Download:
pdf |
pdfMEMORANDUM
From: Ron Jordan
USEPA/OW/EAD
ph: (202) 566-1003
[email protected]
To:
Jim Laity
OMB/OIRA
Date: May 17, 2010
Re:
Revisions to the Questionnaire for the Steam Electric Power Generating Effluent
Guidelines (EPA ICR Number 2368.01, OMB Control No. 2040–NEW)
As a result of public comments on the second Federal Register notice regarding the proposed
information collection request (ICR) for the steam electric effluent guidelines (75 FR 10791;
March 9, 2010) and OMB review, EPA made certain revisions to the questionnaire. The
following pages summarize the revised estimated burden for the ICR, as well as the editorial/
formatting and substantive changes to the questionnaire. In addition, it should be noted that EPA
is now allowing respondents 90 days to return the completed questionnaire to EPA, instead of 60
days (response time for Part G remains 120 days).
Summary of Changes to Burden Estimates
Questionnaire for the Steam Electric Power Generating Effluent Guidelines
The following tables, from Part A of the Supporting Statement, were updated to reflect the
changes made to the ICR following the 2nd FRN comment period. The changes are highlighted in
red.
The estimated number of respondents in the tables changed based on:
• Finalizing the sample frame population, making small adjustments in response to industry
input;
• Changing the cutoff date for Parts C, D, and F cost sections (January 1, 2000 instead of
January 1, 1985); and
• Correcting the number of sample points used for calculating Part G burden.
Changing the cutoff date for cost data substantially reduced the number of respondents for Part
C: Sections 2.3 through 2.5 and Sections 3.3 through 3.5; and Part D: Section 6. Respondents
for Part F: Section 3.2, are also likely to be substantially reduced, but EPA lacks data for
assessing the change in cutoff date. The approach for calculating the Part G burden was
modified to correct errors that previously double-counted certain activities, such as laboratory
procurement and obtaining sampling supplies.
The per-respondent burden for most questionnaire sections does not change substantially. In
some cases that is because the section did not significantly. In other cases, the reduced burden
due to questions EPA deleted was offset in the burden calculation by adjustments made to the
time required to respond to questions, in response to industry comments.
The 15 percent reduction in total industry burden is largely due to the fewer numbers of
respondents providing cost and other data, which results from changing the cutoff date from
1985 to 2000.
The revised total hourly burden estimate is 123,146 hours. This is 21,306 hours less than the
burden estimate prepared for the 2nd Federal Register notice (144,451). The corresponding total
dollar burden is $6,824,739. This is $1,187,159 less than the estimate prepared for the 2nd
Federal Register notice ($8,011,898). The revised total burden, including the capital costs, is
$8,041,789. The average hourly burden for the 733 respondents is 168 hours.
Table 6-2. Estimated Respondent Hours per Section of the Questionnaire
Hours by Job Category
Section
Estimated
Number of
Respondents
Respondent Basis
Part A (Total Respondents: 733 Plants)
Section 1 through
Section 7
733
Plant
Section 8
733
Plant
Section 9 through
11
733
Plant
Section 12
495
Plant
Part A Total
Part B (Total Respondents: 546 Plants)
Section 1 through
Section 3
242
Plant
Section 4
259
FGD System
Section 5 and
Section 7
259
FGD System
Section 6
55
FGD System
Section 8
68
FGD System
Part B Total
Part C (Total Respondents: 546 Plants)
Section 1
530
Plant
Section 2.1
1292
Generating Unit
Section 2.2
530
Plant
Section 2.3 through
Fly Ash Handling
2.5
22
System
Section 3.1
1292
Generating Unit
Section 3.2
530
Plant
Section 3.3 through
Bottom Ash Handling
3.5
40
System
Section 4
1292
Generating Unit
Section 5
1292
Generating Unit
Part C Total
Operating
Engr
Engr
Mng
r
Engr
Tech
Jr.
