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NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal)

OMB: 2060-0590

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13


SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY


NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal)


1. Identification of the Information Collection


1(a) Title of the Information Collection


NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal), EPA ICR Number 2196.03, OMB Control Number 2060-0590


1(b) Short Characterization/Abstract


The New Source Performance Standards (NSPS) for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII), were proposed on July 11, 2005, and promulgated on July11, 2006. These regulations apply to stationary compression ignition (CI) internal combustion engines (ICE). The standards apply to stationary sources whose construction, reconstruction, or modification begins after a standard for those sources is proposed. This information is being collected to assure compliance with 40 CFR part 60, subpart IIII.


Owners and operators of stationary CI ICE are required to submit an initial notification report. In addition, manufacturers are required to submit an application for certification, including emission data and other descriptive information for each engine family subject to the emission standards. They are also required to maintain records of corrective action taken after the backpressure monitor has alerted the owner or operator of a high backpressure limit. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS. Annual reports are also required.


Owners or operators of stationary CI ICE facilities are required to maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority. In the event that there is no such delegated authority, the reports are sent directly to the United States Environmental Protection Agency (EPA) regional office.


Based on our consultations with industry representatives, there is an average of one affected facility at each plant site and that each plant site has only one respondent (i.e., the owner/operator or manufacturer of the plant site).


All of the CI ICE units in the United States are owned and operated by the CI ICE industry (the “Affected Public”). These facilities in the United States are owned by either industry, state, local, tribal government. The burden to the “Affected Public” is listed below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal). The Federal government burden associated with the review of reports submitted by the respondent is shown below in Table 2: Average Annual Designated Administrator Burden – NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal).


The Office of Management and Budget (OMB) approved the currently active Information Collection Request (ICR) without any “Terms of Clearance.”


2. Need for and Use of the Collection


2(a) Need/Authority for the Collection


The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:


. . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).


The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years.


In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:


(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.


In the Administrator's judgment, emissions from CI ICE engines cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart IIII.


2(b) Practical Utility/Users of the Data


The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. In addition, the collected information is used for targeting inspections and as evidence in legal proceedings.


Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.


The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed.


3. Non-duplication, Consultations, and Other Collection Criteria


The requested recordkeeping and reporting are required under 40 CFR part 60, subpart IIII.


3(a) Non-duplication


If the subject standards have not been delegated, the information is sent directly 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 standards to implement the Federal standards, 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 standards. Therefore, no duplication exists.


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

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (73 FR 79470) on December 29, 2008. No comments were received on the burden published in the Federal Register.


3(c) Consultations


The Agency’s industry experts have been consulted, and the Agency’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts.


Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. We contacted the Engine Manufacturers Association (EMA), Mr. Joe Suchecki at (312) 827-8700.


It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice.


3(d) Effects of Less Frequent Collection


Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.


3(e) General Guidelines


None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance, and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond the five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.


3(f) Confidentiality


Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).


3(g) Sensitive Questions


None of the reporting or recordkeeping requirements contain sensitive questions.


4. The Respondents and the Information Requested


4(a) Respondents/SIC Codes


The respondents to the recordkeeping and reporting requirements are stationary compression ignition internal combustion engines. The North American Industry Classification System (NAICS) code, are listed below for source category description.


Standard (40 CFR, Part 60, Subpart IIII)

NAICS Codes

Electric Power Generation, Transmission, or Distribution

2211

Medical and Surgical Hospitals

622110

Motor and Generator Manufacturing

335312

Pump and Compressor Manufacturing

33391

Welding and Soldering Equipment Manufacturing

333992


4(b) Information Requested


None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, section 1320.5.


(i) Data Items


In this ICR, all the data recorded or reported is required by NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR part 60, subpart IIII).


