1975ss05_SRICE

1975ss05_SRICE.doc

NESHAP for Stationary Reciprocating Internal Combustion Engines (40 CFR part 63, subpart ZZZZ) (Final Rule)

OMB: 2060-0548

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NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR STATIONARY RECIPROCATING INTERNAL COMBUSTION ENGINES (40 CFR PART 63, SUBPART ZZZZ)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

(a) Title of the Information Collection

NESHAP for Stationary Reciprocating Internal Combustion Engines (40 CFR part 63, subpart ZZZZ) (Final Rule), ICR 1975.05, OMB Control Number 2060-0548

(b) Short Characterization

This supporting statement addresses new information collection activities that will be imposed by the revised National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE), 40 CFR part 63, subpart ZZZZ. These standards fulfill the requirements of section 112 of the Clean Air Act (CAA) as amended in 1990, which requires the EPA to promulgate standards for stationary RICE. The original NESHAP (69 FR 33474, June 15, 2004) applied only to stationary RICE greater than 500 horsepower (hp) located at a major source. The revised regulation includes new or reconstructed 4-stroke lean burn (4SLB) engines with a brake hp greater than 250 and less than or equal to 500 that are located at a major source. This ICR addresses only the costs associated with these sources. The revised regulation also addresses other types of stationary RICE less than 500 hp located at major sources, as well as stationary RICE located at area sources. The NESHAP requirements for these types of sources, including emergency and landfill and digester engines, are identical to the requirements of new source performance standards (NSPS) for stationary engines, so the costs are included in the compression ignition (CI) and spark ignition (SI) NSPS ICRs.

The information collection activities in this ICR include: stack tests, continuous operating parameter monitoring, one-time and periodic reports, and the maintenance of records. The information collection activities will enable the EPA to determine initial and continuous compliance with emission standards for the regulated pollutants.


2. NEED FOR AND USE OF THE COLLECTION

(a) Need/Authority for the Collection

The EPA is required under section 112 of the CAA to establish NESHAP that reflect the maximum achievable control technology (MACT) for achieving continuous emission reductions. Section 112(d) states:

Emissions standards promulgated under this subsection and applicable to new or existing sources of hazardous air pollutants shall require the maximum degree of reduction in emissions of the hazardous air pollutants subject to this section that the Administrator, taking into consideration the cost of achieving such emission reduction, and any non-air quality health and environmental impacts and energy requirements, determines is achievable for new or existing sources in the category or subcategory to which such emission standard applies . . . .


Section 112(i) further states:


After the effective date of any emissions standard, limitation or regulation promulgated under this section and applicable to a source, no person may operate such source in violation of such standard, limitation or regulation . . . .


In addition, section 114(a)(1) states that:


. . . the Administrator may require any person who owns or operates any emission source or who is subject to any requirement of this Act . . . to (A) establish and maintain such records, (B) make such reports, (C) install, use, and maintain such monitoring equipment or methods, (D) sample such emissions (in accordance with such methods, at such locations, at such intervals, and in such manner as the Administrator shall prescribe), and (E) provide such other information, as he may reasonably require.


Certain reports are necessary to enable the Administrator to identify stationary RICE subject to the regulation and to determine if the standards are being achieved.

(b) Practical Utility/Users of the Data

The information will be used by the EPA to identify sources subject to the standards and ensure that the emission standards are being met. Records and reports are necessary to enable the EPA to identify facilities that may not be in compliance with the standards. Based on reported information, EPA will decide which facilities should be inspected and what records or units should be inspected at the facilities. The records that facilities maintain will indicate to EPA whether facility personnel are operating and maintaining the equipment properly.


3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

(a) Nonduplication

Duplication in the reporting of stationary RICE information is not anticipated. If the standard has not been delegated, the information is sent to the appropriate EPA Regional Office. Otherwise, the information is sent directly to the delegated State or local agency. If a State or local agency has adopted their own similar regulation to implement the Federal regulation, a copy of the report submitted to the State or local agency can be sent to the Administrator in lieu of the report required by the Federal standard. Therefore, no duplication exists.

(b) Public Notice Required Prior to ICR Submission to OMB

A public notice of this collection will be provided in the final rule for the NESHAP.