Acct
Financial
Manager
Clerical
Support
Legal
Total
Burden
per
Activity
(Hours)
13.00
4.75
4.00
0.75
0.00
0.00
0.00
0.00
0.00
0.00
2.00
1.00
0.00
0.00
19.00
6.50
6.25
4.00
28.00
2.50
0.75
8.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.00
1.00
5.00
0.00
0.00
0.00
9.75
5.75
41.00
6.00
8.00
1.25
1.25
0.00
0.00
0.00
0.00
0.00
0.00
1.00
1.00
0.00
0.00
8.25
10.25
4.00
3.50
6.75
28.25
1.25
0.00
1.25
5.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.00
2.50
1.00
6.50
0.00
0.00
0.00
0.00
6.25
6.00
9.00
39.75
1.50
4.50
2.50
0.50
1.00
0.25
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.50
0.50
0.00
0.00
0.00
0.00
2.50
6.00
2.75
14.00
5.50
2.00
1.25
1.00
0.25
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.50
0.50
0.00
0.00
0.00
0.00
16.75
7.00
2.25
12.5
1.25
1.25
45.00
1.25
0.50
0.50
6.50
0
0.00
0.00
0.00
0
0.00
0.00
0.00
0
0.00
0.00
0.00
1.5
0.00
0.00
4.50
0
0.00
0.00
0.00
15.25
1.75
1.75
56.00
Table 6-2. Estimated Respondent Hours per Section of the Questionnaire
Part D (Total Respondents: 546 Plants)
Section 1 and
Section 2
530
Plant
3.25
1.25
0.00
0.00
0.00
Pond/Impoundment/
Section 3
611
WWT System
8.25
2.00
0.00
0.00
0.00
Section 4
573
Ponds/Impoundments
7.25
2.00
0.00
0.00
0.00
Section 5
38
WWT Systems
7.50
1.25
0.00
0.00
0.00
Pond/Impoundment/
Section 6
75
WWT System
6.75
1.75
0.00
0.00
0.00
Part D Total
33.00
8.25
0.00
0.00
0.00
Part E (Total Respondents: 327 Plants)
Section 1 and
Section 2
792
Generating Unit
2.75
0.75
0.00
0.00
0.00
Section 3
792
Generating Unit
2.25
0.75
0.00
0.00
0.00
Part E Total
5.00
1.50
0.00
0.00
0.00
Part F (Total Respondents: 97 Plants)
Section 1 and 2
140
Ponds
3.75
1.50
0.00
0.00
0.00
Section 3.1
55
Landfills
5.75
1.50
0.00
0.00
0.00
Section 3.2
50
Landfills
6.25
1.00
0.00
0.00
0.00
Leachate Treatment
Section 4.1 through
4.5
9
Systems
15.50
4.00
0.00
0.00
0.00
Section 5
195
Ponds and Landfills
3.25
1.25
0.00
0.00
0.00
Part F Total
34.50
9.25
0.00
0.00
0.00
Part G (Total Respondents: 97 Plants)
Lab Procurement
30
Plant
0.00 18.00
6.00
0.00
0.00
Sample Collection
51
Sample
15.00
0.00
17.00
0.00
0.00
Data Entry and
Submittal
51
Sample
0.00
2.00
8.00
0.00
0.00
Part G Total
15.00 20.00
31.00
0.00
0.00
Part H (Total Respondents: 733 Plants)
Section 1
21
Plant
2.25
1.25
0.00
0.00
0.00
Section 2
21
Plant
4.25
1.25
0.00
0.00
0.00
Section 3
21
Plant
3.50
1.25
0.00
0.00
0.00
Part H Total
10.00
3.75
0.00
0.00
0.00
0.00
0.00
4.50
1.50
1.00
1.00
0.00
0.00
0.00
11.75
10.25
9.75
0.00
3.50
0.00
0.00
8.50
44.75
0.25
0.25
0.50
0.00
0.00
0.00
3.75
3.25
7.00
1.00
0.50
0.00
0.00
0.00
0.00
6.25
7.75
7.25
2.50
0.50
4.50
0.00
0.00
0.00
22.00
5.00
48.25
0.00
0.00
0.00
0.00
24.00
32.00
0.00
0.00
0.00
0.00
10.00
66.00
0.25
0.25
0.25
0.75
0.00
0.00
0.00
0.00
3.75
5.75
5.00
14.50
Table 6-2. Estimated Respondent Hours per Section of the Questionnaire
Part I (Total Respondents: 733 Plants)
Section 1 through
5.3
733
Plant
0.00
0.00
0.00 27.50
11.50
Part I Total
0.00
0.00
0.00 27.50
11.50
4.00
4.00
2.00
2.00
45.00
45.00
Table 6.3 Estimated Respondent Hours per Part of the Questionnaire
Hours by Job Category
Part
Part A
Part B
Part C
Part D
Part E
