1564ss09

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal), EPA ICR Number 1564.09, OMB Control Number 2060-0202.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Small Industrial-Commercial- Institutional Steam Generating Units were proposed on June 9, 1989, promulgated on September 12, 1990, and was last amended on February 16, 2012. These regulations apply to both existing and new industrial-commercial-institutional steam generating units with maximum design heat input capacity of 29 megawatts (MW) (100 million Btu/hr) or less, but greater than or equal to 2.9 MW (10 million Btu/hr), commencing construction, modification, or reconstruction after June 9, 1989. The standards limit the emissions of sulfur dioxide (SO₂) and particulate matter (PM). The amendment removed the condensable PM testing requirement during continuous emissions monitoring system (CEMS) correlation test runs for sources that elect to install PM CEMS.  In addition, the amendment allowed certain sources to meet the opacity standard by conducting periodic opacity observations instead of using a continuous opacity monitoring system (COMS). However, new sources are still required to conduct initial performance tests. New facilities include those that commenced construction, modification or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 60, subpart Dc.

In general, all NSPS standards require initial notification reports, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS.

Any owner/operator subject to the provisions of this part shall 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 U. S. Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an average of 1.7 affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, an average of 268 respondents per year will be subject to these standards and 11 additional respondents per year will become subject to these same standards.

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

There are approximately 268 small industrial-commercial-institutional steam generating units in the United States, all which are publicly-owned and -operated by the small industrial-commercial-institutional steam generating industry. None of the 268 facilities in the United States are owned by either state, or local, or tribal, or Federal government. They are all owned and operated solely by privately-owned, for-profit businesses. The “burden” to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal). The “burden” to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors. This burden may be found below in Table 2: Average Annual EPA Burden and Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal).

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, SO₂ and PM emissions from small industrial-commercial-institutional steam generating units either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart Dc.

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. The collected information is also 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 test 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 check if the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and the standard is being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

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

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

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 its 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, duplication does not exist.

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 (78 FR 33409) on June 4, 2013. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency 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 EPA’s Office of Compliance. Otis is EPA’s 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.

Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply. In developing this ICR, the Agency contacted: 1) Novus Engineering, PC, at (518) 439-8235; and 2) the Council of Industrial Boiler Owners (CIBO), at (703) 250-9042, who also consulted with owners and council members.

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. In this case, no comments were received.

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

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

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

The reporting or recordkeeping requirements in the standard do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and/or operators of small industrial-commercial-institutional steam generating units. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards, and the corresponding North American Industry Classification System (NAICS) codes, are listed below.

40 CFR Part 60, Subpart Dc	SIC Codes	NAICS Codes
Crude Petroleum and Natural Gas	13	211
Sawmills and Planing Mills, General	24	321
Pulp Mills	26	322
Alkalies and Chlorine Manufacturing	28	325
Petroleum Refining	29	324
Tires and Inner Tubes	30	326, 316, 339
Steel Works, Blast Furnaces	33	324
Metal Cans	34	332
Motor Vehicles and Passenger Car Bodies	37	336
Electric Power Distribution	49	221
General Medical and Surgical Hospitals	80	622
Elementary and Secondary Schools	82	611

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc).

A source must make the following reports:

Notifications
Notification of construction or reconstruction	60.7(a)(1), 60.48c(a)
Notification of anticipated startup	60.7(a)(2), 60.48c(a)
Notification of actual startup date	60.7(a)(3)
Notification of modification	60.7 (a)(4)
Notification of demonstration of continuous monitoring system (CMS)	60.8 (a), 60.8 (d)
Semiannual reports of excess emissions and performance of continuous monitoring systems, and/or summary report forms	60.7(c), 60.7(d), 60.48(c), 60.48c(c)
Initial performance test results and any subsequence performance test s and, if applicable, the performance evaluation of the CEMS, and/or COMS	60.8(a)(d), 60.48c(b)

A source must keep the following records:

Recordkeeping
Keep records of startups, shutdowns, malfunctions of affected facilities; malfunctions of control devices; and periods where the continuous monitoring system is inoperative.	60.7(b)
Keep records of measurements, performance evaluations, calibration checks, adjustments and maintenance related to continuous monitoring systems	60.7(f)
Keep records of location, plans or specifications for exempted non-contact cooling water systems.	60.697(j)

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 still not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for SO₂ or sample fuel prior to combustion and estimate emissions using Method 6B. Install, calibrate, maintain, and operate COMS for opacity.