(c) Consultations

In September 1996, the EPA chartered the Industrial Combustion Coordinated Rulemaking (ICCR) advisory committee under the Federal Advisory Committee Act (FACA). The committee’s objective was to develop recommendations for regulations for several combustion source categories under sections 112 and 129 of the CAA. The ICCR advisory committee, known as the Coordinating Committee, formed Source Work Groups for the various combustor types covered under the ICCR. One work group, the RICE Work Group, was formed to research issues related to stationary RICE. The RICE Work Group submitted recommendations, information, and data analysis results to the Coordinating Committee, which in turn considered them and submitted recommendations and information to the EPA. The Committee’s recommendations were considered by the EPA in developing the original regulations for stationary RICE, as well as for the additional stationary RICE now being addressed.

More recently, EPA has met with the Engine Manufacturers Association (EMA), the Interstate Natural Gas Association of America (INGAA), as well as other affected entities that will be subject to the new emission standards. Information and advice from these groups was considered when developing these additions to the NESHAP. The public also had the opportunity to review and comment on the proposed NESHAP and the ICR during the specified comment period.

(d) Effects of Less Frequent Data Collection

The frequency of the data collection requirements was chosen by the EPA to provide reasonable assurance that a facility is in compliance with the standard. Less frequent collection could result in long-term exceedances of the applicable emission standards.

(e) General Guidelines

With the exception of requiring records to be maintained for more than 3 years, none of the guidelines in CFR 1320.5 are being exceeded. This rule requires all records to be maintained for a period of 5 years, which is consistent with the General Provisions under 40 CFR part 63.

(f) Confidentiality

The type of data that will be required is principally emissions data and will not be confidential. If any information is submitted to the EPA for which a claim of confidentiality is made, the information will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B -- Confidentiality of Business Information.

(g) Sensitive Questions

This section is not applicable because the ICR does not involve matters of a sensitive nature.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

(a) Respondents/NAICS Codes

Respondents are owners or operators of new or reconstructed 4SLB stationary RICE that have a maximum hp rating greater than 250 and less than or equal to 500 that are located at a major source of hazardous air pollutants (HAP) emissions. A major source of HAP emissions is a plant site that emits or has the potential to emit 10 tons or more per year of any single HAP or 25 tons or more per year of any combination of HAP. These standards affect any industry, State, local, or tribal government using stationary RICE as defined in the regulation. The North American Industrial Classification System (NAICS) codes for facilities using stationary RICE affected by the regulation include: 2211 (Electric Power Generation, Transmission, or Distribution), 48621 (Natural Gas Transmission), 211111 (Crude Petroleum and Natural Gas Production), 2111112 (Natural Gas Liquids Producers), and 92811 (National Security).

(b) Information Requested

(i) Data Items: Attachment 1, Source Data and Information Requirements, summarizes the recordkeeping and reporting requirements of this regulation.

(ii) Respondent Activities: The respondent activities required by the regulation are provided under the first column of Tables 1 through 3, introduced in section 6(a).

(iii) Summary of Monitoring Requirements: The monitoring activities in this ICR include stack tests and continuous operating parameter monitoring. Spark ignition 4SLB with hp greater than 250 and less than or equal to 500 located at major sources must reduce carbon monoxide (CO) emissions by 93 percent or limit formaldehyde emissions to 14 parts per million by volume on a dry basis (ppmvd) at 15 percent oxygen. For either option, these sources must demonstrate compliance by conducting an initial performance test. If using an oxidation catalyst, these sources will be required to continuously monitor the catalyst inlet temperature and measure the catalyst pressure drop monthly. As an alternative to continuous parametric monitoring, these sources may choose to use a continuous emission monitoring system (CEMS); however, it is not expected that any sources will choose this option.


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

(a) Agency Activities

A list of Agency activities for the first 3 years following the effective date of the standard is provided in Tables 5 through 7, which are introduced in section 6(c).

(b) Collection Methodology and Management

Data obtained during periodic visits by EPA personnel, from records maintained by the respondents, and from information provided in semiannual reports will be tabulated and published for internal EPA use in compliance and enforcement programs. The final rule allows records to be retained in hard copy or electronic format to allow flexibility and minimize burden.