A source must make the following reports:


Notifications

Initial notification requirements for owners/operators of non-emergency stationary CI ICE greater than 3,000 HP; non-emergency stationary CI ICE with a displacement of greater than 10 liters per cylinder; and non-emergency pre 2007 model year stationary CI ICE greater than 175 HP that are not certified

60.7(a)(1), 60.4214(a)(1)


A source must keep the following records:


Recordkeeping

Maintain records of notifications and maintenance conducted on the engine for owners/operators of non-emergency stationary CI ICE greater than 3,000 HP; non-emergency stationary CI ICE with a displacement of greater than 10 liters per cylinder; and non-emergency pre-2007 model year stationary CI ICE greater than 175 HP that are not certified.

60.4214(a)(2)

Maintain records of the hours of operation spent for emergency stationary CI ICE and the reason the engine was in operation during that time.

60.4214(b)

Maintain records of any corrective action taken after the backpressure monitor has notified the owner operator that the high backpressure limit of the engine is approached for stationary CI ICE equipped with DPF (no burden is estimated for this requirement since DPF is not required until the year 2011).

60.4214(c)


Electronic Reporting


Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.


Also, regulatory agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically. However, electronic reporting systems are not widely used.


(ii) Respondent Activities


Respondent Activities

Read instructions.

Perform initial performance test, Reference Methods, 1, 1A, 3, 3A, 3B, 4, 5, 7E tests, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of 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.

Transmit, or otherwise disclose the information.


Currently, sources are using monitoring equipment that provides parameter data in an automated way (e.g., continuous parameter monitoring system). Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping.



5. The Information Collected: Agency Activities, Collection Methodology, and Information Management


5(a) Agency Activities


EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.


Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the OTIS.


5(b) Collection Methodology and Management


Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properly installed and operational. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.


Information contained in the reports is entered into OTIS which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses OTIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. EPA-delegated Authorities can edit, store, retrieve and analyze the data.


The records required by this regulation must be retained by the owner or operator for two years.


5(c) Small Entity Flexibility


The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.


5(d) Collection Schedule


The specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Costs - NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal).


6. Estimating the Burden and Cost of the Collection


Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.


The 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.


6(a) Estimating Respondent Burden


The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 192,197 (Total Labor Hours from Table 1). This is based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously approved ICR, and any comments received.


6(b) Estimating Respondent Costs


(i) Estimating Labor Costs


This ICR uses the following labor rates:


Managerial $113.19 ($53.90 + 110%)

Technical $96.73 ($46.06 + 110%)

Clerical $45.93 ($21.87 + 110%)


These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2008, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.


(ii) Estimating Capital/Startup and Operation and Maintenance Costs


The type of industry costs associated with the information collection activities in the subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs, such as photocopying and postage.


(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs


Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device

(B)

Capital/

Startup Cost for One Respondent

(C)

Number of New Respondents

(D)

Total

Capital/

Startup Cost

(B X C)

(E)

Annual O&M Costs for One Respondent 1

(F)

Number of Respondents with O&M

(G)

Total O&M,

(E X F)

Certification/

Durability Testing

$0

0

$0

$28.40

5,880

$166,992

Selective Enforcement Audits

$0

0

$0

$375.50

200

$75,100




$0



$242,092

1 These costs are for laboratory time, use of testing equipment, engine parts, fuel and other supplies, and fabrication of test tools and fixtures.


The total capital/startup costs for this ICR are zero. This is the total of column D in the above table.


The total operation and maintenance (O&M) costs consists of photocopying, and postage, testing equipment are $242,092. This is the total of column G.


The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $242,000 (rounded).


6(c) Estimating Agency Burden and Cost


The only costs to the Agency are those costs associated with analysis of the reported information. The EPA compliance and enforcement program includes activities such as: the examination of records maintained by the respondents; periodic inspection of sources of emissions; and the publication and distribution of collected information.


The term Agency in the ICR refers to the designated Administrator of each state plan or to the United States EPA Administrator in the event that a state plan is not approved.


The average annual Agency cost during the three years of the ICR is estimated to be $16,762.


This cost is based on the average hourly labor rate as follows:


Managerial $61.36 (GS-13, Step 5, $38.35 + 60%)

Technical $45.52 (GS-12, Step 1, $28.45 + 60%)

Clerical $24.64 (GS-6, Step 3, $15.40 + 60%)


These rates are from the Office of Personnel Management (OPM) “2009 General Schedule” which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual Designated Administrator Burden -- NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal).


