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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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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 2196.06, 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, promulgated on July 11, 2006, and initially amended on both June 28, 2011, and January 30, 2013, and most-recently amended on July 7, 2016 (81 FR 44219)1. These regulations apply to manufacturers, owners and operators of new stationary compression ignition (CI) internal combustion engines (ICE). New facilities include those that commenced construction, modification or reconstruction after the date of proposal. For the purposes of this subpart, the date that construction commences is the date the engine is ordered by the owner or operator. This information is being collected to assure compliance with 40 CFR Part 60, Subpart IIII.


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 containing these documents and retain the file for at least two years following the generation date of such maintenance reports and records. All reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.


The “Affected Public” include manufacturers, owners, and operators of stationary CI ICE units. The ‘burden’ to the Affected Public 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). The ‘burden’ to the “Federal Government” 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 Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal). There are approximately 206,885 facilities, which are owned and operated by either industry, state, local, or tribal government. We assume that they will all respond to EPA inquiries.


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


Over the next three years, approximately 206,885 respondents per year will be subject to the standard, including 40 additional respondents per year that will become subject to these standards.


The Office of Management and Budget (OMB) approved the currently active 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 eight 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, hazardous air pollutant emissions from CI ICE 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 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. 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 standards. Continuous emission monitors are used to ensure compliance with these 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 these 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 and that these 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 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 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 (83 FR 24785) on May 30, 2018. No comments were received on the burden published in the Federal Register for this renewal.


3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 206,885 respondents will be subject to these standards over the three-year period covered by this ICR, including 40 new respondents per year that will become to these same standards.


Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Engine Manufacturers Association (EMA), at (312) 929-1970, and 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 for 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 these 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 stationary CI ICE. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standard and the corresponding North American Industry Classification System (NAICS) codes are listed below for stationary source compression ignition internal combustion engines:



Standard (40 CFR, Part 60, Subpart IIII)


SIC Codes


NAICS Codes

Electric Power Generation, Transmission, or Distribution

4911, 4931, 4939

2211

Medical and Surgical Hospitals

8062, 8069

622110

Motor and Generator Manufacturing

3621, 7694

335312

Pump and Compressor Manufacturing

3561, 3743

33391

Welding and Soldering Equipment Manufacturing

3548, 3699

333992

4(b) Information Requested


(i) Data Items


In this ICR, all the data that are recorded or reported is required by the 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, or have a displacement of greater than 10 liters per cylinder; or are pre-2007 model year engines that are greater than 175 HP and not certified.

§ 60.7(a)(1),

§ 60.4214(a)(1)



Reports

Annual report for owners/operators of emergency stationary CI 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.

§ 60.4214(d)

For stationary CI ICE equipped with AECDs, report the use of AECDs as required by 40 CFR 1039.665(e).

§ 60.4214(e)


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, or have a displacement of greater than 10 liters per cylinder; or are pre-2007 model year engines that are greater than 175 HP and 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 diesel particulate filter (DPF).

§ 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. Additionally, the annual report must be submitted electronically using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX). The annual report is required for owners/operators of emergency stationary CI ICE with a maximum engine power more than 100 HP that either operates or is contractually obligated to be available for more than 15 hours per calendar year. Is it assumed that approximately 5% of respondents (which is equal to 10,344 respondents) are required to submit this annual report.


(ii) Respondent Activities



Respondent Activities


Familiarization with the regulatory requirements.


Install, calibrate, maintain, and operate hourly meters or CMS for backpressure


Perform initial performance test, Reference Method 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 collecting, validating, and verifying information.


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


Develop, acquire, install, and utilize technology and systems for disclosing and providing information.


Train personnel to be able to respond to a collection of information.


Transmit, or otherwise disclose the information.


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 Enforcement and Compliance History Online (ECHO) and ICIS.


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 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 annual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.


Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS 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


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 regulations. 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 Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (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. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.