Part F
Part G
Part H
Part I
Total
Operating Engr
19,572
5,212
20,138
11,709
3,960
1,927
765
210
0
63,492
Engr Manager
5,686
1,035
4,484
3,209
1,188
622
642
79
0
16,944
Engr Tech
0
0
0
0
0
0
1,455
0
0
1,455
Jr. Acct
Financial
Manager
0
0
0
0
0
0
0
0
20,158
20,158
0
0
0
0
0
0
0
0
8,430
8,430
Clerical
Support
3,427
966
1,650
1,528
396
288
0
16
2,932
11,201
Legal
0
0
0
0
0
0
0
0
1,466
1,466
Total Burden
per Activity
(Hours)
28,685
7,212
26,272
16,446
5,544
2,837
2,862
305
32,985
123,146
Table 6-6. Total Estimated Respondent Burden
Hours by Job Category
Part
Part A
Part B
Operating
Engineer
1,125,028.88
299,565.09
Engineering
Manager
442,336.07
80,523.76
Engineering
Technician
0.00
0.00
Jr.
Accountant
0.00
0.00
Financial
Manager
0.00
0.00
Clerical
Support
69,679.84
19,631.13
Legal
0.00
0.00
Total Burden per
Activity (Dollars)
$1,637,044.78
$399,719.98
Part C
Part D
Part E
Part F
Part G
Part H
Part I
Total
1,157,563.43
673,037.09
227,626.93
110,766.94
43,973.38
12,071.13
0.00
3,649,632.88
348,819.59
249,682.00
92,427.27
48,411.51
49,948.07
6,126.81
0.00
1,318,275.07
0.00
0.00
0.00
0.00
53,094.87
0.00
0.00
53,094.87
0.00
0.00
0.00
0.00
0.00
0.00
856,230.65
856,230.65
0.00
0.00
0.00
0.00
0.00
0.00
601,744.59
601,744.59
33,548.80
31,058.05
8,051.71
5,845.62
0.00
320.24
59,615.20
227,750.59
0.00
0.00
0.00
0.00
0.00
0.00
118,010.55
118,010.55
Table 6-11. Total Estimated Respondent Burden
Number of
Respondents
733
Total Burden
(Hours)
123,146
Total Labor Cost
$6,824,740
Total O&M Cost
$1,217,049
Total Cost
$8,041,789
$1,539,931.82
$953,777.14
$328,105.92
$165,024.07
$147,016.33
$18,518.17
$1,635,600.98
$6,824,739.20
Page
xii, xv, xix
Question
Glossary
Change
Changes made to definition in glossary:
Filter Press: An apparatus used in solids dewatering that
utilizes a filter to separate liquid filtrate from solids.
Type of Change
Reason for
Change
Content
Change definition in Part D instructions to include missing
phrase regarding examples of ash ponds.
Comment
Remove zero discharge. Never used in the questionnaire.
xi, xv, xviii
Glossary
Glossary
Unbold and unitalicize all "surface water" and "byproduct"
terms in the glossary and the questionnaire.
Formatting
Change definition of process water:
Content
Process wastewater – Any water which comes into direct
contact with or results from the storage, production, or use of
any raw material, intermediate product, finished product,
byproduct, or waste product. Examples of process wastewater
include, but are not limited to, wastewater from ash handling,
equipment cleaning, air pollution control devices, rinse water,
coal pile runoff or other contaminated stormwater, and
condenser cooling water (i.e., once through cooling water,
cooling tower blowdown). Process wastewater does not
include other non-contact cooling for other miscellaneous
cooling purposes. Process wastewater can be treated,
recycled, discharged, or hauled off site for disposal. Sanitary
wastewater, potable water, sewage, fire protection, car
washes, and uncontaminated stormwater are not considered
process wastewater for the purpose of this information
collection request.