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


Based on our research for this ICR, 206,290 respondents will be subject to this standard in the next three years. It is estimated that 40 additional sources per year will become subject to the standard. The average number of respondents, as shown in the table below, is 206,290 per year.


The number of respondents is calculated using the following table which addresses the three years covered by this ICR.


Number of Respondents

Year

(A)

Number of New Respondents 1

(B)

Number of Existing Respondents

(C)

Number of Existing Respondents That Keep Records But Do Not Submit Reports

(D)

Number of Existing Respondents That Are Also New Respondents

(E)

Number of Respondents

(E=A+B+C-D)

1

40

235

205,975

0

206,250

2

40

235

206,015

0

206,290

3

40

235

206,055

0

206,330

Average

40

235

206,015

0

206,290

1 New respondents include sources with constructed, reconstructed and modified affected facilities.


To avoid double-counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three-year period of this ICR is 206,290.


The total number of annual responses per year is calculated using the following table:


Total Annual Responses

(A)

Information Collection Activity

(B)

Number of Respondents

(C)

Number of Responses

(D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification for non-emergency stationary CI ICE >3,000 hp, prime

32

1

0

32

Notification for non-emergency stationary CI ICE with a displacement >10 l/cyl, prime

8

1

0

8

Non-emergency operation

206,290

1

0

206,290




Total

206,330


The number of Total Annual Responses is 206,330


The total annual labor costs are $18,773,209. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal).


6(e) Bottom Line Burden Hours Burden Hours and Cost Tables


The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below.


(i) Respondent Tally


The total annual labor costs are $18,773,209. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost -- NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average one hour per response.


The total annual capital/startup and O&M costs to the regulated entity are $242,000.


(ii) The Agency Tally


The average annual Agency burden and cost over the next three years is estimated to be 372 labor hours at a cost of $16,762. See below Table 2: Average Annual Designated Administrator Burden -- NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal).


6(f) Reasons for Change in Burden


There is an adjustment increase in the total estimated labor hour burden as currently identified in the OMB Inventory of Approved ICR Burdens because the standard is now fully implemented. There has not been an increase in the number of facilities subject to the standard. It should be noted that the increase is not due to any program changes.


The previous ICR covered the initial phase of standard implementation which occurred over a three-year period. Hence, the average number of respondents during the initial phase is less than the number of respondents when the standard is fully implemented. This ICR shows the labor hour burden after full implementation.


There are no change of cost in the capital/startup and operating and maintenance (O&M) costs associated with this ICR.


6(g) Burden Statement


The annual public reporting and recordkeeping burden for this collection of information is estimated to average one hour per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, 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 valid OMB Control Number. The OMB Control Numbers for EPA’s regulations are listed at 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 Number EPA-HQ-OECA-2008-0899. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the content of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., 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 Enforcement and Compliance Docket and Information Center Docket is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2008-0899 and OMB Control Number 2060-0590 in any correspondence.


Part B of the Supporting Statement


This part is not applicable because no statistical methods were used in collecting this information.


Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal)


Burden item

(A)

Person hours per occurrence

(B)

No. of occurrences per respondent per year

(C)

Person hours per respondent per year

(C=AxB)

(D)

Respondents per year a

(E)

Technical person- hours per year

(E=CxD)

(F)

Management person hours per year

(Ex0.05)

(G)

Clerical person hours per year

(Ex0.1)

(H)