(c) Small Entity Flexibility

Minimizing the information collection burden for all sizes of organizations is a continuing effort for the EPA. The additions to the NESHAP for stationary RICE applies to engines less than or equal to 500 hp located at major sources and to all engines at area sources. However, these engines can demonstrate compliance by meeting the requirements in the CI and SI NSPS, with the exception being new and reconstructed 4SLB between 250 and 500 hp located at major sources. It is not expected that small entities will be affected by the requirements discussed for 4SLB engines between 250 and 500 hp at major sources. Thus, we do not believe that the NESHAP will have a significant impact on a substantial number of small entities.

(d) Collection Schedule

New and reconstructed 4SLB sources with hp greater than 250 and less than or equal to 500 located at major sources which began construction or reconstruction after the effective date of the standard must submit the following: notification of construction/reconstruction; notification of anticipated startup, delivered or postmarked not more than 60 days or less than 30 days before anticipated startup; and notification of actual startup, delivered or postmarked within 15 days after actual startup.

Any of these sources that do not install CEMS must submit a notification 60 days prior to each performance test. After the initial performance testing, sources must submit an initial notification of compliance within 180 days after completion of the initial compliance demonstration. Any source using an oxidation catalyst to meet the emission limit must also conduct semiannual performance testing. After 2 consecutive performance tests demonstrate compliance, sources may reduce the frequency of performance testing to once annually. All facilities must submit to the EPA a semiannual compliance report that includes any exceedances and malfunctions.


6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

(a) Estimating Respondent Burden

It is estimated that an average of 360 new 4SLB SI engines with hp greater than 250 and less than or equal to 500 at major sources will come online in each of the next 3 years. Sources must perform initial performance tests for each of these engines. Sources with oxidation catalysts must also conduct semiannual performance tests and monitor the catalyst inlet temperature and measure the catalyst pressure drop monthly. After 2 consecutive performance tests demonstrate compliance, test frequency may be reduced to annually. For this analysis, it was assumed that sources will continue to conduct performance tests semiannually.

An itemized breakdown of the reporting and recordkeeping requirements with the annual cost and labor requirements for the respondents subject to the NESHAP for the 3-year period following promulgation is presented in Tables 1 through 3. The annual cost and labor respondent burden estimates for the first year after promulgation are provided in Table 1. The burden estimates for years 2 and 3 are presented in Tables 2 and 3, respectively. These numbers were derived from the EPA’s experience with other standards and from discussions with industry representatives.

(b) Estimating Respondent Costs

The information collection activities for sources subject to these requirements are presented in Tables 1 through 3. The total cost for each respondent activity includes labor costs, capital/startup costs, and operation and maintenance (O&M) costs.

(i) Estimating Labor Costs The total cost for each respondent activity includes labor costs. Labor rates, on a per-hour basis, are taken from the Bureau of Labor Statistics web site (http://www.bls.gov/news.release/ecec.toc.htm) as posted for December 2005, except when noted otherwise in the tables. The base labor rates are $29.24 for technical/professional personnel, $33.98 for management, and $14.30 for clerical. The total compensation rate is $40.62 for technical/professional personnel, $48.56 for managerial, and $20.31 for clerical. This accounts for paid leave, insurance, etc. The compensation rates were then adjusted by an overhead and profit rate of 167 percent. The final total wage rates are $68 for technical/professional personnel, $81 for management, and $34 for clerical.

(ii) Estimating Capital/Startup Costs Capital costs associated with this NESHAP result from the purchase and installation of portable CO monitors, a continuous parameter monitoring system (CPMS) and a device to measure pressure drop across the catalyst monthly. The EPA estimated that each engine will have its own CPMS.

Capital costs are based on consultation with equipment vendors and industry experts. Portable CO monitors are expected to have an annualized capital cost of $583. Each facility can purchase one portable CO monitor and use it for several stationary RICE. The annualized capital cost of a CPMS for temperature monitoring and a device to measure pressure drop monthly is $1,708 per CPMS and device. The total capital costs for each year are shown in Tables 1 through 3. The total capital cost over the three year period is estimated to be $2,472,650 or an average of $824,217 per year.