Comment
Comment
Page
A-4
Question
A1-6
Change
Reverse the order of "stop" and "continue" instructions for question A1-6.
Type of Change
Reason for
Change
Content
Comment
A-5
A1-8
Revise note to say: [NOTE: Do NOT include fuels only used for start upor emergency
generators when answering this question.]
Content
Comment
A-9
A2-4, Table A-2 Change question to read "… individual NPDES permit...."
Content
Comment
A-10-A-11
A2-5 through
A2- 10
Revise the instructions for Part A Section 2.2 to the following:
Content
"Throughout Section 2.2 (Questions A2-5 to A2-10), provide information for all internal and
final outfalls designated in the plant's NPDES permit . Note: This section does not require
information on stormwater outfalls, other than those storm water outfalls that may be
identified in the NPDES permit itself. Please provide all free response answers in the
highlighted yellow areas.
Comment
A2-10, Table A-3 Add a row for "storm water" percentage contribution. Provide a checkbox below the table
A-22
A5-2
Content
Comment
Checkbox: "Outfall is only used for emergency discharges. (Respondent still required to
answer Table A-3)"
Adjust instructions to say that aerial maps are not required to be provided if a nuclear plant is
located on site.
Comment
A-25-A-27
A6- 1
Change "operated in 2009" column to "Calendar Days in Operation".
Content
Comment
A-37
A 10-1, Table A- Revise column heading to "Design or Targeted Mercury Removal Efficiency (%)"
14
A3-2
Revise 2nd instruction paragraph:
A5-1
Additionally, provide the latitude and longitude at the pond outlet (see glossary), the closest
distance from the pond/impoundment unit to the nearest surface water, the year the
pond/impoundment unit was brought online (or is planned to be brought online), and indicate
whether the pond/impoundment is lined or unlined and whether leachate (see glossary) is
collected from the pond/impoundment (e.g., the pond/impoundment has a leachate collection
system or other means for collecting leaks or seepage, etc.). Note: If the
pond/impoundment does not have a pond outlet, provide the latitude and longitude
corresponding to the emergency outlet for the pond/impoundment
Revise question: Provide the geographical coordinates of the plant (degrees, minutes,
seconds) as reported to EIA on U.S. DOE/EIA Form-860, schedule 2, line 6.
Note: Geographical coordinates are not required for any plants that have any nuclear
units on site.
Checkbox: Geographical coordinates not provided, nuclear unit(s) located at the plant.
Remove EIA checkbox.
Content
Comment
Content
EPA
Content
EPA
Page
Question
A13-11
Part A
Destination
questions
A7-3
Change
Type of Change
Revise wording of question: Was any water used in the coal pulverization process, other than Formatting
that used for sluicing mill rejects?
Revise question to specify which destinations to check. If all destinations are required change Content
language to "Indicate all intermediate and final destination(s) of the FGD wastewater. If the
plant recycles the FGD wastewater, indicate the plant process to which this water is recycled.
[Check all that apply]."
Questions: 9-6, 9-11, 12-5, 13-5, 13-7
Added question to identify whether POTW effluent is used in condenser cooling system
Content
Reason for
Change
EPA
EPA
Comment
Page
Question
Instructions
B- 12
B4- 19
B1-2 (Table B-2)
B8-9
EPA Decision
Revise language on page B-1, to
match general instructions for Part B,
in order to clarify EPA's request and
highlight the date limitation for data to
be submitted.
Revise moisture content units from
ppm to percent by weight.
Revise last line of question
instructions: Also provide the design or
actual sulfur dioxide removal efficiency
for each FGD system.
Add: Yes (Continue) No (Skip to
Question B8-11)
Type of Change
Reason for
Change
Content
EPA
Content
EPA
Content
EPA
Content
EPA
Provide the volume of dry FGD
wastewater generated in 2009 (gpd)
and the frequency of dry FGD
wastewater generation (days).
____ gpd, over ______ days.
Part B Destination
questions
Revise question to specify which
Content
destinations to check. If all destinations
are required change language to
"Indicate all intermediate and final
destination(s) of the FGD wastewater.
If the plant recycles the FGD
wastewater, indicate the plant process
to which this water is recycled. [Check
all that apply]."
