Burden calculations

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Overview

Table 1
Table 2
Capital and O&M
Number of Sources

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (Renewal)
					106.45	138.43	52.77
Burden Item	(A) Person-hours per occurrence	(B) Number of occurrences per year	(C) Person-hours per respondent (C=AxB)	(D) Respondents per year a	(E) Technical person-hours (E=CxD)	(F) Management person-hours (F=Ex0.05)	(G) Clerical person-hours (G=Ex0.1)	(H) Total Cost b ($)
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	0.5	1	0.5	18,570	9,285	464.25	928.5	$1,101,651.32
B. Required Activities	N/A
C. Gather Existing Information	See 3D
D. Write Report
Initial notification (>500 hp non-certified engines) d	1	1	1	30	30	1.5	3	$3,559.46
Subsequent Performance Test (>500 hp certified engines) e	1	1	1	2,228	2,228	111.4	222.8	$264,348.86
Annual report for emergency stationary SI ICE f	16	1	16	21	336	16.8	33.6	$39,865.90
Subtotal for Reporting Requirements					13,274			$1,409,426
4. Recordkeeping Requirements
A. Record Engine Maintenance	1	1	1	18,570	18,570	928.5	1,857	$2,203,302.65
B. Train personnel	N/A
C. Recording hours in non-emergency operation	1	1	1	427	427	21.35	42.7	$50,662.91
D. Records of initial notification, manufacturer's certifications, and performance tests	See 3D
Subtotal for recordkeeping Requirements					21,847			$2,253,966		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) g					35,100			$3,660,000		19048	2
TOTAL CAPITAL AND O&M COST (rounded) g								$2,480,000
GRAND TOTAL (rounded) g								$6,140,000
Assumptions:
a We assume there are an average of 18,317 existing respondents per year and an additional 253 respondents will become subject to the rule each year. The overall average number of respondents is 18,570 per year.
b This ICR uses the following labor rates: $106.45 for technical, $138.43 for managerial, and $52.77 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2015, “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 assume all new and existing respondents will have to familiarize themselves with the regulatory requirements each year.
d 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. (253 x 12% = 30.36, rounded to 30)
e 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. (18570 x 12% = 2228.4, rounded to 2228)
f We assume it will take 16 hours per annual report based on ICR 1975.06 (NESHAP For Stationary Reciprocating Internal Combustion Engines 40 CFR Part 63, Subpart ZZZZ). Based on the 2015 reporting data, 3 of the estimated 427 emergency stationary SI ICE reported under Subpart JJJJ for the purposes specified in §60.4243(d)(3)(i). Based on this reporting, approximately 0.70% of emergency stationary SI ICE submitted an annual report. The NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) estimated 5% of emergency stationary CI ICE will submit annual reports. Because there is only 1 year of available reporting data, it is unclear if the number of engines that reported in 2015 is representative of a typical reporting year. Therefore, the we assume 5% of emergency stationary SI ICE will be required to report to conservatively estimate respondent burden for this activity. (427 x 5% = 21.35, rounded to 21)
g Totals have been rounded to 3 significant figures. Figures may not added exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden – NSPS for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (Renewal)
					47.63	64.16	25.76
Activity	(A) EPA person-hours per occurrence	(B) Number of occurences per year	(C) EPA Person-hours per plant (C=AxB)	(D) Plants per year a	(E) Technical person-hours (E=CxD)	(F) Management person-hours (F=Ex0.05)	(G) Clerical person-hours (G=Ex0.1)	(H) Total Cost b ($)
Report Review
1. Initial notification (>500 hp non-certified engines)c	2	1	2	30	60	3	6	$3,204.84
2. Engine Certification for Non-certified Engine c	2	1	2	253	506	25.3	50.6	$27,027.48
3. Engine Certification from nonroad to stationary	1	1	1	0	0	0	0	$0
4. Performance Tests c	2	1	2	2,228	4,456	222.8	445.6	$238,012.78
5. Annual reports for emergency stationary SI ICE d	2	1	2	21	42	2.1	4.2	$2,243.39
TOTAL LABOR BURDEN AND COST (rounded) e					5,780			$270,000
Assumptions:
a We assume there are an average of 18,317 existing respondents per year and an additional 253 respondents will become subject to the rule each year. The overall average number of respondents is 18,570 per year.
b This ICR uses the following labor rates: $47.63 for technical, $64.16 for managerial, and $25.76 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2016 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.
c 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.
d We assume it will take 2 hours to review each annual report based on ICR 1975.06 (NESHAP For Stationary Reciprocating Internal Combustion Engines 40 CFR Part 63, Subpart ZZZZ). Based on the 2015 reporting data, 3 of the estimated 427 emergency stationary SI ICE reported under Subpart JJJJ for the purposes specified in §60.4243(d)(3)(i). Based on this reporting, approximately 0.70% of emergency stationary SI ICE submitted an annual report. The NSPS for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) estimated 5% of emergency stationary CI ICE will submit annual reports. Because there is only 1 year of available reporting data, it is unclear if the number of engines that reported in 2015 is representative of a typical reporting year. Therefore, the we assume 5% of emergency stationary SI ICE will be required to report to conservatively estimate respondent burden for this activity. (427 x 5% = 21.35, rounded to 21)
e Totals have been rounded to 3 significant figures. Figures may not added exactly due to rounding.

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Sheet 3: Capital and O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Burden	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent a	Number of Respondents with O&M	Total O&M, (ExF)
Engine Certification for Stationary Use b
- 25-300 hp				$15.10	91	$1,373.93
- 300-600 hp				$37.18	9	$334.60
- >600 hp				$176	14	$2,464
Initial Test for Engines not Certified	$1,000	253	$253,000	$0	0	$0
Subsequent Performance Test for Engines > 500 hp c				$1,001	2,228	$2,230,258
Total (rounded)			$253,000			$2,230,000
a O&M cost per occurrence for certifications for stationary was increased by 1.33 percent from the previous ICR to account for the increase in the average annual consumer price index (https://www.bls.gov/cpi/#data). 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.
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.

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Sheet 4: Number of Sources

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	253	18,064	0	0	18,317
2	253	18,317	0	0	18,570
3	253	18,570	0	0	18,823
Average	253	18,317	0	0	18,570