TABLE 1. RESPONDENT BURDEN AND COST OF REPORTING FOR THE FIRST YEAR

Burden Item

Person-hours

per Occurrence

Number of

Occurrences

per year

Person-hours per Respondent

Respondents

per year

Technical

Person-hours

Management

Person-hours

Clerical

Person-hours

Capital/

Startup

Cost**

O&M Cost** 

Total Cost ($)

Year 1

1. Applications

N/A









 

2. Surveys and Studies

N/A









 

3. Reporting Requirements










 

A. Read Instructions

4

1

4

350

1,401

70

140



105,725

B. Required Activities










 

-Initial Performance Tests/ 1st Semiannual

24

2

48

350

16,815

841

1,682



1,268,697

-Semiannual Performance Tests***

24

2

48

0

0

0

0



0

C. Gather Existing Information

Included in 3D









 

D. Write Report










 

-Notification of construction/










 

reconstruction

2

1

2

350

701

35

70



52,862

-Notification of anticipated startup

2

1

2

350

701

35

70



52,862

-Notification of actual startup

2

1

2

350

701

35

70



52,862

-Notification of performance test***

2

2

4

350

1,401

70

140



105,725

-Initial notification of compliance

2

1

2

350

701

35

70



52,862

-Semiannual compliance report

4

2

8

350

2,803

140

280



211,449

4. Recordkeeping Requirements










 

A. Read Instructions

4

1

4

350

1,401

70

140



105,725

B. Train personnel

16

1

16

350

5,605

280

561



422,899

C. Continuous monitoring










 

-Purchase and install CEMS

120

1

120

0

0

0

0




-Purchase and install CPMS










 

- portable CO monitor

40

1

40

350

14,013

701

1,401

583

1,873

1,917,618

- pressure and temperature

40

1

40

350

14,013

701

1,401

1,708


1,655,584

-Record information

0.5

12

6

350

2,102

105

210



158,587

 










 

SUBTOTAL BURDEN AND COST




350

62,356

3,118

6,236

802,569

656,138

6,163,458

AVERAGE PER RESPONDENT





178

9

18

2,291

1,873

17,594

*Costs are based on December 2005 Bureau of Labor Statistics, Employment Cost Trends total compensation index which includes wages, salaries, and benefits. Costs are estimated using the following hourly rates: technical at $68, management at $81 and clerical at $34.


 

**Costs per Respondent.










 

***Performance tests are required semiannually until 2 consecutive tests deomonstrate compliance. For this analysis, it was assumed that all sources continue to test semiannually.


TABLE 2. RESPONDENT BURDEN AND COST OF REPORTING FOR THE SECOND YEAR

 

Burden Item


Person-hours

per Occurrence

Number of

Occurrences

per year

Person-

hours per

Respondent

Respondents

per year


Technical

Person-hours

Management

Person-hours

Clerical

Person-hours

Capital/

Startup

Cost**

O&M Cost**

Total Cost ($)