EPA
Questions: B7-5, B8-8, B8-10
Content
Revise the request for scrubber purge
monitoring data. Plants should provide
the J-flagged values from the lab, if
available. If the J-flagged values are
not available, the plant does not have
to report them, just enter "< Detection
Limit." (Draft ICR requires J value info
for all data sets.)
EPA
Change
Page
C-1
Type of Change
Question
General
C 1-2,
Table C-1
Change request for capital costs from 1985 to 2000
Combine "Buildings" and "Other Developed Areas" into
one category called "Buildings and Other Developed
Areas"
Content
Content
Reason for
Change
Comment
Add "cooling reservoir" to the (e.g., …) for Unusable
Land entry.
Comment
C-7
C-22
C-41
C2-7
C2-38
C3-9
Table C-2
Revise the question: If the current fly ash handling
operations for the steam electric generating unit are
expected to change from now until December 31,
2020, indicate how (i.e., convert to or add dry
handling capability).
Content
Comment
Make this question a "check all that apply" option. Also,
add option buttons "Expanding handling capacity" and
"Expanding storage capacity"
Content
Add a note to the question: Note: If the respondent
indicates that the ash is transported to a
pond/impoundment, in Question C2-45, the
intermediate storage and disposal information will
be provided in Part D. Therefore, the block diagram
should only include the conveyance portion of the
system.
Revise question: Does the plant use a mechanical drag Content
system (e.g., submerged chain conveyor (SCC)) to
remove bottom ash from the generating unit boiler(s)?
Refer to the glossary for the definition of dry
bottom ash handling systems.
Remove Fly Ash Class column from the table.
Content
Comment
Comment
EPA
C2-13/14
and C314/15
C2-17
C2-20
C2-25
C2-33
Sections
2.5, 2.6,
3.5, and
3.6
Remove questions from the questionnaire. We are not
interested ultimately in why the plant converted from wet
to dry, but how they converted.
Remove from questionnaire (overlap with Part B)
Remove from questionnaire.
Remove the request for"Number of dry-to-wet mixing
junctions" and "Distance(s) between hoppers and dry-towet mixing junction(s).
For the two landfill checkboxes, add place for plants to
insert the landfill IDs from Part A.
revise/simplify conveyance and intermediate storage
component lists to reduce burden.
Content
EPA
Content
Content
Content
EPA
EPA
EPA
Formatting
EPA
Content
EPA
Change
Page
Type of Change
Question
C3-8
C3-38
C2-4 and
C3-5
C3-33
Revise the question: If the current bottom ash handling
operations for the steam electric generating unit are
expected to change from now until December 31,
2020, indicate how (i.e., convert to or add dry
handling capability).
Make this question a "check all that apply" option. Also,
add option buttons "Expanding handling capacity" and
"Expanding storage capacity"
Add a note to the question: Note: If the respondent
indicates that the ash is transported to a
pond/impoundment, in Question C3-45, the
intermediate storage and disposal information will
be provided in Part D. Therefore, the block diagram
should only include the conveyance portion of the
system.
Restructured Part C to streamline/simplify and
substantially shorten the section and reduce potential
confusion.
Removed from questionnaire, too much overlap with C23 and C3-4, respectively.
Made same change to table as in question C2-26
(Combined distance columns, made "pipe" an option for
transporting the ash.
Reason for
Change
Content
EPA
Content
EPA
Content
EPA
Content
EPA
Content
EPA
Page
D2-3
D- 18
Change
Type of Change
Remove request for information about analytical methods
used for pilot- and full-scale studies
Revise the question
Content
Question
D4-9
Reason for
Change
EPA
Content
Describe any expansion(s), since January 1, 2000, to the
pond/impoundment unit, including the starting and ending
dimensions and the total capital associated with the
expansion(s).
Comment
Note: Total capital costs should include purchased equipment,
installation, buildings, site preparation, land, engineering
costs, construction expenses, and any other costs available.
D3-1
Fix references within checklist:
Formatting
EPA
4th check: "…to the chemicals listed in Tables D-7 and D-13"
7th check: "…flow rates that are entered into Tables D-3 and
D-4 in Questions D3-2 and D3-3."
