or may be implemented and the wastewaters associated with the operation.
A11-5 and A11-6	Asks for flow characteristics of the process wastewater generated from the carbon capture system. Also if characterization samples were collected during the study, requests the plant to provide analytical results for the carbon capture wastewater.	EPA would use this information to help characterize process wastewaters generated by carbon capture systems and to determine if any wastewaters are generated that may warrant effluent limitations.
Wet Electrostatic Precipitator Systems
A12-1	Requests information about operating and planned wet electrostatic precipitator (ESP) systems associated with steam electric generating units, including the date of installation, the location of the wet ESP, whether it is a full-scale or pilot-scale system, and the percent of flue gas treated.	EPA would use this information to update the industry profile and to determine if the wet ESP wastewaters may warrant effluent limitations.
A12-2	Requests information about the flow rate, duration, and frequency of the wet ESP wastewater generated by the system	EPA would use this information to identify the amount of wet ESP wastewater generated by the industry.
A12-3 and A12-4	Requests information about the water sources used for wet ESP wastewater and the criteria that the water must meet to be used as a source for wet ESP wastewater.	The responses from these questions would help EPA identify potential water reuse options for power plants.
A12-5	Asks plants to identify the destinations of the wet ESP wastewater.	EPA would use the response from this question to update wastewater management practices associated with wet ESP operations.
A12-6 through A12‑8	Asks whether the plant has participated in a full- or pilot-scale study for a wet ESP system(s) in which the wastewaters generated were evaluated. If so, EPA requests information about the company and the time period of the study, as well as requesting copies of the technical evaluation report. Also if characterization samples were collected during the study, requests the plant to provide analytical results for the carbon capture wastewater.	EPA would use this information to identify wastewater management practices associated with wet ESP operations, identify issues/problems encountered during their operation, and characterize the wet ESP wastewaters. EPA would use this information to determine if the wet ESP wastewaters warrant effluent limitations.
Coal Storage and Processing
A13-1	Asks whether the plant stored or processed any coal during 2009.	EPA would use this question to identify plants that should complete this section of the questionnaire; plants that did not store or process coal during 2009 would skip to the end of the section.
A13-2 through A13‑5	Requests information about the generation, handling, and characteristics of coal pile runoff generated at the plant.	EPA would use this information to characterize the coal pile runoff waste streams generated by the industry and to identify best management practices for handling the waste stream.
A13-6 through A13‑7	Requests information about the coal washing performed at the plant and how the coal wash waters are handled.	EPA would use this information to characterize the coal wash water streams generated by the industry and determine if an effluent limitation may be warranted for the stream. Additionally, EPA would use the information to identify potential best management practices.
A13-8 and A13-9	Requests information about coal blending performed at the plant and whether there are wastewaters generated from the operation.	EPA would use this information to determine whether coal blending operations generate wastewater streams. Additionally, EPA would use the information to identify the volume of coal blending wastewaters generated by the industry to determine if effluent limitations may be warranted.
A13-10 through A13‑15	Requests information about whether the plant pulverizes coal on site and how the plant handles the mill rejects associated with the pulverization process.	EPA would use this information to determine the amount of mill reject sluice generated by the industry to determine if effluent limitations may be warranted. Additionally, EPA would use the information to identify potential best management practices.
A13-16 and A13-17	Asks whether the plant gasified coal, petroleum coke, or oil to operate an IGCC generating unit and whether the plant operates, is constructing/installing, or plans to construct/install an IGCC unit.	EPA would use this information to update the industry profile and evaluate the number of IGCC units currently operating and that will be operated in the future. EPA would use this information in developing effluent limitations.

Part B: Flue Gas Desulfurization (FGD) Systems

Part B collects information on wastewater generated and treated from flue gas desulfurization.

Table 4-2. FGD System Question Justifications
Question Number	Question Description	Purpose of Question
General FGD System Information
B1-1	Asks if the plant operates one or more FGD systems or if the plant is currently constructing/installing or planning to begin constructing at least one FGD system.	EPA would use this question to identify plants that should complete this FGD part of the questionnaire; plants that do not operate or plan to operate a FGD system would not complete Part B of the questionnaire.
B1-2	Requests the plant to include the date the system initially began operation or is planned to begin operation, identify the steam electric units that exhaust to the FGD system, the type of FGD system and sorbent used, whether the system generates a slurry blowdown stream, and the SO₂removal efficiency.	Plants will fill out information for both FGD systems operated in 2009 and planned FGD systems. EPA would use this information to link the generating unit(s) and its specific characteristics to the associated FGD system. In addition, EPA would use the information to characterize FGD operations and to update the industry profile, and as an input to models used to predict the costs associated with FGD wastewater treatment.
Planned FGD System Information
B2-1	Requests the plant to identify the method for handling solids generated, whether a purge stream will be generated, the type of wastewater treatment system planned, the design maximum and 24-hour daily average flow rate for the treatment system, and the date the treatment system will be brought on line for FGD systems that are planned or under construction/installation.	EPA would use the information to update the future industry profile. EPA would use this information to estimate how the industry is expected to change and to estimate the industry-level loadings associated with FGD wastewater discharges and costs associated with treatment of FGD wastewaters. EPA will use this information to estimate the treatment systems planned in the future for use in industry cost analysis. The type of wastewater treatment and design flow rate will be used to predict the industry-wide cost of wastewater treatment in the future industry profile, as well as develop reasonable projections of pollutant reductions.
FGD Additive Information
B3-1	Asks the plant for information about the additive(s) used or planned to be used in each FGD system.	EPA would use the type of additive used in each FGD system to characterize wet FGD operations and to update the industry profile. EPA would also relate the type of additive to the characteristics of the FGD wastewater.
Wet FGD System Information
B4-1	Asks if the plant reported use of a FGD system that generates a slurry blowdown stream (i.e., wet system).	Plants that do not operate a wet FGD system will not complete Part B, Sections 4 through 7, of the questionnaire
B4-2 and B4‑3	Asks the plant to provide the operating concentration range of chlorides within the FGD scrubber absorber and the maximum design chlorides concentration for the FGD system and indicate which equipment unit(s) of the FGD system determines this concentration and the materials of construction for the equipment unit(s).	EPA would use this information to relate the chlorides concentration in the FGD system to the materials of construction for the FGD scrubber absorber and the volume of FGD scrubber purge generation (asked in later questions). This information would be used to help EPA establish trends and predict wastewater generation and characteristics for planned wet FGD systems (i.e., not currently operating).
B4-4 and B4‑5	Asks the plant to provide the FGD system parameters used to control the FGD slurry blowdown from the FGD system and indicate the maximum chlorides concentration and maximum solids percentage that is acceptable for the water used as a source of FGD reagent preparation water or absorber make-up water to be used for those purposes.	The responses from these questions would help EPA identify potential water reuse options for power plants. Plants may increase or decrease the FGD blowdown flow rate for a variety of reasons. Additionally, the flow rates of the blowdown and blowdown recycle are related to the flow rate of water sent to wastewater treatment. These questions will help EPA understand the reasons plants chose to increase or decrease the blowdown rate and may help EPA establish trends and predict wastewater generation for plants that may install FGD units.
B4-6 through B4‑12	Asks the plant to provide the flow rates, durations, frequencies, and sources of the mist eliminator wash water used for the FGD system, the absorber make-up water, the FGD reagent preparation water, and the FGD reagent slurry.	The responses from these questions would help EPA identify potential water reuse options for power plants.
B4-13 through B4‑17	Asks information about the solids generated from the FGD scrubber system including the types of solids that are generated, the percentage of FGD solids within the system, if the solids are combined with other materials, whether a cementitious/pozzolanic material is generated, the methods of solids separation, and the methods of solids dewatering used by the plant.	EPA would use the responses from these questions to identify trends in the industry. The type of solid byproducts produced in a wet FGD system dictate the types of wastewaters generated and the ultimate destination of the solids. Additionally, EPA must identify how the solids are separated and dewatered separately because the methods of separation and dewatering range from settling ponds to combinations of more advanced mechanical separation technologies (e.g., hydrocyclones, vacuum belt filters).
B4-18 through B4‑22	Requests information on FGD solids disposition, FGD solids marketed/sold, and the costs incurred to remove or dispose of FGD solids for the calendar years 2005, 2007, and 2009, the typical maximum and minimum chlorides concentration for the FGD solids, and the parameters that affect the ability of the FGD solids to be marketed, sold and/or given away.	EPA would use the responses from these questions to develop industry-wide estimates for FGD solids disposal and marketing. The responses to these questions would be used by EPA to develop a cost model that incorporates the cost for disposal of particular types of FGD solids and to predict the operations for plants with planned wet FGD systems. As a part of this cost model, EPA requests information on the amount of revenue generated by the selling of FGD solids to incorporate into the cost model.
FGD Wastewater Generation
B5-1 and B5-2	Requests the source(s) and percent contributions of FGD reagent preparation water, absorber make-up water, and the mist eliminator wash water, the absorber type, the typical FGD slurry blowdown flow rate exiting the absorber, the typical range of percent solids of FGD slurry blowdown exiting the absorber, the typical amount of solids separation recycle returned to the absorber, the typical amount of scrubber purge sent to wastewater treatment or discharge, and the typical duration and frequency of scrubber purge generation.	The information in these tables would be used to help EPA establish trends and predict wastewater generation and characteristics for planned wet FGD systems (i.e., not currently operating). The responses will also be used to develop a cost model to predict the costs associated with required FGD wastewater treatment based on specific operating characteristics The information in this table will allow EPA to determine the percent solids of the blowdown and the flow rates of the blowdown, recycle, and purge streams. EPA will relate these factors to characteristics of each wet FGD system (i.e. sorbent, coal chlorine content, etc.). Additionally, EPA will use this information to project purge flow rates and treatment systems costs for plants that do not currently have wet FGD systems. EPA will use this information in cost models and for estimating pollutant reductions.
B5-3	Asks the plant to provide chlorides and solids concentrations of the untreated FGD purge stream transferred to the wastewater treatment system.	The response to this question would be used to help EPA establish trends and predict wastewater generation and characteristics for wet FGD systems. The chlorides and solids concentrations are two factors that affect blowdown and purge flow rates and affect wastewater treatment system design. EPA will use these concentrations to develop a complete mass balance of solids and chlorides within the FGD system.
FGD Monitoring Data
B6-1 and B6‑2	Asks the plant to provide monitoring data collected for the untreated FGD purge stream in an electronic format and to identify the FGD systems and steam electric generating units associated with the monitoring data provided.	EPA would use the monitoring data collected from this question to characterize the FGD scrubber purge stream (including determining a range of pollutant concentrations and evaluating variability in the FGD scrubber purge stream) and evaluate treatability of the FGD scrubber purge stream. EPA would use the FGD systems and steam electric generating units associated with the monitoring data to determine how FGD system and steam electric process operations impact the characteristics of the FGD scrubber purge.
FGD Wastewater Treatment
B7-1 through B7‑3	Asks if the plant transfers the FGD scrubber purge to a settling pond. If it does, the plant is asked to indicate which process wastewaters are commingled with the FGD scrubber purge in the settling pond and to select an option that best describes the configuration of the ponds.	EPA would use the responses from these questions to update the industry profile, which would be used to estimate industry-level loadings associated with FGD wastewater discharges and costs to comply with any regulations. EPA needs to identify plants that use ponds to treat the FGD wastewater independent of other wastewater treatment technologies. Some plants combine the FGD wastewater with other process wastewaters during treatment. Question B7-2 will allow EPA to select and analyze all plants that operate a single FGD treatment system, or combinations of FGD treatment systems.
B7-4 and B7‑5	Asks plants to indicate the wastewater treatment technologies used to treat the FGD scrubber purge and to identify the ultimate destination of the treated FGD scrubber purge.	EPA would use the responses from these questions to update the industry profile, which would be used to estimate industry-level loadings associated with FGD wastewater discharges and costs to comply with any regulations. Question B7-4 is necessary to determine the possible combinations of wastewater treatment technologies used to treat FGD scrubber purge. Question B7-5 is necessary to determine the ultimate destination of FGD wastewaters after treatment. EPA will use these questions to develop industry-wide trends.
B7-6 and B7‑7	Asks plants that produce gypsum from wet FGD systems to identify if gypsum-related waters are generated and, if so, asks the average volume of the gypsum-related waters generated per day. Also asks the plants to indicate how the gypsum-related waters are handled.	EPA would use the responses from these questions to establish trends and predict wastewater generation and characteristics for planned wet FGD systems. Plants may temporarily store gypsum and/or wash the gypsum prior to hauling off site. This question is necessary to collect information on gypsum wash water and gypsum pile runoff, which may contain chlorides and other pollutants present in the gypsum material.
Dry FGD System Information
B8-1	Asks if the plant reported use of a dry FGD system.	Plants that do not operate a dry FGD system will not complete Part B, Section 8 of the questionnaire.
B8-2 and B8‑3	Asks the plant to indicate how the FGD solid is removed from the flue gas and if the FGD system is located upstream or downstream of the fly ash collection system.	EPA would use the responses from these questions to assess whether fly ash would be marketable.
B8-4 through B8-6	Asks the plant to provide information about FGD reagent preparation water.	The response from this question would help EPA identify potential water reuse options for power plants.
B8-7 through B8‑10	Asks the plant to indicate if any FGD wastewaters are generated from the operation of the dry FGD scrubber, identify the ultimate destination of the FGD wastewater, indicate if any FGD wastewaters are generated from cleaning the dry FGD scrubber, and identify the ultimate destination of the FGD wastewater for cleaning.	EPA would use the responses to these questions to identify wastewater generation and management practices associated with dry FGD operations. These questions ask the plant to identify any potential wastewaters associated with dry scrubber operation and the destination of those wastewaters. Although EPA does not anticipate that there is much wastewater generated from dry FGD systems, this will provide EPA with a definitive answer.
B8-11 through B8‑14	Requests information on FGD solids disposition, FGD solids marketed/sold, and total costs incurred to remove or dispose of FGD solids for calendar years 2005, 2007, and 2009. Also asks what parameters affect the ability of the FGD solids to be marketed, sold and/or given away.	EPA would use the responses from these questions to identify trends in the industry and develop industry-wide estimates for FGD solids disposal and marketing associated with dry FGD systems. The responses to these questions will also be used by EPA to develop a cost model for estimating the costs of converting from a wet FGD system to a dry system. EPA needs to develop industry-wide estimates for how much solids are sold and disposed of in landfills. Also, knowing whether the sold material is landfilled permanently or temporarily will help identify which plants may need to install runoff/leachate controls within the landfills.