Year 2

1. Applications

N/A










2. Surveys and Studies

N/A










3. Reporting Requirements











A. Read Instructions

4

1

4

360

1,439

72

144



108,576

B. Required Activities











-Initial Performance Tests/1st semiannual

24

2

48

360

17,269

863

1,727



1,302,917

-Semiannual Performance Tests***

24

2

48

350

16,815

841

1,682



1,268,697

C. Gather Existing Information

Included in 3D










D. Write Report











-Notification of construction/











reconstruction

2

1

2

360

720

36

72



54,288

-Notification of anticipated startup

2

1

2

360

720

36

72



54,288

-Notification of actual startup

2

1

2

360

720

36

72



54,288

-Notification of performance test***

2

2

4

710

2,840

142

284



214,301

-Initial notification of compliance

2

1

2

360

720

36

72



54,288

-Semiannual compliance report

4

2

8

710

5,681

284

568



428,602

4. Recordkeeping Requirements











A. Read Instructions

4

1

4

360

1,439

72

144



108,576

B. Train personnel

16

1

16

360

5,756

288

576



434,306

C. Continuous monitoring











-Purchase and install CEMS

120

1

120

0

0

0

0




-Purchase and install CPMS











-portable CO monitor

40

1

40

360

14,391

720

1,439

583

1,873

1,969,342

- pressure and temperature

40

1

40

360

14,391

720

1,439

1,708


1,700,239

-Record information

0.5

12

6

710

4,260

213

426



321,452












SUBTOTAL BURDEN AND COST




710

87,158

4,358

8,716

824,217

673,836

8,074,161

AVERAGE PER RESPONDENT





242

12

24

2,291

1,873

22,443

*Costs are based on December 2005 Bureau of Labor Statistics, Employment Cost Trends total compensation index which includes wages, salaries, and benefits. Costs are

estimated using the following hourly rates: technical at $68, management at $81 and clerical at $34.

**Costs per Respondent.











***Performance tests are required semiannually until 2 consecutive tests deomonstrate compliance. For this analysis, it was assumed that all sources continue to test semiannually.

TABLE 3. RESPONDENT BURDEN AND COST OF REPORTING FOR THE THIRD YEAR

 

Burden Item


Person-hours

per Occurrence

Number of

Occurrences

per year

Person-

hours per

Respondent

Respondents

per year


Technical

Person-hours

Management

Person-hours

Clerical

Person-hours

Capital/

Startup

Cost**

O&M Cost**

Total Cost ($)

Year 3

1. Applications

N/A










2. Surveys and Studies

N/A










3. Reporting Requirements











A. Read Instructions

4

1

4

369

1,477

74

148



111,428

B. Required Activities











-Initial Performance Tests/1st semiannual

24

2

48

369

17,722

886

1,772



1,337,137

-Semiannual Performance Tests***

24

2

48

710

34,084

1,704

3,408



2,571,614

C. Gather Existing Information

Included in 3D










D. Write Report











-Notification of construction/











reconstruction

2

1

2

369

738

37

74



55,714

-Notification of anticipated startup

2

1

2

369

738

37

74



55,714

-Notification of actual startup

2

1

2

369

738

37

74



55,714

-Notification of performance test***

2

2

4

1,079

4,317

216

432



325,729

-Initial notification of compliance

2

1

2

369

738

37

74



55,714

-Semiannual compliance report

4

2

8

1,079

8,634

432

863



651,458

4. Recordkeeping Requirements











A. Read Instructions

4

1

4

369

1,477

74

148



111,428

B. Train personnel

16

1

16

369

5,907

295

591



445,712

C. Continuous monitoring











-Purchase and install CEMS

120

1

120

0

0

0

0




-Purchase and install CPMS











-portable CO monitor

40

1

40

369

14,768

738

1,477

583

1,873

2,021,065

- pressure and temperature

40

1

40

369

14,768

738

1,477

1,708


1,744,894

-Record information

0.5

12

6

1,079

6,476

324

648



488,594












SUBTOTAL BURDEN AND COST




1,079

112,585

5,629

11,258

845,864

691,533

10,031,916

AVERAGE PER RESPONDENT





305

15

30

2,291

1,873

27,171

*Costs are based on December 2005 Bureau of Labor Statistics, Employment Cost Trends total compensation index which includes wages, salaries, and benefits. Costs are

estimated using the following hourly rates: technical at $68, management at $81 and clerical at $34.

**Costs per Respondent.

***Performance tests are required semiannually until 2 consecutive tests deomonstrate compliance. For this analysis, it was assumed that all sources continue to test semiannually.

(iii) Total Operation and Maintenance Costs Costs associated with operation and maintenance (O&M) are the annual operating and maintenance costs of the portable CO monitors. These costs were also estimated through contact with equipment vendors and industry experts. The estimated total annual O&M cost of each portable CO monitor is $1,873 per facility. The total O&M costs are for each year are shown in Tables 1 through 3. The total O&M cost over the three year period is estimated to be $2,021,507, or an average of $673,835 per year.

(c) Estimating Agency Burden and Cost

Because the information collection requirements were developed as an incidental part of standards development, no costs can be attributed to the development of the information collection requirements. Because reporting and recordkeeping requirements on the part of the respondents are required under section 112 of the CAA, no operational costs will be incurred by the Federal government. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of sources that is part of the EPA’s overall compliance and enforcement program and, therefore, is not attributable to the ICR.