Total Cost

Per year b


1. Applications

N/A








A. Certification for stationary use









- Certification application c

44

1

44

35

1,540

77

154

$164,753.05

- Recordkeeping

4.4

1

4.4

154

154

7.7

15.4

$16,475.30

- Certificate/durability testing d

168

1

168

35

5,990

0

0

$579,412.27

- Selective enforcement audits

115

1

115

1

115

5.75

11.5

$12,293.80

- Defect reporting e

125

1

125

4

500

25

50

$53,491.25

B. Certification for stationary/non-road use

1

1

1

200

200

0

0

$19,346.00

2. Surveys and studies

N/A








3. Reporting requirements









A. Read instructions f

1

1

1

40

40

2

4

$4,279.30

B. Required activities

See 3D








C. Gather existing information

See 3D








D. Write report









Initial notification









>3,000 hp, prime g

2

1

2

32

64

3.3

6.4

$6,858.20

>10 l/cyl, prime h

2

1

2

8

16

0.8

1.6

$1,711.72

Pre-2007, not certified, prime, >175 hp

N/A








Subtotal for Reporting Requirements






8,983.45


$858621.79

4. Recordkeeping requirements









A. Read instructions

1

1

1

56,171

56,171

2,808.5

5,617.1

$6,879,878.30

B. Train personnel

N/A








C. Recording CDPF corrective action

N/A








D. Recording hours in non-emergency operation i

0.5

1

0.5

206,290

103,145

5,157.25

10,314.5

$11,034,709.90

Subtotal for Recordkeeping Requirements






183,213.35



TOTAL LABOR BURDEN AND COST (rounded)






192,196.8

192,197

(rounded)


$18,773,209.09

$18,773,209

(rounded)


Assumptions:

a We have assumed that there are 206,290 sources currently subject to the regulations, and it is estimated that 40 new sources are expected each year over the next three years.

b This ICR uses the following labor rates: $113.19 per hour for Executive, Administrative, and Managerial labor; $96.73 per hour for Technical labor, and $45.93 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2008 “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

c We have assumed that it will take 44 hours for all affected facilities to complete the certification application.

d We have assumed that it will take 168 hours for all affected facilities to complete the certificate/durability testing.

e We have assumed that it will take 125 hours for all affected facilities to complete the defect report.

f We have assumed that each of the 40 respondents will take one hour to read instructions.

g We have assumed that 80 percent of the 40 affected facilities are required to write the >3,000 hp, prime report.

h We have assumed that 20 percent of the 40 affected facilities will write the 10 l/cyl prime report.

i We have assumed that respondents are required to keep the records for the recording hours in non-emergency operation.






















Table 2: Average Annual Designated Administrator Burden – NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal)

Activity

(A)

EPA person- hours per occurrence

(B)

No. of occurrences per plant per year

(C)

EPA person- hours per plant per year

(C=AxB)

(D)

Plants per year a

(E)

Technical person- hours per year

(E=CxD)

(F)

Management person-hours per year

(Ex0.05)


(G)

Clerical person-hours per year

(Ex0.1)

(H)

Cost, $ b

Report Review









1. Initial notification of compliance c

2

1

2

40

80

4

8

$4,084.16

2. Certification application









A. Certification for stationary use d

2

1

2

35

70

3.5

7

$3,573.64

B. Certification for stationary/non-road use e

1

1

1

200

200

0

0

$9,104.00

Subtotals Labor Burden and cost





350

7.5

15

$16,761.80

TOTAL ANNUAL BURDEN AND COST (rounded)









372.5

372

(rounded)

$16,762

(rounded)



Assumptions:

a We have assumed that there are 206,290 sources currently subject to the regulations, and it is estimated that 40 new sources are expected each year over the next three

years.

b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $61.36 for Managerial (GS-13, Step 5, $38.35 x 1.6), $45.52 for Technical (GS-12, Step 1, $28.45 x 1.6) and $24.64 Clerical (GS-6, Step 3, $15.40 x 1.6). These rates are from the Office of Personnel Management (OPM) “2008 General Schedule” which excludes locality rates of pay.

c We have assumed that each of the 40 affected facilities would have to review the initial notification of compliance report.

d We have assumed that it will take 2 hours for each respondent to review the certification for stationary use report.

e We have assumed that it will take each of the respondent one hour one time per year to review the certification for stationary/non-road use.

File Typeapplication/msword
File TitleSF 83 SUPPORTING STATEMENT
Last Modified Byctsuser
File Modified2009-06-30
File Created2009-06-30

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