Part C: Ash Handling

Part C collects information on wastewater generated and treated from the handling of ash from coal-, petroleum coke-, or oil-fired generating units.

Table 4-3. Ash Handling Question Justifications
Question Number	Question Description	Purpose of Question
Ash Handling Systems
C1-1	Asks if the plant generates ash in any of its steam electric generating units.	Plants that do not generate ash in any of their steam electric generating units do not need to complete Part C.
C1-2	Asks the plant for total acreage of the plant. Question also requests acreage for specific area categories at the plant.	EPA will use this information to determine the total acreage of the plant, along with developed and undeveloped areas.
Fly Ash Handling – System Level Information
C2-1	Asks if the plant generates fly ash in any of its steam electric generating units.	Plants that do not generate fly ash in any of their steam electric generating units do not need to complete the remainder of Part C, Section 2.
C2-2	Requests that plants identify all fly ash handling systems located at the plant. For each handling system identified, plants are asked to provide the type of fly ash collection system, amount of fly ash produced, the design handling rate, and the loss on ignition and class of fly ash.	EPA will use this information to update the industry profile. Specifically, this question identifies the number of wet and dry fly ash handling systems in the industry (for all coal-fired and a subset of oil-fired generating units), which EPA would use to estimate compliance costs for potential regulatory options and to estimate pollutant reductions.
Fly Ash Handling – Unit Level information
C2-3	Requests information on all fly ash handling systems that service each steam electric generating unit at the plant, including the percentage of ash that is handled by each defined system and the number of days that ash was handled.	Informs EPA of the number of fly ash handling systems currently operated. This information also develops fly ash handling system profiles for the industry. This information can help EPA identify wastewaters that are generated.
C2-4 through C2-7	Questions request information regarding wet and dry systems that service ash from one unit, the reasons why multiple fly ash handling systems are necessary, the modifications that would be required to convert to a completely dry fly ash handling system, and changes in fly ash handling operations.	EPA will use this information to determine the reasons and/or challenges associated with converting from a wet to dry fly ash handling system.
Fly Ash Handling Information
C2-8 and C2‑10	Questions ask for the type of dry fly ash handling system, any unscheduled boiler outages caused by the system between 2005 and 2009, length of outages, reasons for the outages and methods used to resolve the outages.	This information informs EPA of additional costs, beyond capital/operating costs, associated with a conversion from wet to dry fly ash handling.
C2-11 and C2-12	Asks whether dry fly ash handling system was installed with the generating unit or was a retrofit, requests shutdown time for retrofits, and whether the retrofit was completed during a regularly scheduled outage.	Informs EPA of additional cost, beyond capital/operating costs, associated with conversion to dry fly ash handling.
C2-13 through C2‑15	Requests if the retrofit was made to an existing dry system or if it was a conversion from wet to dry. Also requests the reasons for the retrofit from a wet to dry system or changes to an existing dry system and the changes required for the retrofit.	EPA would use this information to assess/predict the number of plants/generating units that may convert to dry fly ash handling, apart from a potential EPA requirement. Also allows better understanding of conversion costs.
Dry Fly Ash Handling Information
C2-16	Requests dry fly ash transport/storage information including type of destination, distance and amount transported, the method of transportation, and percent moisture of the fly ash.	EPA would use this information to compare operating costs obtained for dry fly ash handling systems.
C2-17	Asks if they dry fly ash is combined with FGD solids to form a pozzolanic material.	EPA would use this information to understand all possible destinations of dry fly ash.
C2-18 and C2-19	Asks if and to which destinations the dry fly ash was marketed in 2005, 2007, and 2009, and the gross revenue generated. Also requests the typical percent moisture of the fly ash marketed.	Informs EPA of potential revenue that would offset dry fly ash handling system costs.
C2-20	Requests the highest LOI at which fly ash can be marketed.	EPA would use this information to assess/predict the number of plants that could market their fly ash.
C2-21 through C2-23	Requests the source of water used to moisten ash and the criteria plant uses to determine if a water source is acceptable or unacceptable for that purpose.	Identifies potential water reuse options for power plants.
Wet Fly Ash Handling Information
C2-24	Requests the fly ash sluice flow rate, duration and frequency of sluicing, sources of sluice water, and percent contribution of source to sluice water flow for each coal- or oil-fired generating unit in 2009.	Informs EPA of amount of fly ash wastewater generated (sluice flow rate and frequency), which EPA would use in consideration of technology options, and identifies potential water reuse options for power plants.
C2-25 and C2-26	Requests the distance between hoppers and dry to wet mixing junction, number of junctions, destinations of wet fly ash, and distance between wet-to-dry junction and ash pond or other final destination.	Informs EPA of the equipment needed to convert systems to dry fly ash handling.
C2-27 and C2-28	Requests criteria plant uses to determine if a water source is acceptable or unacceptable for use as fly ash sluice water.	Identifies potential water reuse options for power plants.
C2-29 and C2-30	Asks if the plant has had any unscheduled boiler outages due to the wet fly ash handling system between 2005 and 2009, length of outages, reasons for outages, and methods used to resolve outages.	This information informs EPA of additional costs, beyond capital/operating costs, associated with wet fly ash handling.
C2-31 through C2‑34	Asks about installation of dry fly ash handling systems, the modifications required, the planned destinations for the fly ash, and if and to which destinations the plant plans to sell the dry fly ash.	Better informs EPA of the number of plants/generating units that may install dry fly ash handling systems, apart from a potential EPA requirement, and the potential costs for conversion/installation.
C2-35	Asks if and to which destinations wet fly ash was marketed in 2005, 2007, and 2009, and the gross revenue generated. Also requests the typical percent moisture of the fly ash marketed.	Informs EPA of potential revenue that would offset wet fly ash handling system costs, especially compared to dry fly ash potential revenue.
C2-36	Question asks plants that are currently not installing or planning to install dry fly ash handling systems whether installation/conversion has ever been considered and requests associated documentation/costs.	Informs EPA of the potential costs of conversion/installation for plants are currently not installing or planning to install dry fly ash handling systems.
Fly Ash Handling Cost Information
C2-37	Asks plants to identify all major components of the fly ash conveyance system.	This information will help EPA appropriately develop compliance costs and understand variations in costs from different ash handling systems.
C2-38	Requests a block diagram that shows the fly ash handling system.	EPA would use the block diagram to verify, interpret, and clarify the information provided in Question C2-33.
C2-39 and C2-40	Asks if a contractor was hired to install/construct or operate/maintain any aspect of the fly ash conveyance system.	Informs EPA of any costs that need to be adjusted based on the involvement of a contractor.
C2-41 and C2-42	Requests operation and maintenance (O&M) costs for fly ash handling systems operated in 2009, and capital costs for fly ash conveyance system.	EPA would use this cost information to estimate compliance costs for the industry to install the conveyance portion of a new fly ash handling systems.
C2-43	Asks about intermediate storage for ash.	Determines if respondents need to answer the remainder of Part C, Section 2.6.
C2-44 through C2‑46	Asks whether and with which ash handling systems the fly ash handling system shares intermediate storage components, which components are shared, if a pond/impoundment is the intermediate storage or final destination of the fly ash collected, and whether the plant has already provided cost information for the intermediate storage portion of the fly ash handling system and if so, the amount of shared costs.	Determines if respondents need to answer the remainder of Part C, Section 2.6. Also informs EPA of how components/costs are shared between multiple ash handling systems.
C2-47	Asks plants to identify all major components of the fly ash intermediate storage system.	This information will help EPA appropriately develop compliance costs and compare costs from different ash handling systems.
C2-48 and C2-49	Asks if a contractor was hired to install/construct or operate/maintain any aspect of the fly ash intermediate storage system.	Informs EPA of any costs that need to be adjusted based on the involvement of a contractor.
C2-50 and C2-51	Requests operation and maintenance (O&M) costs for fly ash handling systems operated in 2009, and capital costs for the intermediate storage portion of the fly ash handling system.	EPA would use this cost information to estimate compliance costs for the industry to install the intermediate storage portion of a new fly ash handling systems.
C2-52 through C2‑54	Asks whether and with which ash handling systems the fly ash handling system shares transport/disposal components, which components are shared, if a pond/impoundment is the final destination of the fly ash collected, whether the plant has already provided cost information for the transport/disposal portion of the fly ash handling system and if so, the amount of shared costs.	Determines if respondents need to answer the remainder of Part C, Section 2.7. Also informs EPA of how components/costs are shared between multiple ash handling systems.
C2-55	Asks about the methods used to transport the ash to the final destination.	Determines the different transport options the industry is utilizing for fly ash. EPA will also use this information to relate capital and O&M costs to different transport/disposal processes.
C2-56 and C2-57	Asks if a contractor was hired to install/construct or operate/maintain any aspect of fly ash transport/disposal.	Informs EPA of any costs that need to be adjusted based on the involvement of a contractor.
C2-58 and C2-59	Requests operation and maintenance (O&M) costs for fly ash handling systems operated in 2009, and capital costs for fly ash transport/disposal.	EPA would use this cost information to estimate compliance costs for the industry to install the transport/disposal portion of a new fly ash handling systems.
Bottom Ash Handling – System Level Information
C3-1	Asks if the plant generates bottom ash in any of its steam electric generating units.	Plants that do not generate bottom ash in any of their steam electric generating units do not need to complete the remainder of Part C, Section 3.
C3-2	Requests that plants identify all bottom ash handling systems located at the plant. For each handling system identified, plants are asked to provide the type of boiler, amount of bottom ash produced, typical percent moisture of the bottom ash, the design handling rate, the loss on ignition for bottom ash produced, and the class of bottom ash.	EPA will use this information to update the industry profile. Specifically, this question identifies the number of wet and dry bottom ash handling systems in the industry (for all coal-fired and a subset of oil-fired generating units), which EPA would use to estimate compliance costs for potential regulatory options and to estimate pollutant reductions.
Bottom Ash Handling Information
C3-3 and C3‑4	Requests information on the type of boiler used and the bottom ash handling systems that service each steam electric generating unit, including the percentage of ash that is handled by each system, and the number of days that ash was handled.	Informs EPA of the number of bottom ash handling systems currently operated. This information will also help develop a bottom ash handling system profile of the industry. This information can help EPA identify wastewaters that are generated.
C3-5 through C3-8	Questions request information regarding wet and dry systems that service ash from one unit, the reasons why multiple bottom ash handling systems are necessary, the modifications that would be required to convert to a completely dry bottom ash handling system, and changes in bottom ash handling operations.	EPA will use this information to determine the reasons and/or challenges associate with converting from a wet to dry bottom ash handling system.