Perform initial performance test for SO₂, Reference Method 19 test (Method 6B for fuel sampling), and repeat performance tests if necessary.

Perform initial performance test for PM, Reference Methods 1, 5, 5B, 9 and/or 17, 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 and reporting equipment that provide 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, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

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

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

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, according to the 2005 Economic Impacts Analysis for the Proposed NSPS amendments in 2005 (see Docket ID: EPA-HQ-OAR-2005-0031-0059), 2 entities of the 17, or 12 percent of the projected new biomass units, were expected to be small entities. Applying this percentage to the respondent universe for this ICR, results in approximately 32 small entities impacted by this ICR.

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 Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 below 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 181,964 hours (Total Labor Hours from Table 1 below). These hours are 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 $123.04 ($58.59+ 110%)

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, “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 standards 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 regulations. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) 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 × C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E × F)
SO2 Monitoring
CEMS, control device inlet and outlet	$113,592	0	$0	$25,900	26	$673,400
CEMS, control device outlet only a	$73,028	19	$1,387,532	$17,100	430	$7,353,000
PM Monitoring
COMS for sources burning coal, residual oil, or wood b	$47,033	7	$329,231	$9,100	111.6	$1,015,560
TOTAL (rounded)			$1,716,763			$9,041,960

^a Number of Respondents with O&M (430 units) represents an annual average of 268 existing facilities, multiplied by an average of 1.7 affected units per facility, less an annual average of 26 units requiring inlet and outlet monitoring.

^b Number of Respondents with O&M (111.6 units) represents 107.2 existing affected facilities that require COMS, plus 4.4 new affected facilities per year that require COMS, averaged over the next three years [107/268 × 11 x 1.7 = 4.4 x 1.7 = 7 units (rounded)].

The total capital/startup costs for this ICR are $1,716,763. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $9,041,960. This is the total of column G.

The average annual cost for both capital/startup and operation and maintenance costs to the respondent industry over the next three years of the ICR is estimated to be $10,758,723. These are the recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with the analysis of the reported information. EPA's overall 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 average annual Agency cost during the three years of the ICR is estimated to be $229,976.

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 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 EPA Burden and Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 257 existing respondents will be subject to the standards. It is estimated that an additional 11 respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 268 per year.

The number of respondents is calculated using the following table that 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	11	246	0	0	257
2	11	257	0	0	268
3	11	268	0	0	279
Average	11	257	0	0	268

¹ New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard existing respondents submit initial notifications.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is 268.

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 of construction/reconstruction	4	1.7	N/A	6.8
Notification of modification	7	1.7	N/A	11.9
Notification of actual startup	11	1.7	N/A	18.7
Notification of initial performance test	11	1.7	N/A	18.7
Notifications of CEMS demonstration	11	1.7	N/A	18.7
Semiannual compliance report	268	2	N/A	536
			Total	610.8

The number of Total Annual Responses is 611 (rounded).

The total annual labor costs are $17,799,248. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal).

6(e) Bottom Line 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 below, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 181,964 hours at a cost of $17,799,248. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 298 hours (rounded) per response.

The total annual capital/startup and O&M costs to the regulated entity are $10,758,723. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 5,103 labor hours at a cost of $229,976. See Table 2 below: Average Annual EPA Burden and Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent and Agency burden from the most- recently approved ICR due to an increase in the number of new or modified sources. This ICR assumes an industry growth rate of 11 respondents per year, which results in an average increase of 33 respondents since the last ICR renewal period. The industry growth also results in an increase in O&M costs. In addition, this ICR corrects the number of new sources that are expected to use COMS for PM monitoring, which results in an increase in capital costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 298 hours (rounded) per response. “Burden” means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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 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-2013-0332. 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 contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then 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), WJC 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 docket center 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, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2013-0332 and OMB Control Number 2060-0202 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 Small Industrial-Commercial-Institutional Steam Generating Units