The Agency may neither conduct nor 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 record-keeping and reporting requirements is estimated to be 408,000 (Total Labor Hours from Table 1). 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 $147.40 ($70.19+ 110%)

Technical $117.92 ($56.15 + 110%)

Clerical $57.02 ($27.15 + 110%)


These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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(s) 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)

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


(F)

Number of Respondents with O&M


(G)

Total O&M,

(E X F)

Certification/

Durability Testing

$0

0

$0

$28.40

5,880

$167,000

Selective Enforcement Audits

$0

0

$0

$375.50

1

$375.50

TOTAL



$0



$167,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.


The total capital/startup costs for this ICR are $0. This is the total of column D in the above table.


The total operation and maintenance (O&M) costs for this ICR are $167,000. 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 $167,000. These are 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 $302,000 (rounded).


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


Managerial $65.71 (GS-13, Step 5, $41.07 + 60%)

Technical $48.75 (GS-12, Step 1, $30.47 + 60%)

Clerical $26.38 (GS-6, Step 3, $16.49 + 60%)


These rates are from the Office of Personnel Management (OPM), 2018 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – 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, on average over the next three years, approximately 206,845 existing respondents will be subject to these standards initially. It is estimated that an additional 40 respondents per year will become subject to these same standards; therefore, the overall average number of respondents, as shown in the table below, is 206,885 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

40

235

206,570

0

206,845

2

40

235

206,610

0

206,885

3

40

235

206,650

0

206,925

Average

40

235

206,610

0

206,885

1 New respondents 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 206,885.


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

Certification for stationary use

35

1

0

35

Certification for stationary/non-road use

200

1

0

200

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

Annual report for emergency stationary CI ICE >100 hp that operates >15 hours/yr

10,344

1

0

10,344




Total

10,619


The number of Total Annual Responses is 10,619.


The total annual labor costs are estimated at $46,700,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Source Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (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 below in Tables 1 and 2, respectively, and summarized below.


(i) Respondent Tally


The total annual labor hours are estimated at 408,000 hours. Details regarding these estimates may be found below in Table 1. Annual Respondent Burden and Cost – NSPS for Stationary Source Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal).


We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.


Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 38 hours per response.


The total annual capital/startup and O&M costs to the regulated entity are $167,000. 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 403 labor hours at a cost of $302,000; see below in Table 2: Average Annual EPA Burden and Cost – NSPS for Stationary Source Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal).


We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.


6(f) Reasons for Change in Burden


There is no significant increase in the burden hours in this ICR compared to the previous ICR. This because the regulations have not changed significantly over the past three years and are not anticipated to change over the next three years. The number of respondents was updated to reflect new respondents since the approval of the prior ICR. There was no change in the capital or O&M costs. There is a small increase in the number of responses based on the adjustments to the number of respondents. There is also an increase in the Agency burden due to a correction to the prior ICR to include hours for review of the annual report submitted by owners and operators of emergency stationary CI ICE, which are submitted by approximately 5% of respondents.


6(g) Burden Statement


The annual public reporting and recordkeeping burden for this collection of information is estimated to average 38 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.


An agency may neither conduct nor 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-2011-0264. 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-2011-0264and 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)

(B)

(C)

(D)

(E)

(F)

(G)

(H)


Person hours per occurrence

No. of occurrences per respondent per year

Person hours per respondent per year
(C=AxB)

Respondents per year a

Technical person- hours per year
(E=CxD)

Management person hours per year
(Ex0.05)

Clerical person hours per year
(Ex0.1)

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

$201,727.68


- Recordkeeping

4.4

1

4.4

154

678

33.88

67.76

$88,760.18


- Certificate/durability testing d

168

1

168

35

5,880

294

588

$770,232.96


- Selective enforcement audits

115

1

115

1

115

5.75

11.5

$15,064.08


- Defect reporting e

125

1

125

4

500

25

50

$65,496.00


B. Certification for stationary/non-road use

1

1

1

200

200

10

20

$26,198.40


2. Surveys and studies

N/A

 

 

 

 

 

 

 


3. Reporting requirements

 

 

 

 

 

 

 

 