Dry Bottom Ash Handling Information
C3-9	Asks if the plant operates a mechanical drag system.	EPA would use this information to compare costs obtained for dry bottom ash handling systems/conversions.
C3-10 and C3-11	Asks if the plant has had any unscheduled boiler outages due to the dry bottom ash handling system between 2005 and 2009, length of outages, reasons for outages, and methods used to resolve outages.	This information informs EPA of additional costs, beyond capital/operating costs, associated with a conversion from wet to dry bottom ash handling.
C3-12	Asks whether dry bottom ash handling system was installed with the generating unit or was a retrofit, requests shutdown time for retrofits, and whether the retrofit was completed during a regularly scheduled outage.	Informs EPA of additional cost, beyond capital/operating costs, associated with conversion to dry bottom ash handling
C3-13 through C3‑16	Asks whether the retrofit was to an existing dry bottom ash handling system or a conversion from wet to dry. Requests the reasons for the retrofit from the wet to dry system or changes to an existing dry system. Also requests the changes required for the retrofit.	EPA would use this information to assess/predict the number of plants/generating units that may convert to dry bottom ash handling, apart from a potential EPA requirement. Also allows better comparison of conversion costs received.
C3-17	Requests engineering process diagrams for the retrofit.	Informs EPA of factors potentially impacting the feasibility of future dry bottom ash handling retrofits and options for addressing the factors.
C3-18	Requests dry bottom ash transport/storage information, including destination, distance and amount transported, method of transportation, and percent moisture of bottom ash.	EPA would use this information to compare operating costs obtained for dry bottom ash handling systems.
C3-19 and C3-20	Asks if and to which industries the dry bottom ash was marketed in 2005, 2007, and 2009, and the gross revenue generated.	Informs EPA of potential revenue that would offset dry bottom ash handling system costs.
Wet Bottom Ash Handling Information
C3-21 and C3-25	Requests bottom ash sluice flow rate, duration and frequency of sluicing, sources of sluice water, and percent contribution of source to sluice water flow, and the destination of the sluice water for each coal- or oil-fired generating unit in 2009.	Informs EPA of amount of bottom ash wastewater generated (sluice flow rate and frequency), which EPA would use in consideration of technology options, and identifies potential water reuse options for power plants.
C3-22 and C3-23	Requests criteria plant uses to determine if a water source is acceptable or unacceptable for use as bottom ash sluice water.	Identifies potential water reuse options for power plants.
C3-24 and C3-26	Requests solids removal information for the wet ash sluice system, including the type of solids removal, the type of solid waste disposal, and the amount and percent moisture of ash disposed..	Identifies the number of wet bottom ash handling systems in the industry that are able to use methods other than ash ponds to remove ash solids and how effective the methods are. EPA would use this information for evaluation of potential technology options for bottom ash handling.
C3-27 and C3-28	Requests the amount of wastewater overflow from solids removal, amount of wastewater re-used, and a description of how/where the water is re-used.	Informs EPA of possible effectiveness of these solids removal methods as technology options, and identifies potential water reuse options for power plants.
C3-29 and C3-30	Asks if the wet bottom ash handling system caused any unscheduled boiler outages between 2005 and 2009, length of outages, reasons for outages, and methods used to resolve outages.	This information informs EPA of additional costs, beyond capital/operating costs, associated with wet bottom ash handling.
C3-31 through C3‑34	Asks about installation of dry bottom ash handling systems, the modifications required, the planned destinations for the bottom ash, and if and to which destinations the plant plans to sell the dry bottom ash.	Better informs EPA of the number of plants/generating units that may install dry bottom ash handling systems, and the potential costs for installing dry bottom ash handling systems.
C3-35	Asks if and to which destinations wet bottom ash was marketed in 2005, 2007, and 2009, and the gross revenue generated. Also requests the typical percent moisture of the bottom ash marketed.	Informs EPA of potential revenue that would offset wet bottom ash handling system costs.
C3-36	Question asks plants that are currently not installing or planning to install dry bottom ash handling systems whether installation/conversion has ever been considered and requests associated documentation/costs.	Informs EPA of the potential costs of conversion/installation for plants are currently not installing or planning to install dry bottom ash handling systems.
Bottom Ash Handling Cost Information
C3-37	Asks plants to identify all major components of the bottom ash conveyance system.	This information will help EPA appropriately develop compliance costs and understand variations in costs from different ash handling systems in the industry.
C3-38	Requests a block diagram that shows the bottom ash handling system.	EPA would use the block diagram to verify, interpret, and clarify the information provided in Question C3-33.
C3-39 and C3-40	Asks if a contractor was hired to install/construct or operate/maintain any aspect of the bottom ash conveyance system.	Informs EPA of any costs that need to be adjusted based on the involvement of a contractor.
C3-41 and C3-42	Requests operation and maintenance (O&M) costs for bottom ash handling systems operated in 2009, and capital costs for bottom ash conveyance handling systems.	EPA would use this cost information to estimate compliance costs for the industry to install the conveyance portion of a new bottom ash handling systems.
C3-43	Asks about intermediate storage for ash.	Determines if respondents need to answer the remainder of Part C, Section 3.6
C3-44 through C3‑46	Asks whether and with which ash handling systems the bottom ash handling system shares intermediate storage components, which components are shared, if a pond/impoundment is the intermediate storage or final destination of the bottom ash collected, and whether the plant has already provided cost information for the intermediate storage portion of the bottom ash handling system and if so, the amount of shared costs.	Determines if respondents need to answer the remainder of Part C, Section 3.6. Also informs EPA of how components/costs are shared between multiple ash handling systems.
C3-47	Asks plants to identify all major components of the bottom ash intermediate storage system.	This information will help EPA appropriately develop compliance costs and compare costs from different ash handling systems.
C3-48 and C3-49	Asks if a contractor was hired to install/construct or operate/maintain any aspect of the bottom ash intermediate storage system.	Informs EPA of any costs that need to be adjusted based on the involvement of a contractor.
C3-50 and C3‑51	Requests operation and maintenance (O&M) costs for bottom ash handling systems operated in 2009, and capital costs for bottom ash intermediate storage.	EPA would use this cost information to estimate compliance costs for the industry to install the intermediate storage portion of a new bottom ash handling systems.
C3-52 through C3‑54	Asks whether and with which ash handling systems the bottom ash handling system shares transport/disposal components, which components are shared, if a pond/impoundment is the final destination of the bottom ash collected, whether the plant has already provided cost information for the transport/disposal portion of the bottom ash handling system and if so, the amount of shared costs.	Determines if respondents need to answer the remainder of Part C, Section 2.7. Also informs EPA of how components/costs are shared between multiple ash handling systems.
C3-55	Asks about the methods used to transport the ash to the final destination.	Determines the different transport options the industry is utilizing for bottom ash. EPA will also use this information to relate capital and O&M costs to different transport/disposal processes.
C3-56 and C3-57	Asks if a contractor was hired to install/construct or operate/maintain any aspect of bottom ash transport/disposal.	Informs EPA of any costs that need to be adjusted based on the involvement of a contractor.
C3-58 and C3-59	Requests operation and maintenance (O&M) costs for bottom ash handling systems operated in 2009, and capital costs for bottom ash transport/disposal.	EPA would use this cost information to estimate compliance costs for the industry to install the transport/disposal portion of a new bottom ash handling systems.
Combined Fly Ash and Bottom Ash Handling Cost Information
C4-1	Asks whether any fly ash and bottom ash handling systems share intermediate storage or transport/disposal components.	Determines if respondents need to answer the remainder of Part C, Section 4.
C4-2	Requests plants to identify which ash handling systems share intermediate storage or transport/disposal components.	Informs EPA of which ash handling systems share costs.
C4-3 and C4‑4	Asks whether any fly ash and bottom ash handling systems share intermediate storage components, which components are shared, and , if a pond/impoundment is the intermediate storage or final destination of the combined ash.	Determines if respondents need to answer the remainder of Part C, Section 4.2. Also informs EPA of how components/costs are shared between fly ash and bottom ash handling systems
C4-5	Asks plants to identify all major components of the combined fly ash and bottom ash intermediate storage system.	This information will help EPA appropriately develop compliance costs and compare costs from different ash handling systems.
C4-6 and C4‑7	Asks if a contractor was hired to install/construct or operate/maintain any aspect of the combined fly ash and bottom ash intermediate storage system.	Informs EPA of any costs that need to be adjusted based on the involvement of a contractor.
C4-8 and C4‑9	Requests operation and maintenance (O&M) costs for the combined fly ash and bottom ash handling systems operated in 2009, and capital costs for combined fly ash and bottom ash intermediate storage.	EPA would use this cost information to estimate compliance costs for the industry to install the intermediate storage portion of a new combined fly ash and bottom ash handling systems.
C4-10 and C4-11	Asks whether any fly ash and bottom ash handling systems share transport/disposal components, which components are shared, and , if a pond/impoundment is the final destination of the combined ash.	Determines if respondents need to answer the remainder of Part C, Section 4.3. Also informs EPA of how components/costs are shared between fly ash and bottom ash handling systems
C4-12	Asks about the methods used to transport the ash to the final destination.	Determines the different transport options the industry is utilizing for combined fly ash and bottom ash. EPA will also use this information to relate capital and O&M costs to different transport/disposal processes.
C4-13 and C4-14	Asks if a contractor was hired to install/construct or operate/maintain any aspect of combined fly ash and bottom ash transport/disposal.	Informs EPA of any costs that need to be adjusted based on the involvement of a contractor.
C4-15 and C4-16	Requests operation and maintenance (O&M) costs for combined fly ash and bottom ash handling systems operated in 2009, and capital costs for combined fly ash and bottom ash transport/disposal.	EPA would use this cost information to estimate compliance costs for the industry to install the transport/disposal portion of a new combined fly ash and bottom ash handling systems.
Economizer Ash Handling Information (steam electric generating unit level)
C5-1	Asks whether economizer and air heater ash are handled together.	Determines if respondents need to answer any of Part C, Section 6.
C5-2 through C5-6	Requests amount and destination of economizer ash produced, the type of economizer ash handling system, whether economizer ash wastewater is generated, and the amount and destination of the wastewater.	Informs EPA of the amount of economizer ash handled in a wet fashion and whether dry economizer ash handling should be considered as a potential control technology (or other alternatives).
Air heater Ash Handling Information
C6-1 through C6-5	Requests amount and destination of air heater ash produced, the type of air heater ash handling system, whether air heater ash wastewater is generated, and the amount and destination of the wastewater.	Informs EPA of the amount of air heater ash handled in a wet fashion and whether dry handling should be considered as a potential control technology (or other alternatives).

