2227ss04

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (Renewal), EPA ICR Number 2227.04, OMB Control Number 2060-0610.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Stationary Spark Ignition Internal Combustion Engines were: 1) promulgated on January 18, 2008; and 2) amended on October 8, 2008, June 28, 2011, and January 30, 2013. These regulations apply to those units that commenced construction, modification, or reconstruction on or after the specified date. The provisions of this subpart are applicable to manufacturers, owners, and operators of stationary spark engines (SI) internal combustion engines (ICE). This information is being collected to assure compliance with 40 CFR part 60, subpart JJJJ.

In general, all NSPS standards require initial notifications, 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.

Over the next three years, an average of 17,558 respondents per year will be subject to these standards, plus253 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.”

The “Affected Public” is composed of manufacturers, owners and operators of stationary SI ICE. The “burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (Renewal). The Federal Government “burden” is attributed entirely to work performed by either Federal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (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, nitrogen oxides (NOx), carbon monoxide (CO), hydrocarbon (HC), non-methane hydrocarbon (NMHC), and volatile organic compound (VOC) emissions from stationary SI ICE cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart JJJJ.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards 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 standards 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 standards 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, leaks are being detected and repaired, and the standards are being met. The performance test may also be observed.

The required annual 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 JJJJ.

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 35023) on June 11, 2013. 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 standards, 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.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standards as they were being developed and the standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted: 1) the Engine Manufacturers Association (EMA), at (312) 929-1970; and 2) Cummins Incorporated, at (800) 343-7357.

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 manufacturers, owners, and operators of SI ICE. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards and the corresponding North American Industry Classification System (NAICS) codes are found in the following table.

Standard (40 CFR Part 60, Subpart JJJJ)	SIC Codes	NAICS Codes
Electric Power Generation, Transmission, or Distribution	4911, 4931, 4939	2211
Medical and Surgical Hospitals	8062, 8069	62211
Motor and Generator Manufacturing	3621,7694	335312
Pump and Compressor Manufacturing	3561, 3743, 3563, 3586	33391
Welding and Soldering Equipment Manufacturing	3548, 3699	333992
Pipeline Transportation of Natural Gas	4922, 4923	48621
Crude Petroleum and Natural Gas Production	1311	211111
Natural Gas Liquid Extraction	1321	211112
National security	9711	92811

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ).

A source must make the following reports:

Notifications / Reports
Initial notification requirements for owners/operators of non-emergency non-certified stationary SI ICE with a maximum horsepower greater than or equal to 500 HP.	60.7(a)(1) and 60.4245(c)
For owners and operators of non-certified stationary SI ICE with a maximum hp greater than 500, a copy of their performance test that demonstrates compliance as conducted in §60.4244.	60.4245(d)
Annual report for owners/operators of emergency stationary SI ICE with a maximum engine power more than 100 hp that operates or is contractually obligated to be available for more than 15 hours per calendar year.	60.4245(e)

A source must keep the following records:

Recordkeeping
Maintain records of initial notifications for sources with non-certified engines with a maximum hp greater than or equal to 500.	60.4245(c)
Maintain records of all maintenance conducted on any SI ICE.	60.4245(a)(2)
Maintain manufacturer’s certification information for any certified engine to demonstrate compliance.	60.4245(a)(3)
Maintain records of performance testing on any non-certified engine to demonstrate compliance.	60.4245(a)(4)
Maintain records of the hours of operation spent during non-emergency operation for emergency stationary SI ICE.	60.4245(b)

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 opacity, or for pressure drop and liquid supply pressure for control device.

Perform initial performance test, Reference Method 18, 320, or 25A test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Submit the required reports developing, acquiring, installing, and utilizing technology and system 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.

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

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 standards, 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. 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 industry-owned 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, 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.

During development of the rule, five of the 21 businesses evaluated were small according to the Small Business Administration (SBA) small business size standard. Applying this data to the respondent universe for this ICR resulted in approximately 24 percent or 4,180 small entities impacted by this ICR.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (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 23,286 hours (Total Labor Hours from Table 1below). 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 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(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) Burden	(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 a	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Engine Certification for Stationary Use b
- 25-300 hp				$14.90	91	$1,355.90
- 300-600 hp				$36.69	9	$330.21
- >600 hp				$175	14	$2,450.00
Initial Test for Engines not Certified	$1,000	253	$253,000
Subsequent Performance Test for Engines > 500 hp c				$1,000	2,107	$2,107,000
Total (rounded)			$253,000			$2,111,136

^a O&M cost per occurrence for certifications for stationary was increased by 4.4 percent from the previous ICR to account for the increase in the average annual consumer price index (ftp://ftp.bls.gov/pub/special.requests/cpi/cpiai.txt). The original certification costs were estimated in Table 5.2.1-4 of the document, “Final Regulatory Support Document: Control of Emissions from Unregulated Non-road Engines.”

^b The distribution of new engine types is based on the same distribution from the previously approved ICR.

^c Previously certified engines > 500-hp are required to conduct subsequent performance tests either after 3-years or 8,760 hours of operation after the initial performance test. It is assumed that 12 percent of existing engines, or 2,107 existing engines, will be rated at > 500 hp, have previously had an initial performance test conducted, and are now required to conduct a subsequent test over the next 3-year period.

The total capital/startup costs for this ICR are $253,000. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $2,111,136. 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 $2,364,136. These are the recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with 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 $247,754.