The Agency burden and cost estimates include only those items where the government will incur additional costs as a result of the information collection. These costs include user costs associated with the review and analysis of the reported information. These are presented in Tables 4 through 6.

The hourly burden for review of reports was estimated through discussion with personnel from local agencies who review these types of reports. Labor rates for Federal employees are based on the January 2006, Office of Personnel Management pay rates for General Schedule employees (see http://www.opm.gov/oca/06tables/html). The pay rates were multiplied by the standard government benefits multiplication factor of 1.6. The resulting average hourly labor costs are $48 for technical personnel, $80 for management, and $28 for clerical.

(d) Estimating the Respondent Universe and Total Burden and Costs

The respondent universe was estimated through projected industry orders for stationary RICE. It is estimated that an average of 360 new facilities will come online in each of the next 3 years. The NESHAP will therefore affect approximately 1,080 new facilities over the next 3 years. The total burden is calculated by adding the total technical, management, and clerical hours per year. The technical hours are calculated by multiplying the total hours per respondent by the number of respondents per year for each respondent activity. Management and clerical hours are assumed to be 5 percent and 10 percent of the technical hours, respectively.

The total cost is calculated by summing the labor, capital/startup, and O&M costs. With the exception of the costs for performance tests, the labor costs are determined by multiplying the total labor hours by the total wage rate for each labor category. The total capital/startup and O&M costs are calculated by multiplying the cost for each respondent by the number of respondents. Total cost is presented in the far right column of each table.

TABLE 4. FEDERAL GOVERNMENT BURDEN AND COST FOR THE FIRST YEAR

 

 

 

Technical

Management

Clerical

 


EPA Hours

Operations

Person-hours

Person-hours

Person-hours

Total Cost ($)

Activity

per Operation

per year

per year

per year

per year

Year 1

Report Review







1. Notification of construction/reconstruction

1

350

350

18

35

19,197

2. Notification of anticipated startup

0.5

350

175

9

18

9,599

3. Notification of actual startup

0.5

350

175

9

18

9,599

5. Notification of performance test

2

700

1,400

70

140

76,720

7. Initial notification of compliance

2

350

701

35

70

38,394

8. Compliance Report

2

700

1,400

70

140

76,720








SUBTOTAL BURDEN AND COST



4,201

210

420

230,229








*Costs are based on January 2006 Office of Personnel Management labor statistics for Federal Workers. Costs are estimated using the following rates:

technical at $48, management at $80, and clerical at $28.






TABLE 5. FEDERAL GOVERNMENT BURDEN AND COST FOR THE SECOND YEAR

 

 

 

Technical

Management

Clerical

 


EPA Hours

Operations

Person-hours

Person-hours

Person-hours

Total Cost ($)

Activity

per Operation

per year

per year

per year

per year

Year 1

Report Review






 

1. Notification of construction/reconstruction

1

360

360

18

36

19,715

2. Notification of anticipated startup

0.5

360

180

9

18

9,858

3. Notification of actual startup

0.5

360

180

9

18

9,858

5. Notification of performance test

2

1,420

2,840

142

284

155,649

7. Initial notification of compliance

2

360

720

36

72

39,430

8. Compliance Report

2

1,420

2,840

142

284

155,649

 






 

SUBTOTAL BURDEN AND COST

 

 

7,120

356

712

390,158








*Costs are based on January 2006 Office of Personnel Management labor statistics for Federal Workers. Costs are estimated using the following rates:

technical at $48, management at $80, and clerical at $28.