Part D: Pond/Impoundment Systems and Other Wastewater Treatment Operations

Part D collects information on pond systems and other wastewater treatment operations.

Table 4-4. Pond/Impoundment Systems and Other Wastewater Treatment Operations Question Justifications
Question Number	Question Description	Purpose of Question
D1-1 and D1‑2	Asks about the use of ponds/impoundments for the storage, treatment, and/or disposal of residues or by-products from the combustion of coal, petroleum coke, or oil; and wastewater treatment systems for ash handling or FGD process wastewaters.	These questions determine if respondents should answer any sections regarding Part D. Respondents that reply “No” to both of these questions are not required to complete Part D.
Pond/Impoundment System and Wastewater Treatment System Identification
D2-1 through D2‑4	Asks about wastewater treatment pilot studies and whether the studies are ongoing. Additionally, requests reports from the pilot and full-scale studies, a description of the studies, and a list of any FGD wastewater treatment technologies explored by the plant, not covered in the pilot or full-scale request.	EPA will use the information to identify the types of wastewater treatment systems that are being investigated by the industry. Additionally, pilot study reports will help EPA understand the reasons why a technology option may or may not be feasible for plants with similar characteristics.
D2-5	Asks about operation of pond/impoundment systems and/or wastewater treatment systems for the treatment of process waters from ash handling or FGD operations.	This question determines if it is necessary for respondents to complete the remainder of Section 2 and Section 3.
D2-6	Identifies pond systems located (or planned to be located) at the plant for the treatment of wastewaters from ash handling or FGD operations. Identifies which pond/impoundment units are included in each pond system.	EPA would use the information collected from this question to identify pond systems operated or planned to be operated by the plant. The question assigns system IDs which will be used to identify the systems in later questions. EPA would also use this information to link the pond/impoundment unit(s) and its specific characteristics (identified in Part A) to the pond system.
D2-7	Identifies wastewater treatment systems (other than pond systems) that the plant operates or plans to operate for the treatment of wastewaters from ash handling or FGD operations.	EPA would use the information collected from this question to identify wastewater treatment systems (other than pond systems) operated or planned to be operated by the plant. The question assigns system IDs which will be used to identify the systems in later questions.
Wastewater Treatment Diagram and Wastewater Flows (wastewater treatment system level)
D3-1	Requests block diagrams for each pond and wastewater treatment system identified in Tables D-1 and D-2.	EPA would use the block diagrams as a guide to understand the operation of the pond or wastewater treatment systems. The diagrams would help EPA understand the physical configuration of the pond or wastewater treatment units (e.g., operated in parallel or series).
D3-2 and D3‑3	Requests influent and effluent wastewater flow information for each pond and wastewater treatment system operated or planned to be operated by the plant. The question also requests the amount of solids or sludge leaving the pond or wastewater treatment system, and the destination of the wastewater/solids.	EPA would use the information to determine the types of wastewaters that are treated by pond and wastewater treatment systems at steam electric power plants. Additionally, EPA will use the information to identify wastewater reuse opportunities in the industry. EPA would use the flow rate information for sizing equipment technology options and estimating compliance costs for regulatory options.
Active/Inactive/Open and Planned Pond/Impoundment Units (pond/impoundment level)
D4-1	Asks if the plant uses ponds/impoundments for the storage, treatment, and/or disposal of residues or by-products from the combustions of coal, petroleum coke, or oil.	Question determines if respondents are required complete the remainder of this section.
D4-2	Requests the residence time, life expectancy, and number of cells for each active/open and planned pond/impoundment unit at the plant.	EPA would use the responses from these questions to characterize the specific pond/impoundment unit(s) comprising the pond system to understand the specific characteristics that may affect the costs for the pond system. EPA would use the pond/impoundment characteristics to estimate compliance costs.
D4-3	Requests information about the pond/impoundment unit volume, surface area, top and bottom elevation, maximum height of the berm/dam, and freeboard height. Requests this as design information for planned units.	EPA would use the responses from these questions to establish a relation between pond/impoundment size and costs. EPA will use the relationship to estimate the cost for a plant to install a new pond/impoundment system for the treatment of FGD or ash wastewaters.
D4-4	Asks about pond/impoundment liners characteristics.	EPA would use the liner information in the industry profile and to identify best management practices in pond/impoundment unit design.
D4-5 through D4-9	Requests information on pond/impoundment dredging practices and pond/impoundment expansions.	EPA would use the responses from these questions to update the industry profile and identify best management practices for the handling of solids from pond/impoundment units and expanding pond/impoundment units.
D4-10 and D4-11	Requests the pollutants targeted for removal by the pond by techniques other than settling and which pollutant limitations are driving the operation of the pond/impoundment.	EPA would use this information to determine whether and how plants are operating pond systems to target specific analytes using techniques in addition to gravity settling. EPA will use the responses to evaluate best management practices for the industry.
D4-12	Requests information on chemicals used in the pond/impoundment unit including dose, purpose of chemical, location of chemical addition, addition rate, and frequency of addition.	EPA would use the responses from this question to identify industry practices for chemical treatment in pond/impoundment units and to identify best management practices.
Closed Pond/Impoundment Units (pond/impoundment level)
D4-13	Asks if the plant has pond/impoundments that have been closed (on or after January 1, 2000) that were used for the storage, treatment, and/or disposal of residues or by-products from the combustions of coal, petroleum coke, or oil.	Question determines if respondents are required to complete the remainder of this section.
D4-14 and D4-15	Requests the date of closure, pond/impoundment life duration, and number of cells for all the closed pond/impoundment units at the plant. Additionally, a question requests the volume, surface area, top and bottom elevation, maximum height of the berm/dam, and freeboard height of the pond/impoundment units.	EPA would use the information from this question to identify trends in the life of pond systems in the industry. EPA would use the size information to establish a relation between pond/impoundment size and costs. EPA would use the relationship to estimate the cost for a plant to install a new pond/impoundment system for the treatment of FGD or ash wastewaters.
D4-16 and D4-17	Requests information about liner characteristics for closed pond/impoundment units at the plant. Also requests the information for the cap/cover of the closed pond/impoundment units.	EPA would use the liner and cap/cover materials and permeability in the industry profile and to identify best management practices in pond/impoundment unit design.
D4-18 and D4-20	Asks if the pond/impoundment was expanded during its life and requests details about the pond/impoundment expansion.	EPA would use the responses from these questions to identify if and how the industry expands their pond/impoundment units and identify best management practices associated with pond/impoundment expansions.
D4-21 and D4-22	Asks if the plant had a closure plan for the pond/impoundment unit, requests a copy of the plan, a description of the closure process, and costs associated with the closure.	EPA would use the information to identify best management practices associated with closing a pond/impoundment unit. EPA may use the cost information when evaluating the cost to convert from a wet ash handling system to a dry ash handling system.
D4-23	Asks if the plant has built any structures on top of the closed pond/impoundment.	EPA would use the information to identify opportunities and potential space available to further develop the facility area.
D4-24	Requests information on long-term groundwater, soil or overflow monitoring of the closed pond/impoundment.	EPA would use the responses from this question to identify best management practices associated with groundwater, soil, and overflow monitoring of closed pond/impoundment units.
Wastewater Treatment Unit Information for Other Wastewater Treatment Systems
D5-1	Asks if the plant identified any wastewater treatment systems in Table D-2.	Question determines if the respondents need to complete the remainder of this section.
D5-2	Asks about the wastewater treatment systems, on the unit level, at the plant. Also requests the plant designation, the date the unit was added to the wastewater treatment system, the volume, surface area, residence time, and materials of construction for each unit in the wastewater treatment system.	EPA would use this information to identify the unit operations comprising each wastewater treatment system and to update the industry profile. EPA would also use the information when evaluating the costs of the wastewater treatment systems (e.g., identify why some systems are more expensive than others).
D5-3	Requests the average and maximum design flow rate, the typical and maximum system flow rates in 2009, and the duration and frequency of the effluent transfers in 2009.	EPA would use the flow rate information to establish a relationship between the flow rate and cost of the wastewater treatment system. EPA would use the relationship to estimate compliance costs for plants that would be required to install wastewater treatment systems based on actual or predicted wastewater flow rates.
D5-4 and D5‑5	Requests the pollutants targeted for removal by the treatment unit by techniques other than settling and which pollutant limitations are driving the operation of the unit.	EPA would use this information to determine whether and how plants are operating wastewater treatment systems to target specific analytes. EPA would use the responses to evaluate best management practices for the industry.
D5-6 and D5‑7	Asks if the wastewater treatment system has the capability for sulfide precipitation and if sulfide is currently being added to wastewater treatment system.	EPA would use this information to determine which wastewater treatment systems have the capability of adding sulfide and how many facilities are actually adding sulfide. This would help EPA associate and develop compliance costs with the necessity of chemical addition to reach certain limits or standards.
D5-8 through D5‑10	The questions also ask the plants to provide information on any impacts that climate or space available may have had on the design and cost of the wastewater treatment system. The bid proposal/engineering report for the wastewater treatment system is also requested.	EPA will collect information on the impacts of climate and space availability to provide ranges in the compliance costs developed regarding the industry. EPA would use the bid proposal/engineering reports to gain a better understanding of the wastewater treatment system to account for variations in costs for the treatment systems.
D5-11 and D5-12	Requests information on any planned improvements to existing wastewater treatment systems.	EPA would use this information to identify potential improvements that can be done to a wastewater treatment system to achieve certain limits. Without this question, EPA would not account for planned improvements when developing technology options for the industry.
D5-13	Requests information on chemicals used in the wastewater treatment unit including dose, purpose of chemical, addition rate, and frequency of addition.	EPA would use the responses from this question to identify industry practices for chemical treatment in wastewater treatment systems and identify best management practices.
Wastewater Treatment System Costs (wastewater treatment system level)
D6-1	Asks if any pond/impoundment systems and/or wastewater treatment systems were defined in Tables D-1 and D-2.	Question determines if respondents are required to complete the remainder of this section.
D6-2 and D6‑3	Requests operation and maintenance (O&M) cost information for each pond and wastewater treatment system operated in 2009. The question specifically requests the cost of labor, chemicals, energy, steam, and sludge disposal. Requests capital cost information for each current and planned pond and wastewater treatment system at the plant including direct costs (e.g. buildings and land) and indirect costs (e.g. engineering costs and contractor expenses).	EPA would use this information to develop compliance costing estimates. EPA would use the O&M and capital costs to estimate an annualized cost for the various wastewater treatment options for compliance purposes.
D6-4 and D6‑5	Asks whether FGD wastewater treatment system was installed with the FGD system or was a retrofit. Also asks if the FGD wastewater treatment system was purchased as part of the FGD scrubber purge package.	This question will be incorporated into the cost of compliance for installing a new FGD system for plants that have existing wastewater treatment technologies that may be retrofitted.
D6-6	Asks plants to identify the major equipment included in the wastewater treatment system that are included in the capital costs provided in question E5-2.	EPA would use this information to evaluate differences in capital costs provided by plants with similar wastewater treatment systems.

Part E: Wastes from Cleaning Metal Process Equipment

Part E collects information on wastewater generation and treatment of wastes from cleaning metal process equipment at the plant.

Table 4-5. Wastes from Cleaning Metal Process Equipment Question Justifications
Question Number	Question Description	Purpose of Question
Metal Cleaning Operations
E1-1	Asks whether the plant generated wastes from cleaning metal processing equipment since January 1, 2000.	EPA would use this information to identify plants that should complete the metal cleaning wastes section of the ICR/questionnaire; plants that have not generated wastes from cleaning metal processing equipment since January 1, 2000 would not complete Part E of the questionnaire.
Generating Unit Cleaning Data
E2-1 and E2-2	Requests information about the chemicals used, average dose and amount added for each chemical, source of water used, volume of wastewater generated, and frequency of cleaning for each metal cleaning operation performed by steam electric generating unit.	EPA would use this information to identify the types of metal cleaning operations performed by the industry to determine if revisions to the existing regulations are necessary. EPA would also use the information to characterize wastewaters generated by metals cleaning operations, and identify potential water reuse operations and best management practices. If needed, EPA would also use this information to calculate industry-level estimates for the wastewater discharges.
Cleaning Operation Data
E3-1	Requests a description of the metal cleaning operation.	EPA would use the responses to this question to characterize the metal cleaning operations to identify best management practices associated with the wastewater generation.
E3-2 and E3‑3	Asks whether the metal cleaning wastes are commingled with other wastewaters and if so, identify other wastewaters. Also requests the ultimate destination of the treated cleaning wastes.	EPA would use the information from these questions to identify trends in the industry and characterize the best management practices for the metal cleaning wastewaters. EPA would also use the information to identify wastewater treatment systems being used to treat the metal cleaning wastewaters.
E3-4 through E3‑6	Asks whether residues or other solid by-products are generated from the metal cleaning operation. If so, asks whether the residues are considered hazardous wastes and the characteristics that make the waste hazardous.	EPA would use this question to identify plants that should complete the remaining questions about solid by-product generation associated with metal cleaning wastes; plants that do not generate solid by-products from metal cleaning operations would not need to complete the remaining questions. EPA would also use this information to characterize the solid by-product generation associated with metal cleaning wastes and identify industry trends.
E3-7 and E3‑8	Requests information on the handling and storage of residues or solid by-products from the metal cleaning operations.	EPA would use the responses from these questions to identify best management practices associated with the handling of metal cleaning waste residues and solid by-products.

Part F: Management Practices for Ponds/Impoundments and Landfills

Part F collects information on the best management practices used for ponds, impoundments, and landfills located at steam electric power plants.