Limit reuqest for capital costs to systems installed since 2000 Content
WWT Unit Drop Added brine concentrator, dryer, and evaporator to list of
Down
WWT Units to cover ZLD units.
Content
EPA
EPA
Change
Page
Instructions
to Part E
E-2-E-3
Type of Change
Question
E2- 1, Table
E-1
Content
Change definition:
"… any process wastewaters resulting from cleaning
(with or without chemical cleaning compounds) any
metal process equipment, including, but not limited to,
boiler tube cleaning, boiler fireside cleaning, and air
heater cleaning. Report all soot blowing operations
that use water or steam during the cleaning
event.”
Change instructions for E2-1 and E2-2:
Content
In Table E-1, provide information about a typical
cleaning event for each cleaning operation that uses
chemical cleaning compounds on metal process
equipment associated with fossil- or nuclear fueled
electric generating units.
E-7
E3-7
Reason for
Change
Comment
Comment
In Table E-2, provide information about a typical
cleaning event for each cleaning operation that does
not use chemical cleaning compounds on metal
process equipment associated with fossil- or nuclearfueled electric generating units.
Change unit "tpy" to "tons per cleaning event."
Content
Comment
Tables E-1 and
E-2
Revise codes for tables E-1 and E-2, so that cleaning Content
operations are identifiable in later sections of Part E.
For example, change: TUBE to TUBE_CHEM (Table
E-1) and TUBE_NO_CHEM (Table E-2)
EPA
Content
Tables E-1 and
E-2
Fix the example in "Typical Frequency" column so
that it reads "1 time every 3 years" and fix the
response to read "____time(s) every ____ years"
E3-5 and E3-7
Spelling errors: E3-5: "unknown"; E3-7 "permanently" Formatting
EPA
EPA
Change
Page
F-4
Question
F2-7
Type of Change
Content
Revise the question:
Does the plant collect stormwater, rainfall, or other process wastewaters in the collection
system for this pond/impoundment unit? If yes, identify thestormwater, rainfall, or process
wastewaters and their flow rates. If the process wastewater is not one of the response options
provided, select "Other" in the drop-down box and specify the type of process wastewater in the
yellow
highlighted space below.
Reason for
Change
Comment
Change units for all responses to gpy, not gpd.
F-7
F2-12
Delete question
F-24
F4-5
Revise question: "In Table F-7, list all improvements to the leachate treatment systemplanned Content
up to December 31, 2020."
F2-1
F2-7
F2-11
F2-12
F3-8 and F3-9
F2-6 and F3-12
F4-4
F4-6
Landfill Costs
Delete question
Spelling error: "identify", add "If other, explain:" prior to yellow response box
Revise questionnaire responses: change "month" to "year" for all.
Remove table from the questionnaire.
Change "HPDE" to "HDPE"
Questions require respondents to provide a description of the estimate method in the
comments tab. Allow space for explanation in question.
Revise instructions: "...Pond ID. The leachate treatment unit ID option accounts for the
possibility of multiple units; they are numbered sequentially. For example, if the leachate
treatment system includes two clarifiers, select CL-1 for the first clarifier and CL-2 for the
second. Note that these terms are defined in the "Code Tables" tab at the end of Part F. In the
“Plant Designation” column, provide the plant’s name for each leachate treatment unit. In the
“Date Added to System” column, either enter the date the unit was/will be installed if the unit is
a retrofit, or enter “original” if the unit was part of the original wastewater treatment system
installation.
Content
Content
Formatting
Content
Content
Formatting
Formatting
Comment
Comment
EPA
EPA
EPA
EPA
EPA
EPA
Formatting
to "...Pond ID. The drop down menu accounts for the possibility of multiple leachate treatment
system units; they are numbered sequentially. Note that these terms originated from the code
tables on the "Code Tables" tab, provided at the end of this workbook. For example, if the
leachate treatment system includes two clarifiers, select Clarification, Primary-1 for the first
clarifier and Clarification, Secondary-1 for the second. In the “Plant Designation” column, provid
name for each leachate treatment unit. In the “Date Added to WWT System”
column, either enter the date the unit was/will be installed if the unit is a retrofit,
or enter “original” if the unit was part of the original wastewater treatment
system installation.