TABLE 6. FEDERAL GOVERNMENT BURDEN AND COST FOR THE THIRD YEAR

 

 

 

Technical

Management

Clerical

 


EPA Hours

Operations

Person-hours

Person-hours

Person-hours

Total Cost ($)

Activity

per Operation

per year

per year

per year

per year

Year 1

Report Review






 

1. Notification of construction/reconstruction

1

369

369

18

37

20,233

2. Notification of anticipated startup

0.5

369

185

9

18

10,116

3. Notification of actual startup

0.5

369

185

9

18

10,116

5. Notification of performance test

2

2,159

4,317

216

432

236,580

7. Initial notification of compliance

2

369

738

37

74

40,466

8. Compliance Report

2

2,159

4,317

216

432

236,580

 






 

SUBTOTAL BURDEN AND COST

 

 

10,111

506

1,011

554,091








*Costs are based on January 2006 Office of Personnel Management labor statistics for Federal Workers. Costs are estimated using the following rates:

technical at $48, management at $80, and clerical at $28.





(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally A breakdown for each of the collection, reporting, and recordkeeping activities required by the NESHAP is presented in Tables 1 through 3. The estimate of total annual hours requested from the respondents was based on the assumptions outlined in section 6(d) of this supporting statement. The EPA estimated the respondent burden by totaling the hours for the first 3 years after the implementation of the NESHAP for technical, managerial, and clerical staff at the facility, and then dividing that total by three to determine the average annualized burden. The 3-year summary results are presented in Table 7. The total number of responses for these respondents over the first 3 years after the implementation of the NESHAP is estimated to be 12,875, or an average of 4,292 per year. For the first 3 years after the implementation of the NESHAP, the EPA estimates that industry will expend 100,471 hours annually at a cost of $8,089,845 per year to meet the monitoring, recordkeeping, and reporting requirements.

(ii) The Agency Tally A breakdown for each of the Agency activities required for the NESHAP is provided in Tables 4 through 6. The bottom line Agency burden hours and costs, presented in Table 8, are calculated by totaling the hours per year for technical, managerial, and clerical staff, and by totaling the cost column. The average annual burden is calculated by dividing the 3-year total by three. The estimated average annual burden, over the first 3 years, for the Agency will be 8,216 hours at a cost of $391,493 per year.

TABLE 7. SUMMARY OF RESPONDENT BURDEN AND COST

 






 

 

Number of

Technical

Management

Clerical

Total

 

Year

Respondents

person-hours

person-hours

person-hours

person-hours

Total Cost ($)**

First

350

62,356

3,118

6,236

71,709

6,163,458

Second

710

87,158

4,358

8,716

100,232

8,074,161

Third

1,079

112,585

5,629

11,258

129,472

10,031,916

 






 

Three Year Total

2,140

262,099

13,105

26,210

301,414

24,269,536

 






 

Annual Average

713

87,366

4,368

8,737

100,471

8,089,845

 






 

*Costs are based on December 2005 Bureau of Labor Statistics, Employment Cost Trends total compensation index which includes wages, salaries, and benefits. Costs

are estimated using the following hourly rates: technical at $68, management at $81 and clerical at $34, unless noted otherwise in this supporting statement.

**Total cost include capital/startup costs and O&M costs.
















TABLE 8. SUMMARY OF AGENCY BURDEN AND COST

 






 

 

Number of

Technical

Management

Clerical

Total

 

Year

Respondents

person-hours

person-hours

person-hours

person-hours

Total Cost ($)

First

350

4,201

210

420

4,831

230,229

Second

710

7,120

356

712

8,188

390,158

Third

1,079

10,111

506

1,011

11,628

554,091

 






 

Three Year Total

2,140

21,432

1,072

2,143

24,647

1,174,478

 






 

Annual Average

713

7,144

357

714

8,216

391,493

 






 

*Costs are based on December 2005 Bureau of Labor Statistics, Employment Cost Trends total compensation index which includes wages, salaries, and benefits. Costs are estimated using the following hourly rates: technical at $48, management at $80 and clerical at $28, unless noted otherwise in this supporting statement.