Table 4-6. Management Practices for Pond/Impoundment Units and Landfills Question Justifications
Question Number	Question Description	Purpose of Question
Pond/Impoundment and Landfill Use
F1-1	Asks if the plant has active/inactive/open or retired/closed ponds/impoundments or landfills used for the storage, treatment, and/or disposal of residues or byproducts from the combustion of coal.	EPA would use this information to identify plans that should complete Part F of the questionnaire.
Pond/Impoundment Management Practices
F2-1	Requests embankment materials of construction.	The embankment materials of construction affect the structural integrity of the embankment. EPA would use this information to identify industry trends in embankment construction and to identify best management practices.
F2-2 through F2‑4	Requests information on hydrologic design criteria and overflow history.	These questions will capture any design considerations for stormwater overflow management. EPA would use this information to establish the baseline industry profile of current stormwater overflow management practices.
F2-5	Asks if the pond/impoundment unit has a system to collect leachate.	EPA would use this information to develop industry trends and identify best management practices among all waste management units.
F2-6	Requests the volume and frequency of leachate collected in the pond/impoundment in 2009.	EPA would use this data to determine the extent to which leachate is collected from ponds/impoundments in the industry.
F2-7 through F2‑9	Requests leachate handling practices including commingling with other wastewaters, treatment information, and chemicals added to treat leachate.	EPA would use the information collected in these questions to determine the extent to which leachate is treated, ultimately released to surface waters, and identify other wastewaters treated by leachate treatment systems. EPA may also use this information to identify potential water reuse options for plants.
F2-10	Asks if the plant regularly monitors or inspects the structural integrity of the pond/impoundment.	EPA would use this information to identify plants that should provide information on monitoring measures and inspections conducted on the pond/impoundment unit.
F2-11	Requests which aspects of pond/impoundment unit structural integrity are monitored or inspected and the frequency and hours per month spent performing monitoring.	EPA would use the information collected from this question to understand the monitoring practices and inspections for several aspects of pond/impoundment integrity.
F2-12	Requests pond/impoundment inspections information for the last five inspections including the date of inspection, affiliation of the inspector, and the cost of the inspection. If applicable, plants are also asked provide any corrective actions that resulted in response to the inspection and costs associated with implementing the corrective actions.	The information collected in this question would be used by EPA to assess inspection practices. EPA would use the cost of inspections and the cost of any corrective actions in forecasting the industry-wide cost of compliance with best management practices.
Landfill Management Practices
F3-1 through F3‑3	Requests information on the area, volume capacity, and height of the landfill.	EPA requests original, present, and completed landfill dimensions to understand how plants respond to the increase in solid wastes that must be stored. Additionally, the progression of landfill size will help EPA understand how expansions in landfill size relate to the overall plant layout.
F3-4 through F3‑7	Asks if the landfill has been expanded since it was built and the type of expansion. Also requests the costs associated with the expansion, a description of the landfill expansion, and the Requests the calendar year 2009 operation and maintenance (O&M) costs associated with the expansion.	Information on expansion would help EPA understand how plants respond to the increase in solid wastes that must be stored and how expansions in landfill size relate to the overall plant layout. Additionally, the information would help EPA understand the landfill expansion process and the costs that have been incurred from the plant to expand a landfill.
F3-8 and F3-9	Asks about the landfill liner and cap/cover characteristics. Requests the liner and cap/cover layer thickness and permeability of each layer in the liner and cap/cover.	EPA would use the liner and cap/cover materials, thickness, and permeability in the industry profile, and to identify landfill best management practices.
F3-10	Asks if the plant built any structures on top of the closed landfill. Requests a description of the structure(s) and any challenges that the plant faced building on top of the landfill.	EPA would use this information to identify methods of constructing on top of closed landfills. EPA would also use this information to determine a plant’s land availability for future construction.
F3-11 and F2-12	Asks if the plant has a leachate collection system and requests the amount of leachate collected in 2009.	EPA would use this data to determine the extent to which leachate is collected from landfills in the industry.
F3-13 and F3-14	Requests leachate handling practices including treatment information and chemicals added to treat leachate.	EPA would use the information collected in these questions to determine how leachate is treated and the ultimate destination of collected leachate. EPA may also use this information to identify potential water reuse options for plants and current industry practices for leachate treatment.
F3-15 through F3‑18	Requests collection and treatment system information for stormwater runoff that has contacted the capped and uncapped portions of the landfill.	EPA would use the information collected in these questions to determine whether stormwater runoff is collected with leachate, how the runoff is treated, and the ultimate destination of runoff. EPA may also use this information to identify potential water reuse options for plants.
Leachate Treatment System Design
F4-1	Identifies leachate treatment systems for leachate from pond/impoundment units and landfills.	EPA would use the information collected from this question to identify leachate treatment systems (not including wastewater treatment systems previously defined in Table D-2 that receive pond/impoundment or landfill leachate) operated or planned to be operated by the plant. The question assigns system IDs which will be used to identify the systems in later questions.
F4-2	Requests block diagrams for each leachate treatment system.	EPA would use the block diagrams as a guide to understand the operation of the leachate treatment systems. The diagrams would help EPA understand the physical configuration of the leachate treatment units (e.g., operated in parallel or series).
Leachate Treatment System Flows
F4-3	Requests leachate treatment system flow information.	EPA would use the information to determine the types of wastewaters that are treated by leachate treatment systems at steam electric power plants. Additionally, EPA will use the information to identify wastewater reuse opportunities in the industry. EPA would use the flow rate information for sizing equipment technology options and estimating compliance costs.
Leachate Treatment System Units
F4-4	Asks for information about treatment units for the leachate treatment system.	EPA would use this information to identify the unit operations comprising each leachate treatment system and to update the industry profile. EPA would also use the information when evaluating the costs of the leachate treatment systems (e.g., identify why some systems are more expensive than others).
F4-5 and F4-6	Requests information on planned improvements to the leachate treatment system, including a description of the improvement, the expected date of the improvement, the total capital cost related to the improvement, and reasons for planned improvement.	EPA would use this information to identify changes that will be made on leachate treatment systems in the near future and to update the industry profile. EPA would also use this information to identify methods of improving different types of leachate treatment systems, evaluate the cost of the improvements, and identify the impact on pollutant concentrations.
F4-7	Requests the typical and maximum leachate treatment system flow rates in 2009 and the duration and frequency of the effluent transfers in 2009.	EPA would use the flow rate information to establish a relationship between the flow rate and cost of the leachate treatment system. EPA would use the relationship to estimate compliance costs for plants that would be required to install leachate treatment systems based on actual or predicted leachate flow rates.
Leachate Treatment Unit Information
F4-8 through F4‑11	Requests the volume, footprint/surface area, residence time, and materials of construction for each unit in the leachate treatment system.	EPA would use the information from these questions to evaluate difference among leachate treatment systems between plants and identify characteristics that factor into the cost of a leachate treatment system.
F4-12 and F4-13	Requests information about leachate treatment by techniques other than settling.	EPA would use this information to determine whether plants are operating leachate treatment systems to target specific analytes using techniques other than settling. EPA would use the responses to evaluate best management practices for the industry.
F4-14	Requests information on chemicals used in leachate treatment.	EPA would use the responses from this question to identify industry practices for chemical treatment in leachate treatment systems and identify best management practices.
F4-15	Requests information on plant species used in the leachate treatment unit (i.e., constructed wetland cell).	EPA would use the responses from this question to identify industry practices for constructed wetlands as leachate treatment systems and identify best management practices.
Leachate Treatment System Costs
F4-16 and F4-17	Requests capital and operation and maintenance (O&M) cost information for the leachate treatment system.	EPA would use this information to develop compliance cost estimates.
Leachate Treatment System Equipment
F4-18	Asks plants to identify the major equipment included in the leachate treatment system that are included in the capital costs provided in question F4-17.	EPA would use this information to evaluate differences in capital costs provided by multiple plants with similar leachate treatment systems.
Groundwater Monitoring Practices
F5-1	Asks if the plant performs groundwater monitoring at the pond/impoundment and landfill and information pertaining to the frequency of monitoring.	EPA would use this information to evaluate the prevalence of groundwater monitoring practices.
F5-2	Asks plants to identify the locations of monitoring wells around each pond/impoundment and landfill. For each well location, EPA requests the average water table depth and distance to surface water.	This information would help EPA evaluate the potential of pond/impoundment and landfill leachate contaminating groundwater and ultimately surface waters.
F5-3 through F5‑6	Asks if the plant has plant measured pollutant concentrations from ash and FGD related constituents in ground water that exceed a primary or secondary MCL, state-issued standard/criteria, or background concentrations. If so, asks the plant to identify the pollutants that exceeded.	EPA would use this question to assess the potential of pond/impoundment and landfill leachate contaminating groundwater and ultimately surface waters. EPA would also use this information to identify pollutants of concern.

Part G: Leachate Sampling Data for Ponds/Impoundments and Landfills

Part G collects sampling data for landfills and ponds/impoundments. Plants are asked to sample treated and untreated leachate for metals, chlorides, mercury, sulfates, total dissolved solids, total suspended solids, and pH. EPA would use the monitoring data collected from this part to characterize treated and untreated leachate streams, evaluate wastewater treatment performance, estimate pollutant discharge loadings, and establish effluent limitations.

Table 4-7. Leachate Sampling Data for Pond/Impoundments and Landfills Question Justifications
Question Number	Question Description	Purpose of Question
Leachate Collection
G1-1	Asks whether leachate is currently collected from any pond/impoundment and/or landfill at the plant.	EPA would use this information to identify plants that should complete Part G of the questionnaire; plants that do not currently collect leachate would not complete Part G.
Leachate Generated from Pond/Impoundments and Landfills
G2-1	Asks whether leachate is currently collected from the pond/impoundment and/or landfill.	EPA would use the responses from this question to identify pond/impoundment units and/or landfills that require leachate sample collection.
G2-2 and G2‑3	Asks whether all of the collected leachate from the pond/impoundment and/or landfill is transported off-site for treatment and/or disposal. If not, asks whether the collected leachate is treated.	EPA would use responses from these questions to identify plants that should sample only untreated leachate.
G2-4	Asks whether the leachate is combined with other waste streams prior to treatment. If so, asks if the leachate is combined with only stormwater runoff or if it is combined with other waste streams.	EPA would use responses from this question to identify plants that should sample both untreated and treated leachate.
Leachate Sample Collection Instructions
G3-1	Requests the plant to collect wastewater samples from untreated and/or treated leachate streams generated from each pond/impoundment unit and landfill that collect leachate.	EPA would use the analytical data from the collected leachate samples to characterize untreated and treated leachate streams. EPA may also use this information to develop numerical limits on discharges of leachate.
G3-2 and G3-3	Requests an aerial photograph or drawing showing the entire waste management unit, including all leachate collection points and the active and inactive areas of the landfill. Also, requests identification of the leachate sample locations used for this sample collection in the block diagram previously requested in Question F4-2.	EPA would use the aerial photograph and block diagram to identify trends in the number and location of leachate collection points found in pond/impoundment units and landfills in the industry and characterize the best management practices for the waste management sites. EPA would also use the aerial photograph and block diagram to determine how leachate generation differs between active/uncapped or inactive/capped waste management sites.
Sample Collection Information
G4-1 and G4‑2	Requests information on the leachate sample collection, including a description of the sample collection location, the date the sample was collected, whether the leachate stream is treated or untreated, and rainfall patterns preceding and during the sample collection.	EPA would use this information to determine how the sample collection location and variation in rainfall patterns impacts leachate generation and characterization.
Waste Information
G5-1	Requests identification of all the process wastes, residues, or by-products that are stored, treated, and/or disposed of in each pond/impoundment unit and/or landfill located on-site. Also requests the amount of waste under the capped and uncapped portions of the landfill.	EPA would use this information to identify the types and the amounts of materials that are disposed of in each pond/impoundment and landfill. EPA would compare this information to the analytical results to determine how the types and amounts of waste impact leachate characteristics.

Part H: Nuclear Power Generation

Part H collects information on wastewater generation and treatment at nuclear power plants.

Table 4-8. Nuclear Power Question Justifications
Question Number	Question Description	Purpose of Question
Nuclear Generating Unit Data
H1-1	Asks if the plant operated an electric generating unit using nuclear energy in 2009.	EPA would use this question to identify plants that need to complete the nuclear power generating units part; plants that did not operate any nuclear generating units in 2009 would not complete Part H of the questionnaire.
H1-2	Asks if the plant generated process wastewater associated with the nuclear electric generating units.	EPA would use this question to identify the plants that need to complete the nuclear process wastewater generation section; nuclear plants that did not generate process wastewater in 2009 would not complete that section.
H1-3	Requests information on process wastewater generated by the nuclear electric generating units.	EPA would use this information to identify the types of process wastewater generated by the nuclear electric generating units.
Process Wastewater Generation
H2-1	Asks for the characteristics of the process wastewater generated by the nuclear electric generating units.	EPA would use the responses to this question to characterize the process wastewater generated at nuclear plants and cost technology options, if appropriate.
H2-2	Asks information on how process wastewater generated by nuclear electric generating units is handled.	EPA would use the responses to this question to identify how nuclear plants typically manage process wastewater including information on recycling and ultimate destination.
Wastewater Treatment Systems
H3-1	Asks if the wastewater treatment system treats radioactive waste.	EPA would use the responses to this question to identify how nuclear plants treat process wastewater differently depending on whether it is radioactive or nonradioactive.
H3-2 and H3-3	Asks the plant to identify all the process wastewater that a wastewater treatment system treats and indicate flow rates for the wastewater treatment system.	EPA would use this information to determine, which process wastewaters are typically combined for treatment and help characterize wastewater treatment systems at nuclear power plants.
H3-4 and H3-5	Asks for the treatment technologies used in the wastewater treatment system, the pollutants targeted for removal by each technology.	EPA would use the information from these questions to determine how different process wastewaters are treated at nuclear power plants and to determine best management practices and/or treatment technologies.
H3-6	Asks information on treatment technologies the plant is currently adding or planning to add to the wastewater treatment system.	EPA would use this information to evaluate if changes are being made to how the plant treats process wastewater.
H3-7 and H3-8	Asks information on how the treated process wastewater is handled.	EPA would use the responses to these questions to determine how nuclear plants typically manage treated process wastewater including information on recycling and ultimate destination. These questions would help EPA to characterize nuclear power plant recycling practices and determine management practices.

Part I: Economic and Financial Data

Part I of the survey asks for economic and financial information about each plant, the plant’s owner(s), and its steam-electric generating units. This part requests identifying and contact information, information on economic activities, including activities other than generation of electricity, and revenues and costs associated with the economic activities. This part also asks for three years of data on a plant-level financial balance sheet and operational information about the generating units. The Agency will use this information to assess the potential impacts of compliance with steam electric ELGs and on the economic viability of all affected plants and their steam-electric generating units.

The questionnaire is designed to be completed with standard accounting information that is generated as a matter of customary business practice and which should be readily available to a knowledgeable company representative.