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 Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (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 17,558 existing respondents will be subject to the standards. It is estimated that an additional 253 respondents per year will become subject to the same standards. The overall average number of respondents, as shown in the table below, is 17,811 per year.

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

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
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	253	17,305	0	0	17,558
2	253	17,558	0	0	17,811
3	253	17,811	0	0	18,064
Average	253	17,558	0	0	17,811

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

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 17,811.

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
Initial notification (>500 hp non-certified engines) 1	30	1	n/a	30
Record Engine Maintenance	17,558	1	n/a	17,558
Recording hours in non-emergency operation	427	1	n/a	427
Total (rounded)				18,015

¹ We assume 12% of the 253 new respondents, or 30 respondents, will have engines rated at >500 hp.

The number of Total Annual Responses is 18,015.

The total annual labor costs are $2,277,790. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (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, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 23,286 hours at a cost of $2,277,790. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 hour per response.

The total annual capital/startup and O&M costs to the regulated entity are $2,364,136. 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 5,498 labor hours at a cost of $247,754. See Table 2 below: Average Annual EPA Burden and Cost – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (Renewal).

6(f) Reasons for Change in Burden

The increase in burden from the most recently-approved ICR is due to adjustments in the number of new or modified sources and updated labor rates. This ICR accounts for the industry growth since the last ICR renewal period and uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs.

Additionally, the capital/startup and O&M costs as calculated in section 6(b)(iii) have been corrected to reflect initial performance tests as a one-time capital/startup costs, rather than ongoing O&M costs. This results in an increase in capital costs, and a corresponding decrease in O&M costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 hour 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 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-2013-0353. 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-2013-0353 and OMB Control Number 2060-0610 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 Spark Ignition Internal Combustion Engines (40 CFR

Part 60, Subpart JJJJ) (Renewal)

Burden Item	(A) Person-hours per occurrence	(B) Number of occurrences per year	(C) Person-hours per respondent (AxB)	(D) Respondents per year	(E) Technical person-hours (CxD)	(F) Management person-hours (Ex0.05)	(G) Clerical person-hours (Ex0.1)	(H) Total Cost ($)
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements
A. Read Instructions b	0.5	1	0.5	253	126.5	6.33	12.65	$14,229.99
B. Required Activities
C. Gather Existing Information	See 3D
D. Write Report
-Initial notification (>500 hp non-certified engines)b	1	1	1	30.36	30.36	1.52	3.04	$3,415.20
-Subsequent Performance Test (>500 hp certified engines)c	1	1	1	2,106.96	2,106.96	105.35	210.70	$237,011.93
Subtotal for Reporting Requirements					2,603.41			$254,657.12
4. Recordkeeping Requirements
A. Record Engine Maintenance	1	1	1	17,558	17,558	877.9	1755.8	$1,975,099.42
B. Train personnel	N/A
C. Recording hours in non-emergency operation	1	1	1	427	427	21.35	42.7	$48,033.23
Subtotal for recordkeeping Requirements					20,682.75			$2,023,132.60
TOTAL LABOR BURDEN AND COST (rounded)					23,286			$2,277,790

Assumptions:

^a Costs are based on March 2013 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 $101.22, management at $123.04, and clerical at $51.18.  

^b It is assumed that 253 non-certified new engines will become subject to the rule each year over the 3-year period. Based on the estimated distribution of existing engines, it is assumed that 12 percent of new engines, will be rated at >500 hp and require initial notification.

^c Previously certified engines > 500-hp are required to conduct subsequent performance tests either after 3 years or 8,760 hours of operation after the initial performance test. It is assumed that 12 percent of existing engines will be rated at > 500 hp and have previously had an initial performance test conducted and are now required to conduct a subsequent test over the next 3-year period.

Table 2: Average Annual EPA Burden and Cost – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR

Part 60, Subpart JJJJ) (Renewal)

Activity	(A) EPA hours per operation	(B) Number of occurrences per year	(C) EPA hours per plant (AxB)	(D) Plants per year	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Total Cost ($)
Report Review
1. Initial notification (>500 hp non-certified engines)b	2	1	2	30.36	60.72	3.04	6.07	$3,146.78
2. Engine Certification for Non-certified Engine b,	2	1	2	253	506	25.3	50.6	$26,223.20
3. Engine Certification from non-road to stationary	1	1	1	0	0	0	0	$0
4. Performance Tests b	2	1	2	2,106.96	4,213.92	210.70	421.39	$218,384.30
TOTAL LABOR BURDEN AND COST (rounded)					5,498			$247,754

Assumptions:

^a Costs for notifications are based on Office of Personnel Management General Schedule 2013. Costs are estimated using the following rates: technical at $46.21, management at $62.27, and clerical at $25.01.

^b After full implementation, existing sources are no longer subject to these activities. It is assumed that 253 non-certified new engines will become subject to the rule each year over the 3-year period. Based on the estimated distribution of existing engines, it is assumed that 12 percent of new engines, will be rated at >500 hp and require initial notification. Additionally, previously certified engines > 500-hp are required to conduct subsequent performance tests either after 3 years or 8,760 hours of operation after the initial performance test. It is assumed that 12 percent of existing engines will be rated at > 500 hp and have previously had an initial performance test conducted and are now required to conduct a subsequent test over the next 3-year period. The agency is expected to experience burden from evaluating these new sources and subsequent testing of existing sources > 500 hp.