(iii) Variations in the Annual Bottom Line The total burden and cost estimates for the first 3 years after the NESHAP is promulgated are given in Tables 1 through 3 and Table 7. The variation in total activity and respondent burden and cost from year to year is shown in the tables. In years 1, 2, and 3, the total costs are $6,163,458; $8,074,161; and $10,031,916; respectively (see Tables 1 through 3 and 7). In the first year, 350 engines are in startup phase with initial and startup notifications, performance tests and compliance reports. In the second year, 360 engines are in startup phase and 350 engines continue to operate with required semiannual performance tests and reporting. In the third year, 369 engines are in startup mode and 710 engines continue to operate with semiannual performance tests and compliance reports. Thus, the number of respondents, the respondent burden and respondent costs increase each year. However, the average burden and cost per respondent will decrease slightly each year because a smaller percentage of sources will be in startup mode. For example, the total number of respondent labor hours in the first year for each engine is 204 hours (71,709/350 = 204). This represents a total cost to this respondent of $17,594 ($6,163,458/350 = $17,594) in the first year. In the second year, the respondent hours and costs for each facility will decrease to 141 and $11,371; respectively. In the third year, the respondent hours will be 120 and the costs will be $9,294.

The total number of agency hours for review of reports also increases as more engines startup. Each year the agency must review all of startup notifications for that year, semiannual compliance reports from that year, and semiannual compliance reports from engines started up in all previous years since 2008. The total number of agency hours for years 1, 2, and 3 are 4,831; 8,188; and 11,628, respectively. The corresponding agency costs for activities during these years are $230,229; $390,158; and $554,091 (see Table 8).

(f) Reasons for Change in Burden

The estimate of burden on this ICR has been revised in order to account for additional sources that will be affected as a result of a final rule that was promulgated on December 20, 2007.

(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 23 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 for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

EPA has established a public docket for this ICR under Docket ID

No. EPA-HQ-OAR-2005-0030, which is available for public viewing at the Air and Radiation Docket and Information Center, 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 Air Docket is (202) 566-1742. An electronic version of the public docket is available through at http://www.regulations.gov. Use this site 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 “advance search,” then “Docket 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 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. (EPA-HQ-OAR-2005-0030) in any correspondence the OMB Control Number (2060-0548).

PART B OF THE SUPPORTING STATEMENT


This section is not applicable because statistical methods are not used in data collection associated with this regulation.






Recordkeeping Requirements


40 CFR 63

Subpart ZZZZ


5-year retention of records


63.6660(b)


Records of all notifications and reports


63.6655(a)(1)


Records of the occurrence and duration of each startup, shutdown, or malfunction of the stationary RICE and each malfunction of the air pollution control equipment


63.6655(a)(2)


Records of performance tests and performance evaluations


63.6655(a)(3)


Records of any malfunction of the CEMS


63.6655(b)(1)


All CEMS calibration checks


63.6655(b)(1)


All adjustments and maintenance performed on CEMS


63.6655(b)(1)


Previous (i.e., superseded) versions of the performance evaluation plan


63.6655(b)(2)


Request for alternatives to the relative accuracy test audit


63.6655(b)(3)


Records of the date and time that each deviation started and stopped, and whether the deviation occurred during a period of malfunction or during another period


63.6650(b)(4)


Records of daily fuel usage for landfill gas and digester gas fired units


63.6655(c)


Records of the catalyst pressure drop (measured monthly) and catalyst inlet temperature (4-hour average)


63.6655(d)


Records of the average reduction of CO emissions determined from CEMS measurements before and after the emission control device, using a 4-hour average, averaged every hour


63.6655(d)



Reporting Requirements


40 CFR 63

Subpart ZZZZ


Report the following information semiannually:

-company name and address

-name, title, and signature of the responsible official certifying the accuracy of the report

-date of report and beginning and ending dates of the reporting period

-if no deviations occurred during the period, a statement that no deviations occurred

-information on deviations, startup, shutdown, and malfunctions


63.6650


Report the following information by fax or telephone within 2 working days after starting actions inconsistent with the SSMP:

-an immediate startup, shutdown, and malfunction report which contains actions taken for the event


63.6650


Report the following information by letter within 7 working days after the end of the event, unless alternative arrangements have been made with the permitting authorities:

-name, title, and signature of the responsible official who is certifying the accuracy of the report

-the circumstances of the event

-the reasons for not following the startup, shutdown, and malfunction plan


63.6650


9


File Typeapplication/msword
File TitlePART A OF THE SUPPORTING STATEMENT FOR STANDARD FORM 83
Authorbriddle
Last Modified ByHiggins_C
File Modified2008-04-25
File Created2008-04-25

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