Table 4-9. Economic and Financial Data Question Justifications
Question Number	Question Description	Purpose of Question
Immediate Parent-Level
I1-1 through I2‑13	Requests information pertaining to the immediate legal parent owner(s) of the plant or other entities that have a financial interest in the plant. The section includes a general question regarding the identity of the owner(s). It also includes several questions asking for more detailed information on the owner with the largest ownership share in the steam electric capacity of the plant, including ownership type and structure, sales, purchases and generation of electricity, income statement, balance sheet, and cash flow information.	EPA would use information gathered through these questions to identify entities that may be affected by the regulations and for economic impact analyses, household impact and electricity rate impact analyses as well as to extrapolate certain plant-level information when necessary. In those instances when the immediate parent is also the ultimate parent, this information would be used for parent-level cost impact, RFA, and UMRA analyses.
Ultimate Domestic Parent-Level
I3-1 and I3‑2	Asks respondents to provide revenue, electricity sales, and total number of employees for the ultimate parent unless the immediate parent is also the ultimate parent.	This information would be used for the parent-level cost impact, RFA, and UMRA analyses.
Plant-Level
I4-1 through I4‑12	Asks for total number of employees, total generating capacity, total electricity generation, capital outlays for plant and equipment, income statement, and balance sheet information for the plant. The questions also ask for the description of economic activities other than electricity generation and costs and revenues associated with these activities.	Information collected through these questions would be used for facility-level cost impact analysis.
Generating Unit-Level
I5-1 through I5‑4	Asks for information on nonutility status and operating status, undepreciated value of generating plant and equipment, generating capacity, electricity generation, net peak demand, energy source, planned/scheduled and forced/unscheduled outages, and total, fuel, and variable O&M costs for each steam electric generating unit.	EPA would use the information collected through these questions in: assessing the unit-level impact of compliance requirements, estimating the potential cost of unit downtime during technology installation, assessing the short-term and long-term reduction in capacity availability due to installation downtime, and conducting electricity rate impact analyses.

(ii)Respondents Activities

Each respondent will receive a transmittal letter with attachments citing authority of Section 308 of the Clean Water Act and confidentiality and handling of any responses for which assertions of confidential business information (CBI) may be made. Respondents will also need to read the Introduction, General Instructions, Glossary of Key Terms, and Certification Statement sections in the beginning of the questionnaire. The Introduction section provides the purpose and use of the questionnaire, questionnaire outline, e-mail/help line information, and information on how to return the completed questionnaire. The General Instructions section will give the respondent guidance on completing the responses and including attachments, if needed. The Glossary of Key Terms provides respondents with all pertinent definitions and acronyms to understand and complete the questionnaire sections.

There are four different categories of respondents for the questionnaire. These categories include coal- and petroleum coke-fired power plants included in the statistical subset, coal- and petroleum coke-fired power plants not included in the statistical subset, oil-fired and combination power plants, and gas-fired and nuclear power plants. EPA will distribute four different versions of questionnaire, corresponding to the categories stated above, to avoid respondents from potentially answering parts not applicable to their facility.

The coal- and petroleum coke-fired power plants included in the statistical subset will receive Parts A through I of the questionnaire. The coal- and petroleum coke-fired power plants not included in the statistical subset will receive Parts A through D, H, and I of the questionnaire. Oil-fired and combination power plants will receive Parts A through E, H, and I of the questionnaire. Gas-fired and nuclear power plants will receive Parts A, E, H, and I of the questionnaire. Respondents must still read the instructions preceding each part to determine whether that part needs to be completed for their plant. These instructions also give the respondents guidance on completing the responses in each part. The planned distribution of the questionnaire parts is illustrated by Table 4-10.

Table 4-10. Number of Questionnaire Respondents

Questionnaire Part	Steam Electric Power Plants by Fuel Type
Questionnaire Part	Coal	Petroleum Coke	Oil	Gas ^a	Nuclear	Combination ^b	Total
Estimated population of fossil/ nuclear steam electric plants	495	9	43	561	63	32	1,203
Total number of respondents	495	9	20	168	20	22	734
Part A: Power plant operations	495	9	20	168	20	22	734
Part B: FGD systems	495 ^c	9 ^c	20 ^c	—	—	22 ^c	546 ^c
Part C: Ash handling	495	9	20	—	—	22	546
Part D: Ponds/treatment	495	9	20	—	—	22	546
Part E: Cleaning wastes	94	3	20	168	20	22	327
Part F: Management practices	94	3	—	—	—	—	97
Part G: Leachate sampling	94 ^d	3^d	—	—	—	—	97^d
Part H: Nuclear power	495 ^e	9 ^e	20 ^e	168 ^e	20 ^e	22 ^e	734 ^e
Part I: Economic data	495	9	20	168	20	22	734

The questionnaire respondents must review the instructions to understand the questionnaire. Other respondent activities will include searching data sources to consult records and reviewing plant information regarding production techniques, equipment types, expenditure histories, and financial company information. The respondent will also have to compile and review information and complete the questionnaire. A subset of questionnaire recipients will be required to collect and analyze samples of leachate from surface impoundments and landfills containing coal combustion residues. The respondents will be required to return the completed questionnaire and leachate sampling data to EPA in electronic format (i.e., MS Excel format). The respondents should retain the completed questionnaire for up to one year in the event that EPA has to contact the facility for clarification of any response. The respondents will not need to maintain any new records because this is a one-time information collection effort.

5.THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION

5.a)Agency Activities

The Agency has conducted, is conducting, or will conduct the following activities to administer the steam electric questionnaire:

Develop the questionnaire;
Develop the sample frame;
Develop the ICR supporting statement;
Provide the questionnaire for review by trade associations, industry representatives, public interest groups, state regulatory agencies, EPA workgroup members, OMB, and other stakeholders;
Revise the questionnaire based on comments from trade associations, industry representatives, public interest groups, state regulatory agencies, EPA workgroup members, OMB, and other stakeholders;
Develop a mailing list database and mailing labels;
Develop a tracking system for questionnaire mail-out, receipt, and return activities;
Distribute questionnaires;
Develop and maintain help lines for respondents who require assistance in completing their questionnaire;
Develop an electronic database for questionnaire responses;
Receive and review questionnaire responses;
Summarize and analyze questionnaire responses; and
Conduct technical analyses.

The Agency will transfer data received from the questionnaire forms to a master database for future use.

5.b)Collection Methodology and Management

Each selected plant will be assigned a specific plant identification number and will receive an electronic MS Excel version of the questionnaire to complete. Plants will be required to fill out the electronic version of the questionnaire, but EPA will also include a pdf file of the questionnaire that can be printed out and used as a working copy. The questionnaire will be sent via Federal Express or similar delivery service to each plant to ensure that a point of contact (the plant contact person) receives and signs for the questionnaire package. Each plant will be allowed 60 calendar days from the time of receipt to return the completed questionnaire, for all portions of the questionnaire except Part G. Plants will be allowed 120 calendar days to submit Part G along with the leachate sampling data.

EPA will include an e-mail address and phone number in the instructions that respondents can use to request assistance in completing the questionnaire. Using these assistance methods enables the respondents to receive a timely response to any inquiries that they may have. E-mail and telephone communication will also reduce any misinterpretations of the questionnaire and thus decrease the burden of follow-up phone calls and letters to the respondents.

The plant will enter their unique plant identification number on each section of the questionnaire for ease of tracking. The plant identification number will be used to track the mailing date of the questionnaire, questionnaire receipt date, follow-up letters and telephone calls to respondents, and EPA’s receipt of the completed questionnaire. EPA will also use the identification number as an identification code in the questionnaire database. The Agency will make follow-up calls as needed to clarify inconsistencies in responses, and to remind non-respondents of their requirement to complete and return the questionnaire.

Upon receipt of completed questionnaires, EPA and its contractors will review the questionnaire responses for completeness and CBI claims. All questionnaires will also be reviewed for consistency and reasonableness and follow-up calls will be conducted as needed to clarify inconsistencies found in the responses. Reviewed questionnaire files will then be uploaded into the questionnaire database. The database developed using the questionnaire responses will be used by EPA to perform data analysis for the purpose of revising the steam electric ELGs.

5.c)Small Entity Flexibility

In accordance with requirements of the Regulatory Flexibility Act (RFA), EPA must assess whether actions would have “a significant impact on a substantial number of small entities” (SISNOSE). Small entities include small businesses, small organizations, and small governmental jurisdictions. EPA has determined that approximately 734 plants will be required to respond to this questionnaire. Based on EPA’s past analyses of steam electric entities, the majority of the businesses that EPA is targeting to receive the detailed questionnaires are not defined as small. Whether a respondent is defined as small depends on the size of the domestic parent and is based on the appropriate Small Business Administration (SBA) entity size criterion (codified at 13 CFR part 121). The criteria for entity size determination vary by the organization/operation category of the parent entity, as follows:

Private Entities: Private entities include investor-owned utilities, non-utility entities, and entities with a primary business other than electric power generation. For entities with electric power generation as a primary business, small entities are those with total annual electric output less than 4 million MWh. For entities with a primary business other than electric power generation, the relevant size criteria are based on revenue or number of employees by NAICS sector (see Table 5-1).^⁴

Public entities: Public entities include federal, state, municipal, and political subdivision entities. Facilities owned by Federal and State governments are considered to be large; facilities owned by municipalities and other political units with population less than 50,000 are considered to be small.

Not-for-profit enterprises: Not-for-profit enterprises include rural electric cooperatives. Small entities are those with total annual electric output less than 4 million MWh.

Table 5-1. NAICS Codes and SBA Size Standards for Entities with a Primary Business Other Than Electric Power Generation

NAICS Code	NAICS Description	SBA Size Standard
221210	Natural Gas Distribution	500 Employees
221310	Water Supply and Irrigation Systems	Revenue of $7,000,000
331315	Aluminum Sheet, Plate, and Foil Manufacturing	750 Employees
524126	Direct Property and Casualty Insurance Carriers	1,500 Employees
525990	Other Financial Vehicles	Revenue of $7,000,000
551112	Offices of Other Holding Companies	Revenue of $7,000,000
562212	Solid Waste Landfill	Revenue of $12,000,000
562219	Other Nonhazardous Waster Treatment and Disposal	Revenue of $12,000,000
562920	Materials Recovery Facilities	Revenue of $12,000,000
611310	Colleges, Universities, and Professional Schools	Revenue of $7,000,000

Source: SBA, 2008.

EPA has designed the survey to minimize respondent burden while obtaining sufficient and accurate information. The survey employs the use of checkboxes where feasible, or provides a set of potential responses for respondents to choose from. The questions are phrased with commonly used terminology. Questions requesting similar types of information are arranged together to facilitate review of pertinent records and completion of the questionnaire. The questionnaire will include initial questions to determine which parts of the questionnaire the plant will be required to complete. EPA will revise the questionnaire as necessary in response to public comments on this information collection request in order to minimize respondent burden while ensuring the practical utility of the data. EPA will be providing a helpline to answer questions respondents might have when completing the questionnaire.

To further reduce the burden on small entities, EPA is excluding small entities from the requirement to collect and analyze samples of leachate from ponds/impoundments and landfills. By doing so, small entities will be relieved of the labor burden required to collect the samples and compile and review analytical data, as well as the costs associated with sampling supplies, shipping samples to analytical laboratories, and laboratory analysis of the samples. EPA’s methodology to identify potential respondents and distribute the questionnaire will result in not requiring small entities to complete Parts E, F, and G of the questionnaire. In providing this burden relief to small entities, EPA is assuming that the information collected in Parts E, F and G from non-small entities is appropriate for use in characterizing wastewater generation/characteristics and practices at small entities.

5.d)Collection Schedule

The specific dates for distribution, response receipt, and data collection activities for the questionnaire have not yet been established but will include the following activities listed below in Table 5-2.

Table 5-2. Collection Schedule

Activity	Estimate of Schedule
EPA send questionnaires to recipients	Late May/Early June 2010
Plants complete questionnaire (all parts except for Part G)	60 days following receipt
Plants complete Part G of questionnaire	120 days following receipt
EPA conduct questionnaire follow-up	4 months
EPA complete ICR database, assign statistical weighting factors	2-4 weeks

6.ESTIMATING THE BURDEN AND COST OF COLLECTION

6.a)Estimating Respondent Burden

EPA published a notice in the Federal Register announcing EPA’s intent to submit the Steam Electric ICR to OMB on October 29, 2009 (74 FR 55837). EPA reviewed all public comments regarding burden estimates and carefully revised estimates as appropriate. EPA will publish a final notice in the Federal Register in March 2010. EPA encourages the receipt of public comments and suggestions regarding the revised questionnaire and associated estimates of burden.

Because the steam electric industry will devote time and resources to respond to the questionnaire, EPA has made significant efforts to minimize the burden on the industry. Many of the changes made in this regard are described in Appendix B. EPA worked to eliminate redundant, unclear, and unnecessary questions from the questionnaire. EPA also developed a user-friendly, MS Excel electronic version of the questionnaire. This electronic version should allow plants to easily enter data using check boxes, drop down menus, and option buttons.