A. Familiarization with rule requirementsf

1

1

1

56,272

56,272

2813.6

5627.2

$7,371,181.82


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

3.2

6.4

$8,383.49


>10 l/cyl, prime h

2

1

2

8

16

0.8

1.6

$2,095.87


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

N/A

 

 

 

 

 

 

 


E. Annual report for emergency stationary CI ICEi

16

1

16

10,344

165,508

8,275.4

16,550.8

$21,680,223.94


F. Report for AECD use j

1

0

0

0

0

0

0

$0


Subtotal for Reporting Requirements

 

 

 

 

265,388

$30,229,364


4. Recordkeeping requirements

 

 

 

 

 

 

 

 


A. Familiarization with rule requirements

See 3A

 

 

 

 

 

 

 


B. Train personnel

N/A

 

 

 

 

 

 

 


C. Recording CDPF corrective actionk

1

1

1

20,689

20,689

1,034.43

2,068.9

$2,710,027.99


D. Recording hours in non-emergency operation l

0.5

1

0.5

206,885

103,443

5172.125

10344.25

$13,550,139.96


Subtotal for Recordkeeping Requirements

 

 

 

 

143,000

$16,300,000


TOTAL LABOR BURDEN AND COST (rounded)m

 

 

 

 

408,000

$46,500,000


TOTAL CAPITAL/O&M COST (rounded) m

 

 

 

 

 

 

 

$167,000


GRAND TOTAL (rounded)m

 

 

 

 

 

 

 

$46,700,000

Assumptions:


a We have assumed that there are 206,885 sources currently subject to the regulations, and it is estimated that 40 new sources are expected each year over the next three years. These entities are owned and operated by private industry, state, local, and tribal governments. For the purposes of estimating burden, we have assumed all entities are privately owned.


b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018 “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 on average 56,272 of the 206,885 respondents will read rule instructions each year.


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 16 hours per annual report based on ICR 1975.06 (NESHAP For Stationary Reciprocating Internal Combustion Engines 40 CFR Part 63, Subpart ZZZZ) and that 5% of respondents must submit an annual report.


j Reporting that would occur if the AECD is activated during a qualified emergency situation. Assumes that no AECDs will ever need to be activated.


k We have assumed that it will take 10% of respondents 1 hour to keep records of corrective actions taken for CI ICE equipped with diesel particulate filters.


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


m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



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


Activity

(A)

(B)

(C)

(D)

(E)

(F)

(G)

(H)

EPA person- hours per occurrence

No. of occurrences per plant per year

EPA person- hours per plant per year

Plants per year a

Technical person- hours per year

Management person-hours per year

Clerical person-hours per year

Cost, $ b

 

 

(C=AxB)

 

(E=CxD)

(Ex0.05)

(Ex0.1)

 

 

 

 

 

 

 

 

 

Report Review

 

 

 

 

 

 

 

 

1. Initial notification of compliance c

2

1

2

40

80

4

8

$4,373.88

2. Certification application

 

 

 

 

 

 

 

 

A. Certification for stationary use d

2

1

2

35

70

3.5

7

$3,827.15

B. Certification for stationary/non-road use e

1

1

1

200

200

10

20

$10,934.70

C. Annual report for emergency stationary CI ICEf

0.5

1

0.5

10,344

5,172

259

517

$282,778.18

TOTAL ANNUAL BURDEN AND COST (rounded)g

 

 

 

 

403

$302,000

Assumptions:










a We have assumed that there are 206,885 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: $65.71 for Managerial (GS-13, Step 5, $41.07 + 60%), $48.75 for Technical (GS-12, Step 1, $30.47 + 60%) and $26.38 Clerical (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay. These rates have been increased by 60 percent to account for the benefit packages available to government employees.


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





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





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




f We have assumed that 5% of respondents must submit an annual report.







g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








1 The only new information collection activity in the July 2016 amendments is the reporting by engine owners and operators and engine manufacturers that would occur if the AECD is activated during a qualified emergency situation. However, the EPA expects that it is unlikely that these AECDs will ever need to be activated, therefore, there is no burden associated with these reports.

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