EPA
Spelling error: "potential"
Formatting
Insert section to collect landfill costs:
Content
Insert question to collect the capital cost to install landfills (since 2000); mimic format of Q4-17.
Clarify that leachate treatment systems should NOT be included in the costs.
EPA
EPA
Insert question to collect the 2009 O&M to operate the landfill; mimic format of Q4-16. Again,
clarify that leachate treatment system O&M should NOT be included.
F3-6
F5-6
Removed request for cost information (because it is already requested in question F3-7)
Content
Water table wording changed to define the request: In Table F-14, provide the average water Content
table depth, averaged over the last year, at each monitoring well location and the distance to
the nearest surface water.
EPA
Comment
Page
G-2, G-3
Question
G2- 1 and
Figure G- 1
Page G-5
Change
Type of Change
Add another set of boxes to ask if leachate
is 100% returned to the pond. If yes, no
sample collection is required
Revise instructions:
Content
Reason for Change
Comment
Formatting
EPA
Add checkbox to determine that plants have Formatting
identified the sampling points on diagram
requested in F4-2.
EPA
EPA will then determine if the plant is
exempt from the leachate sample collection
requirement. If the plant can provide
previously collected leachate
characterization data, then the plant
should complete Question G4-1, then
continue to Section 5 (Question G5-1).
Also, the plant must provide the leachate
sampling data in Table G-4 found in the
"Part G Sampling Results" tab. If the plant
cannot collect the samples safely, then the
plant should SKIP Section 4, then
continue to Section 5 (Question G5-1).
G3-3
Checkbox: Leachate sampling collection
locations identified on the block diagram
requested in Part F, Question F4-2.
Change
Page
H-1
H-1,
H-6
H-7
Type of Change
Question
H1-2
H 1-3, Table
H-1
H2- 1, Table
H-2
Content
Revise question: Did the plant generate any process
wastewater (with the exception of wastewater from service
water treatment systems, such as reverse
osmosis reject water) during 2009 that is associated with
the production of electricity from nuclear generating units?
Add a definition in the glossary and revise term to
Content
"chemical and volume control system"
40 CFR Part 122.2 provides a definition for continuous that Content
states "a discharge which occurs without interruption
throughout the operating hours of the facility, except for
infrequent shutdowns for maintenance, process changes,
or other similar activities." Add this definition of
"continuous" to the questionnaire.
Reason for
Change
Comment
Comment
Comment
Change the term "intermittent" to "not continuous."
H-10
H-10
H- 14-H-15
H-16
H3-3
H3-4
H3-6, Table
H-4
H3-7
Revise question: "… In addition, provide the duration and Content
frequency of the discharges, and other dispositions off-site,
from the wastewater treatment system in 2009.
Delete question and add "oil/water separator" and
Content
"dechlorination" to the "Wastewater Treatment
Technology" drop down menu.
Content
delete last column of Table H-4
Comment
Revise H2-2: Indicate how the untreated process
wastewater is handled. If recycled, indicate to which
process the process wastewater is recycled.
Comment
Comment
Comment
Formatting
Underline/italicize "treated" in question H3-7.
H3-4 and H3-5
Page H-3
Table H-2
Table H-2
Delete question H3-4. Delete the last column of the table in Content
question H3-5.
Spelling error: "IF"
Formatting
Unlock cell G21 and change it to yellow in order to get
Formatting
"typical volume generated annually" for both continuous
and non-continuous flows.
Fix the example in "Typical Frequency" column so that it
reads "1 time every 3 years" and fix the response to read
"____time(s) every ____ years"
EPA
EPA
EPA
Content
EPA
Revisions to Part I
•
Part I Instructions: removed mention of a separate glossary for Part I terms. A single
glossary is used for all parts of the questionnaire.
•
P I-2, 2nd para of instructions: deleted “…when answering the rest of the questions in this
section.”.
•
P I-2, below Table I-2: added details of calculations that can be used to determine
ownership share of steam capacity for each company.
•
Q I2-11: changed the wording of the question to specify that EPA requests data
specifically on electric energy generated, purchased, exchanged and wheeled during each
year.