The burden to respondents for Parts A through H includes the time necessary to read through all instructions and questions, develop a data gathering plan, gather data, transfer data to the questionnaire, and review/check the responses. Each section of the survey is expected to be completed by technical and clerical staff, and reviewed by managerial staff. The burden estimates reflect the assumption that technical and clerical staff will devote their time to reading instructions, gathering information and completing the survey form; managers will devote their time to reading instructions and reviewing survey responses.

The burden to the respondents for Part I includes the time necessary to read general instructions and review before submittal, provide owner table with shares, provide detailed immediate parent level and ultimate parent level information, perform a contracts review, and provide plant and unit level information. EPA predicts that only a subset of plants will incur the burden of answering certain questions. For example, plants that already provide certain data to FERC on Form 1 may skip the questions asking for detailed financial information for the immediate parent. EPA estimated that approximately 40 percent of the steam electric plants that will receive this questionnaire are owned by major regulated utilities and are therefore required to submit FERC Form 1 data. The Agency adjusted the overall burden of these questions (I1-8 through I1-12) on the universe of respondents accordingly. Additionally, EPA’s review of the respondent universe showed multiple plants owned by the same immediate parent firms. Because detailed financial information for the immediate parent only needs to be compiled once, EPA adjusted the burden estimate for these questions (I1-2 through I1-16) to account for the expected number of unique responses. Finally, only a subset (2/3) of respondents is assumed to currently sell electricity using contracts and therefore would incur the burden of answering the relevant questions (I1-13 and I1-14). Table 6-1 presents the hourly burden estimate for Part I. These estimates are used, along with the burden for Parts A through H, to calculate the total respondent burden, shown in Table 6-2.

EPA identified labor categories associated with all respondent activities necessary to complete the questionnaire: operating engineer, engineering manager, engineering technician, clerical support, legal support, junior accountant, and financial manager.

(i)Respondent Burden

For the purpose of estimating the burden, the questionnaire will be sent to approximately 734 steam electric plants, including a census of all coal-fired power plants and a subset of the rest of the industry that will be statistically selected using a sample frame population identified by the 2007 EIA Database (Form 860 and Form 923) and confirmed by NAICS code. All questionnaire recipients will receive the parts of the questionnaire corresponding to designated fuel type (734 steam electric plants). EPA will require statistical sample subpopulations of the steam electric industry to fill out additional detailed sections of the questionnaire, as illustrated by Table 2-1.

EPA estimates the total burden for the steam electric questionnaire to be approximately 144,451 hours. For the purpose of estimating the burden of completing this questionnaire, EPA assigned burden estimates for all sections of the questionnaire. Table 6-2 presents a summary of the average hourly burden, estimated number of respondents, and total burden by labor category associated with each section of the questionnaire.

By calculating separate burden estimates for each section, EPA can estimate respondent burden by predicting the number of respondents per section. This number changes based on the criteria required for each section (e.g., number of plants, number of generating units, number of FGD systems, etc.) in order to account for all units and/or systems throughout the industry. This estimated respondent number will also change based on the intended population of each part. For example, Table 6-2 shows that EPA expects responses for 772 generating units in Part E. These generating units are not the total estimated number of units in the respondent universe; they are the estimated number of units in all the subpopulations required to respond to Part E. EPA estimated the total number of respondents per section using EIA data and information collected from the data request, site visits, and communication with the industry.

EPA also estimated the associated burden with certain subsets of the industry population. As described earlier, EPA will send the questionnaire to all coal-fired fired power plants, but only a statistical subset of these plants will be required to complete Sections E, F, and G. Therefore, EPA estimated the hourly burden for a coal plant that is in the statistical subset (and subject to report on all parts of the questionnaire) versus a coal plant that is not in the subset. In addition, EPA estimated the average hourly burden for non-coal plants. Table 6-4 presents the burden for these types of plants.

(ii)Total Estimated Respondent Burden

EPA calculated the total estimated respondent burden using the estimated response time per section and the total number of estimated respondents and respondent elements shown in Table 6-2. Multiplying the hourly burden section estimates by the number of respondents provided a total industry burden per section of the questionnaire; further broken down by labor category. EPA summed all labor category estimates to calculate the total respondent burden, per part of the questionnaire, of 144,451 hours shown in Table 6-3.

Table 6-1. Economic and Financial Data Burden Estimates for Part I
Survey Section	Activity	Number of Hours					Estimated Fraction of Respondents Incurring Burden	Adjustment to Response Burden due to Multiple-Plant Owners	Weighted Average Response Burden
Survey Section	Activity	Jr. Acct	Financial Manager	Clerical Support	Legal	Total Burden	Estimated Fraction of Respondents Incurring Burden		Weighted Average Response Burden
Economic/ Financial Section	Read general instructions and do final review before submitting	1.00	3.00	0.00	2.00	6.00	100%	1.00	6.00
Immediate Parent Info	Provide owner table with shares	2.00	2.00	0.00	0.00	4.00	100%	1.00	4.00
	Detailed info (except contracts) - Applies to non-FERC respondents only	8.00	2.00	2.00	0.00	12.00	60%	0.76	5.50
	Contracts review - applies only to entities that sell under contract	12.00	3.00	1.00	0.00	16.00	64%	0.76	7.81
Ultimate Parent Level	Detailed info	2.00	1.00	0.00	0.00	3.00	100%	0.76	2.29
Plant-Level and Unit-Level Info	General information	5.00	1.00	0.00	0.00	6.00	100%	1.00	6.00
Plant-Level and Unit-Level Info	Estimate from corporate info	10.00	3.00	3.00	0.00	16.00	100%	0.83	13.33
TOTAL		40.00	15.00	6.00	2.00	63.00			45.00

Table 6-2. Estimated Respondent Hours per Section of the Questionnaire
Section	Estimated Number of Response Elements	Response Element (e.g., Plant, Generating Unit, FGD System, etc.)	Hours by Job Category							Total Burden per Activity (Hours)
Section	Estimated Number of Response Elements		Operating Engineer	Engineer Manager	Engineer Tech	Jr. Acct	Financial Manager	Clerical Support	Legal	Total Burden per Activity (Hours)
Part A (Total Respondents: 734 Plants)
Section 1 through Section 7	734	Plant	14.00	4.00	0.00	0.00	0.00	2.00	0.00	20.00
Section 8	734	Plant	4.75	0.75	0.00	0.00	0.00	1.00	0.00	6.50
Section 9 through 11	734	Plant	6.25	2.50	0.00	0.00	0.00	1.00	0.00	9.75
Section 12	495	Plant	4.00	0.75	0.00	0.00	0.00	1.00	0.00	5.75
Part A Total			29.00	8.00	0.00	0.00	0.00	5.00	0.00	42.00
Part B ^a(Total Respondents: 546 Plants)
Section 1 through Section 3	242	Plant ^a	6.00	1.25	0.00	0.00	0.00	1.00	0.00	8.25
Section 4	259	FGD System^a	8.00	1.25	0.00	0.00	0.00	1.00	0.00	10.25
Section 5 and Section 7	259	FGD System^a	4.00	1.25	0.00	0.00	0.00	1.00	0.00	6.25
Section 6	55	FGD System^a	3.50	0.00	0.00	0.00	0.00	2.50	0.00	6.00
Section 8	68	FGD System^a	6.75	1.25	0.00	0.00	0.00	1.00	0.00	9.00
Part B Total			28.25	5.00	0.00	0.00	0.00	6.50	0.00	39.75
Part C (Total Respondents: 546 Plants)
Section 1	530	Plant	1.50	0.50	0.00	0.00	0.00	0.50	0.00	2.50
Section 2 (2.1 through 2.7)	642	Fly Ash Handling System ^b	19.00	3.50	0.00	0.00	0.00	2.00	0.00	24.50
Section 2 (2.2 only)	1296	Generating Unit	1.50	0.50	0.00	0.00	0.00	0.00	0.00	2.00
Section 3 (3.1 through 3.7) and Section 4 (4.1 through 4.3)	530	Bottom Ash Handling System ^b	16.00	2.75	0.00	0.00	0.00	2.00	0.00	20.75
Section 3 (3.2 only)	1296	Generating Unit	1.50	0.50	0.00	0.00	0.00	0.00	0.00	2.00
Section 4	1296	Generating Unit	1.25	0.50	0.00	0.00	0.00	0.00	0.00	1.75
Section 5	1296	Generating Unit	1.25	0.50	0.00	0.00	0.00	0.00	0.00	1.75
Part C Total			42.00	8.75	0.00	0.00	0.00	4.50	0.00	55.25
Part D (Total Respondents: 546 Plants)
Section 1 and Section 2	530	Plant	3.75	1.25	0.00	0.00	0.00	0.00	0.00	5.00
Section 3	619	Pond/Impoundment/WWT System ^c	8.25	2.00	0.00	0.00	0.00	1.50	0.00	11.75
Section 4	573	Ponds/Impoundment ^c	7.25	2.00	0.00	0.00	0.00	1.00	0.00	10.25
Section 5	46	WWT System ^c	7.50	1.25	0.00	0.00	0.00	1.00	0.00	9.75
Section 6	608	Pond/Impoundment/WWT System ^c	6.75	1.75	0.00	0.00	0.00	0.00	0.00	8.50
Part D Total			33.50	8.25	0.00	0.00	0.00	3.50	0.00	45.25
Part E (Total Respondents: 327 Plants)
Section 1 and Section 2	772	Generating Unit	2.75	0.75	0.00	0.00	0.00	0.25	0.00	3.75
Section 3	772	Generating Unit	2.25	0.75	0.00	0.00	0.00	0.25	0.00	3.25
Part E Total			5.00	1.50	0.00	0.00	0.00	0.50	0.00	7.00
Part F (Total Respondents: 97 Plants)
Section 1 and 2	140	Pond ^d	4.75	1.50	0.00	0.00	0.00	1.00	0.00	7.25
Section 3	55	Landfill ^d	5.75	1.50	0.00	0.00	0.00	0.50	0.00	7.75
Section 4	9	Leachate Treatment System ^e	15.50	4.00	0.00	0.00	0.00	2.50	0.00	22.00
Section 5	195	Pond and Landfill ^d	3.25	1.25	0.00	0.00	0.00	0.50	0.00	5.00
Part F Total			29.25	8.25	0.00	0.00	0.00	4.50	0.00	42.00
Part G (Total Respondents: 97 Plants)
Lab Procurement	30	Plant	0.00	18.00	6.00	0.00	0.00	0.00	0.00	24.00
Sample Collection	204	Sample ^e	8.00	0.00	14.00	0.00	0.00	0.00	0.00	22.00
Data Entry and Submittal	204	Sample ^e	0.00	2.00	8.00	0.00	0.00	0.00	0.00	10.00
Part G Total			8.00	20.00	28.00	0.00	0.00	0.00	0.00	56.00
Part H (Total Respondents: 734 Plants)
Section 1	21	Plant	2.25	1.25	0.00	0.00	0.00	0.25	0.00	3.75
Section 2	21	Plant	4.25	1.25	0.00	0.00	0.00	0.25	0.00	5.75
Section 3	21	Plant	3.50	1.25	0.00	0.00	0.00	0.25	0.00	5.00
Part H Total			10.00	3.75	0.00	0.00	0.00	0.75	0.00	14.50
Part I (Total Respondents: 734 Plants)
Section 1 and Section 2	734	Plant	0.00	0.00	0.00	27.50	11.50	4.00	2.00	45.00
Part I Total			0.00	0.00	0.00	27.50	11.50	4.00	2.00	45.00

a – For purpose of this burden calculation, EPA estimated the number of plants that currently operate and/or plan to operate FGD systems, the number of operating wet/dry FGD systems in the industry, and the estimated number of wet FGD systems that have scrubber purge data available. Planned wet/dry FGD system estimates were developed by observing trends in the industry. The following estimates were determined using the 2007 EIA database and the Steam Electric Detailed Study.

b – Part C of this questionnaire is based on the number of ash handling systems (both fly and bottom) that a facility operates. EPA estimated that each coal-, oil-, and petroleum coke-fired power plants have 1 fly ash and 1 bottom ash handling system. After reviewing facility data, EPA estimated that 20% of these facilities operate two fly ash handling systems (both wet and dry) in order to estimate industry burden.

c – EPA used the number of ponds/impoundments reported to the ORCR ICR, for all facilities in the respondent universe. EPA estimated the number of operating wastewater treatment systems using data from site visits and the Steam Electric Detailed Study. Estimates for planned wastewater treatment systems were developed by observing trends for planned wet FGDs in the industry.

d – EPA estimated the number of ponds and landfills for the statistical subset or coal- and all of petroleum coke-fired power plants using the numbers provided in Table B-5, in Part B of the Supporting Statement. Petroleum coke plants, selected for the statistical subset (3), were assumed to be in the "Both Landfill and Pond" category. For the purpose of this burden, EPA estimated 2 ponds for each facility identified as having a pond and 1 landfill for each facility identified as having a landfill.

e – EPA used Supporting Statement Part B Table B-5 information to gather information on plants having ponds, landfills, or both. EPA estimated that 30% of the plants would collect leachate and that 25% of those plants would have a segregated leachate treatment system. Petroleum coke plants, selected for the statistical subset (3), were assumed to be in the "Both Landfill and Pond" category. All numbers were multiplied by 4 to estimate the number of points for 4 weeks. The 204 samples correspond to 51 individual sample points.