(40 CFR Part 60, Subpart Dc) (Renewal)

	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
Burden item	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=A×B)	Respondents per year a	Technical person- hours per year (E=C×D)	Management person-hours per year (E×0.05)	Clerical person-hours per year (E×0.1)	Cost ($)b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Read instructions c	2	1	2	11	22	1.10	2.2	$2,474.78
B. Required activities
1. Performance test (2.9 - 8.7 MW) h	8	2	16	7	112	5.60	11.2	$12,598.88
2. Performance test (8.7 – 29 MW) h	330	2	660	4	2,640	132	264	$296,973.60
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Notification of construction/ Reconstruction d, g	2	1.7	3.4	4	13.6	0.68	1.36	$1,529.86
Notification of modification e, g	2	1.7	3.4	7	23.8	1.19	2.38	$2,677.26
Notification of actual startup f, g	2	1.7	3.4	11	37.4	1.87	3.74	$4,207.13
Notification of initial performance test g	2	1.7	3.4	11	37.4	1.87	3.74	$4,207.13
Notification of demo of CEMS g	2	1.7	3.4	11	37.4	1.87	3.74	$4,207.13
Semiannual reports	16	2	32	268	8,576	428.8	857.6	$964,714.24
Results of performance test	See 3B
Subtotal for Reporting Requirements					13,224.5			$1,293,590
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Check computer system, calibrate continuous monitors	1.5	365	547.5	268	146,730	7,336.5	14,673	$16,505,657,70
F. Train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					168,739.5			$16,505,658
TOTAL LABOR BURDEN AND COST (rounded)					181,964			$17,799,248

Assumptions:

^a. We have assumed that the average number of respondents that will be subject to the rule will be 268. There will be eleven additional new sources per year that will become subject to the rule over the three-year period of this ICR.

^b. This ICR uses the following labor rates: $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and $51.18 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, “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 each new respondent will take two hours to read instructions.

^d. We have assumed that four new respondents will each take two hours to write notification of construction/reconstruction report.

^e. We have assumed that seven new respondents will each take two hours to write notification of modification report.

^f. We have assumed that all new respondents will each take two hours to write the semiannual report two times per year.

^g. We have assumed that occurrences/respondents for new facilities are based on an average of 1.7 affected facilities per respondent, with an estimated 10 percent retest.

^h. This estimate includes performance test (opacity) for coal, wood, and oil-fired steam generating units and test of continuous emissions monitor.

Table 2: Average Annual EPA Burden and Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating

Units (40 CFR Part 60, Subpart Dc) (Renewal)

	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
Activity	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=A×B)	Plants per year a	Technical person- hours per year (E=C×D)	Management person-hours per year (E×0.05)	Clerical person-hours per year (E×0.1)	Cost b
Review of notification of construction/‌reconstruction c	2	1.7	3.4	4	13.60	0.68	1.36	$704.81
Review of notification of modification c	2	1.7	3.4	7	23.80	1.19	2.38	$1,233.42
Review of notification of actual startup c	2	1.7	3.4	11	37.40	1.87	3.74	$1,938.24
Review of initial CEMS demonstration c	2	1.7	3.4	11	37.40	1.87	3.74	$1,938.24
Review of demonstration of monitoring system c	2	1.7	3.4	11	37.40	1.87	3.74	$1,938.24
Review of semiannual reports d	8	2	16	268	4,288	214.4	428.8	$222,223.46
TOTAL ANNUAL BURDEN AND COST (rounded)					5,103			$229,976

Assumptions:

^a We have assumed that the average number of respondents that will be subject to the rule will be 268. There will be eleven additional new sources that will become subject to the rule over the three-year period of this ICR.

^b. The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $62.27 (GS-13, Step 5, $38.92 × 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 × 1.6), and Clerical rate of $25.01 (GS-6, Step 3, $15.63 × 1.6). These rates are from the Office of Personnel Management (OPM) “2013 General Schedule” which excludes locality rates of pay.

^c. We have assumed that occurrences/respondent for new facilities are based on an average of 1.7 affected facilities per respondent.

^d. We have assumed that it will take 8 hours two times per year to review each semiannual report.