•
Added a new question, after questions I4-10 and I4-11, to request that respondents who
estimate plant-level balance sheet and/or income statement information describe the
estimation methodology they used, if other than the default methodology outlined in the
instructions.
•
P I-17, Col labeled “Gross and Net Electricity Generated”: separated the entry into two
distinct columns and specified the units to be used (MWh).
•
P I-21: added a note at the bottom of the table to clarify that total operating costs may also
include other operating costs such as fixed O&M costs.
•
Glossary: revised the definition of immediate parent firm to clarify that EPA seeks
information on the firm that is most immediately and closely responsible for facility
expenses associated with the steam electric generating units and to clarify that seek the
first entity in the plant ownership structure for which standard financial statements are
prepared and reported. The revised definition reads “Immediate parent firm – The first
entity in the facility’s ownership structure responsible for facility’s expenses associated
with steam electric generating units. This is generally the first entity in the plant
ownership structure for which standard financial statements are prepared and reported.
Note that for the purpose of Part I of the questionnaire, if a plant that has multiple owners,
detailed financial and economic data are requested, at a minimum, for the immediate
parent firm that holds the largest equity share in the plant. Respondents have the option to
provide detailed financial and economic data separately for each relevant immediate
parent firm, for example in cases where equity shares do not appropriately indicate
participation in a plant’s steam generation operations.”
•
Page I-3, Question I2-5: removed revenue indirectly derived from generation of electricity
(e.g., sale of steam or ash, waste combustion) from question I2-5 and instead request this
information as a specific line item in Question I2-7.
•
Page I-4, Question I2-7, Table I-4. “Total operating expenses” heading revised to “Total
Expenses”
•
Page I-4, Question I2-7, Table I-4: revised the question to clarify that all other expenses
should reflect the cost of activities detailed in Question I2-5.
•
Page I-4: combined all non-current assets in one entry in Table I-5 and no longer ask that
respondents report land and buildings separately from other equipment, machinery and
other physical capital when providing parent firm-level information.
•
Page I-5, Question I2-9: revised the wording of some of the items to match more closely
the wording used in FERC Form 1.
•
Page I-10, Question I4-7: To make the question easier to answer using existing data,
revised the question to simply ask respondents to identify the relevant range based on
SBA size standards (e.g., less than 50, 50-100, 100-250, 250-500, 500-750, 750-1,000,
1,000-1,500, and greater than 1,500).
•
Page I-21, Question I5-4: revised the definition and wording of Question I5-4 to refer
specifically to the categories of costs considered to be variable O&M costs for the purpose
of the ICR, namely: fuel handling, steam expenses (other than direct labor costs) and
electric expenses (other than direct labor costs). For the purpose of this ICR, clarified that
EPA does not consider scheduled maintenance such as maintenance of boiler or electric
plant or of other equipment to be “variable” O&M, but instead considers these costs to be
part of fixed O&M costs. Also revised the definition of variable O&M provided in the
glossary accordingly.
•
Glossary: Revised the definition of “Variable O&M” to read: “Variable O&M costs –
Operation and maintenance costs that vary directly in proportion to the amount of
electricity generated by a plant. For the purpose of this questionnaire, variable O&M costs
include fuel handling (i.e., FERC values 501 and 547), steam expense other than direct
labor costs (FERC value 502), and electric expense other than direct labor costs (FERC
value 505). All other costs (e.g., 502: maintenance of boiler plant; 512: maintenance of
electric plant; 533: maintenance of generating and electric equipment) are to be
considered Fixed O&M costs and are to be excluded from “Variable O&M” costs. Note
that fuel expenses are not included as Variable O&M or Fixed O&M costs but are
accounted for separately.
•
Total sources of electric energy in Question I2-10, Table I-7: clarified that total sources of
electricity include net energy exchanged. This is consistent with categories used by FERC
to define sources of energy in Form 1.
•
Total uses of electric energy in Question I2-11, Table I-8: clarified that total uses of
electricity include energy losses. This is consistent with categories used by FERC to
define the disposition of energy in Form 1.
| File Type | application/pdf |
| File Title | Microsoft Word - ICR-memo-to-OMB _steam electric_ _17 May 2010_.doc |
| Author | RJordan |
| File Modified | 2010-05-18 |
| File Created | 2010-05-18 |