Table 6-3. Estimated Respondent Hours per Part of the Questionnaire
Part	Hours by Job Category
Part	Operating Engineer	Engineer Manager	Engineer Tech	Jr. Acct	Financial Manager	Clerical Support	Legal	Total Burden per Activity (Hours)
Part A	20,330	5,693	0	0	0	3,431	0	29,454
Part B	5,212	1,035	0	0	0	966	0	7,212
Part C	28,601	6,562	0	0	0	2,609	0	37,772
Part D	15,698	4,168	0	0	0	1,548	0	21,413
Part E	3,860	1,158	0	0	0	386	0	5,404
Part F	1,755	572	0	0	0	288	0	2,614
Part G	1,632	948	4,668	0	0	0	0	7,248
Part H	210	79	0	0	0	16	0	305
Part I	0	0	0	20,185	8,441	2,936	1,468	33,030
Total	77,297	20,214	4,668	20,185	8,441	12,178	1,468	144,451

Table 6-4. Estimated Respondent Burden (Hourly) per Type of Plant
Type of Plant	Part of Statistical Subset	Questionnaire Part(s)	Estimated Hours per Respondent
Coal	Yes	A through I	346.75
Coal	No	A, B, C, D, H, I	241.75
Petroleum Coke	Yes^a	A through I	346.75
Petroleum Coke	No ^a	A, B, C, D, H, I	241.75
Oil	Yes	A through E, H, I	248.75
Gas ^b	Yes	A, E, H, I	94
Nuclear	Yes	A, E, H, I	108.5
Combination	Yes	A through E, H, I	248.75

a – Petroleum coke facilities identified as small entities will not be included in the sample frame for the statistical subset receiving Parts E, F, and G.

b – Gas plants are not expected to incur burden associated with Part H.

6.b)Estimating Respondent Costs

(i)Estimating Labor Costs

EPA obtained mean labor rates for the steam electric industry from the May 2009, U.S. Department of Labor, Bureau of Labor Statistics: 2008 National Occupational Employment and Wage Data publication. EPA used the Employment Cost Index (ECI) to adjust May 2008 wages to September 2009 wages (the most recently available wage data). EPA also assumed 30% increase for overhead and benefits. Table 6-5 presents the adjusted labor data for 2009.

Table 6-5. 2009 Labor Rate Data

Job Category	Operating Engineer	Engineer Manager	Engineer Tech	Jr. Acct	Financial Manager	Clerical Support	Legal
Mean Hourly Earnings ($/hour)	57.48	77.80	36.49	42.48	71.39	20.33	80.50

The direct labor cost to respondents to complete the questionnaire equals the time required to read through and understand all of the instructions, develop a data gathering plan, gather data, transfer it to the questionnaire, review/check the responses, collect wastewater samples, and report analytical results. Non-labor costs are discussed in Section 6(b)(ii).

EPA calculated the estimated respondent burden using the estimated total response time per part shown in Table 6-3 and the labor rates shown in Table 6-5 to calculate a total labor cost of $8,011,899 shown in Table 6-6.

(ii)Estimating Capital/Start-up Operating and Maintenance Costs

EPA estimates there will be other direct costs associated with responding to Part G of the questionnaire. Plants required to collect and analyze samples will need to purchase supplies and equipment, including bottles, sampling collection equipment, sample packing supplies, and pumps. The plants will also have to analyze the samples collected for certain analytes, according to specified laboratory analytical methods, and will incur costs to procure these services and ship samples to the laboratory(ies). EPA estimates that approximately 204 samples will be collected by plants subject to this part of the questionnaire. EPA estimated this number by using Table B-5 in Part B of the Supporting Statement. The number of sampling points estimated is based on the number of plants having ponds, landfills, or both. EPA estimated that 30% of the plants would collect leachate and that 25% of the plants with leachate collection also operate a segregated leachate treatment system. EPA also assumed that all petroleum coke plants would have both a landfill and a pond for the purpose of this burden estimate. All points were multiplied by 4 to estimate for the 4 weeks of sampling.

Other costs for completing the questionnaire include photocopying and shipping. Respondents will complete an electronic version of the questionnaire (CD/DVD), which will reduce burden and ensure efficient transfer of data. EPA assumes the respondents will incur a photocopying rate of $0.10 per page if a paper copy is printed out for use as a working copy, but they will incur no photocopying cost if no working copy is printed. EPA also assumes that industry will return the completed questionnaire (CD/DVD) via Federal Express or a comparable delivery carrier that require a signature to acknowledge receipt.

Table 6-6. Total Estimated Respondent Burden
Part	Labor Cost by Job Category
Part	Operating Engineer	Engineer Manager	Engineer Tech	Jr. Acct	Financial Manager	Clerical Support	Legal	Total Burden per Activity (Dollars)
Part A	1,168,599.89	442,900.12	0.00	0.00	0.00	69,761.17	0.00	$1,681,261.18
Part B	299,565.09	80,523.76	0.00	0.00	0.00	19,631.13	0.00	$399,719.98
Part C	1,644,029.78	510,489.51	0.00	0.00	0.00	53,047.77	0.00	$2,207,567.06
Part D	902,316.61	324,273.46	0.00	0.00	0.00	31,464.71	0.00	$1,258,054.78
Part E	221,878.78	90,093.25	0.00	0.00	0.00	7,848.39	0.00	$319,820.41
Part F	100,851.38	44,521.47	0.00	0.00	0.00	5,845.62	0.00	$151,218.47
Part G	93,809.89	73,755.09	170,341.49	0.00	0.00	0.00	0.00	$337,906.47
Part H	12,071.13	6,126.81	0.00	0.00	0.00	320.24	0.00	$18,518.17
Part I	0.00	0.00	0.00	857,398.77	602,565.52	59,696.53	118,171.54	$1,637,832.36
Total	4,443,122.55	1,572,683.47	170,341.49	857,398.77	602,565.52	247,615.55	118,171.54	$8,011,898.89

Tables 6-7 and 6-8 below, represent the total Capital/Start-up Operating and Maintenance Costs for the questionnaire and for sampling.

Table 6-7. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire

Number of Respondents	Total Photocopying Cost	Total Shipping Cost	Total Telephone Cost	Total File folder/label Cost	Total
734	$12,478	$3,303	$426	$734	$16,941

Table 6-8. Total Capital/Start-up Operating and Maintenance Costs for Sampling

Number of Sampling Points	Number of Sampling Plants	Total Supplies Cost	Total Shipping Cost	Total Analytical Testing Cost	Total
204	30	$396,780	$21,600	$781,728	$1,200,108

(iii)Annualizing Capital Costs

EPA estimates that there will be no capital costs associated with responding to the questionnaire.

(iv)Estimating Agency Burden and Costs

Table 6-9 presents an estimate for the total capital/start-up O&M costs incurred by the Agency. These initial capital and O&M costs should include purchasing and preparing 734 electronic copies of the questionnaire and the shipping costs associated with mail out of the questionnaire.

Table 6-9. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire
Number of Respondents	Total Questionnaire Distribution Cost	Total Shipping Cost	Total
734	$1,837	$3,303	$5,140

Table 6-9. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire

Number of Respondents

Total Questionnaire Distribution Cost

Total Shipping Cost

Total

734

$1,837

$3,303

$5,140

Table 6-10 presents an estimate of the burden and labor costs that EPA will incur to administer the questionnaire. The table identifies the collection administration tasks to be performed by EPA employees and contractors, with the associated hours required for each grouping of related tasks. EPA determined Agency labor costs by multiplying Agency burden figures by an average hourly Agency labor rate for technical and managerial support using the Salary Table 2009-GS from the U.S. Office of Personal Management. This table can be found at the Web site http://www.opm.gov/‌oca/09tables/indexGS.asp. The government employee labor rates are $33.84 per hour for technical (GS-13, Step1) and $47.03 per hour for managerial (GS‑15, Step 1). EPA determined contractor labor costs by multiplying contractor burden figures by an average contract labor rate of $80 per hour. This rate is consistent with current Agency contracts.

Table 6-10. Agency Burden and Costs
Activities	Burden (hours)			Labor Cost
Activities	Agency	Contractor	Total Hours	Agency ($40.44/hr)	Contractor ($80/hr)	Total Cost
Develop the questionnaire instruments; Provide the draft questionnaire instruments to industry for review	300	2,000	2,300	$12,131	$160,000	$172,131
Meet with trade association representatives
Publish notice of anticipated ICR in Federal Register
Respond to all comments received
Revise Questionnaire instruments based on reviewer’s comments
Design sampling approach	200	920	1,120	$8,087	$73,600	$81,687
Develop a mailing list database
Develop a system to track mailing/e-mailing and receipt activities
Mail questionnaire files
Develop and maintain e-mail helpline	120	1200	1,320	$4,852	$96,000	$100,852
Maintain response tracking system	800	24,700	25,500	$32,348	$1,976,000	$2,008,348
Implement appropriate procedures for handling CBI responses
Review responses and collect missing data
Engineering and economic followup to clarify responses to questionnaires
Develop questionnaire database	40	1,800	1,840	$1,617	$144,000	$145,617
Upload and verify data	40	1,800	1,840	$1,617	$144,000	$145,617
Total	1,460	30,620	32,080	$59,035	$2,449,600	$2,508,635

6.c)Estimating the Respondents Universe and Total Burden Costs

EPA expects to receive 734 completed questionnaires. EPA estimates a total burden of 144,451 hours and a total labor and O&M costs of $ 9,228,948 for all respondents.

6.d)Bottom Line Burden Hours and Costs

Tables 6-11 through 6-13 summarize the total costs that the steam electric industry and the Agency will incur as a result of the ICR.

Table 6-11. Total Estimated Respondent Burden and Cost Summary

Number of Respondents	Total Burden (Hours)	Total Labor Cost	Total O&M Cost	Total Cost
734	144,451	$8,011,899	$1,217,049	$9,228,948

Table 6-12. Total Estimated Agency Burden and Cost Summary

Total Burden (Hours)	Total Labor Cost	Total O&M Cost	Total Cost
32,080	$2,508,635	$5,140	$2,513,775

Table 6-13. Annual Estimated Burden and Cost Summary

Entity	Total Burden (Hours)	Total Labor Cost	Total O&M Cost	Total Cost
Industry Burden	48,150	$2,670,633	$405,683	$3,076,316
Agency Burden	10,693	$836,212	$1,713	$837,925

6.e)Reasons for Change in Burden

Not applicable. This is a new collection.

6.f)Burden Statement

EPA estimates that the total burden to the 734 steam electric power plants for responding to the questionnaire will be approximately 197 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems to collect, validate, and verify information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose 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 number for EPA’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OW-2009-0819, which is available for online viewing at www.regulations.gov, or in person viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426.An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. Once in the system, select “search” then key in the Docket ID number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17^th Street, NW, Washington, DC. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID No. EPA-HQ-OW-2009-0819 and OMB Control No. 2040-NEW in any correspondence.

1 Although the scope of the steam electric ICR includes any generating unit primarily engaged in the production of electricity, the mailing list will be developed from EIA Forms 860 and 767. The minimum capacity necessary to be included in the EIA database is 1 MW. Therefore, the steam electric questionnaire will be distributed to plants operating steam electric generating units with a capacity of 1 MW or greater.

2 This form only applies to privately-owned utilities. A privately-owned electric utility is considered “major” if its sales and transmission services, in each of the three previous calendar years, exceeded one of the following: 1) one million megawatt hours of total annual sales; 2) 100 megawatt hours of annual sales for resale; 3) 500 megawatt hours of annual power exchanges delivered; or 4) 500 megawatt hours of annual wheeling for others. A privately-owned electric utility is considered “nonmajor” if it had total annual sales of 10,000 megawatt hours or more in the previous calendar year but is not classified as “major” under FERC Form 1 definition.

3 FERC Form 1 data for 2009 are expected to be available shortly after they are filed (due by April 18, 2010); consequently, EPA anticipates that Form 1 data will be publicly available by the time the survey is completed.

4 Certain in-scope facilities are owned by entities whose primary business is not electric power generation.

File Type	application/msword
File Title	Part A of the Supporting Statement – Draft 1
Author	ESabol
Last Modified By	Spencer W. Clark
File Modified	2010-03-03
File Created	2010-03-03