Burden Calculations

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Overview

Table 1
Table 2
Capital and O&M

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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)
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									Labor Rates
2. Surveys and Studies	N/A									Management	$141.06
3. Reporting Requirements										Technical	$120.27
A. Familiarize with regulatory requirements c	0.5	1	0.5	19,329	9,665	483	966	$1,287,214.76		Clerical	$58.67
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	$3,995.70
Subsequent Performance Test (>500 hp certified engines) e	1	1	1	2,289	2,289	114	229	$304,871.91
Annual report for emergency stationary SI ICE f	16	1	16	25	400	20	40	$53,276.00
Subtotal for Reporting Requirements					13,781			$1,649,358
4. Recordkeeping Requirements
A. Record Engine Maintenance	1	1	1	19,329	19,329	966	1,933	$2,574,429.51
B. Train personnel	N/A
C. Recording hours in non-emergency operation f	1	1	1	490	490	25	49	$65,263.10
D. Records of initial notification, manufacturer's certifications, and performance tests	See 3D
Subtotal for Recordkeeping Requirements					22,792			$2,639,693		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) g					36,600			$4,290,000		19,874	1.8
TOTAL CAPITAL AND O&M COST (rounded) g								$2,570,000
GRAND TOTAL (rounded) g								$6,860,000
Assumptions:
a We assume there are an average of 19,076 existing respondents per year and an additional 253 respondents will become subject to the rule each year. The overall average number of respondents is 19,329 per year.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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. (19,076 x 0.12 = 2,289)
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). In the 2007 Cost Impacts memo for this rule, EPA estimated that, based on information obtained from the Engine Manufacturers Association, emergency engines make up approximately 5 percent of the total SI population. EPA also assumed that only 50% of engines seek certification. Of the 253 new engines per year, approximately 2.5% (6.3) are non-certified and required to record hours in non-emergency operation. The number of non-certified emergency engines submitting reports has been incremented since the original ICR (421 respondents in year 1 of ICR #2227.02) to the number of 490 for year 2 of this ICR. We assume 5% of emergency stationary SI ICE will be required to report to conservatively estimate respondent burden for this activity. (490 x 0.05 = 25 (rounded))
g Totals have been rounded to 3 significant figures. Figures may not add 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)
Activity	(A) EPA person-hours per occurrence	(B) Number of occurrences 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										Labor Rates
1. Initial notification (>500 hp non-certified engines) c	2	1	2	30	60	3	6	$3,326.76		Management	$66.62
2. Engine Certification for Non-certified Engine c	2	1	2	253	506	25.3	50.6	$28,055.68		Technical	$49.44
3. Engine Certification from nonroad to stationary	1	1	1	0	0	0	0	$0		Clerical	$26.75
4. Performance Tests c	2	1	2	2,289	4,578	228.9	457.8	$253,831.79
5. Annual reports for emergency stationary SI ICE d	2	1	2	25	50	2.5	5	$2,772.30
TOTAL (rounded) e					5,920			$288,000
Assumptions:
a We assume there are an average of 19,076 existing respondents per year and an additional 253 respondents will become subject to the rule each year. The overall average number of respondents is 19,329 per year.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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). EPA estimates that emergency engines make up approximately 5 percent of the total SI population and that 50% of these emergency engines are non-certified and required to report hours in non-emergency operation. Of the 253 new engines per year, approximately 2.5% (6.3) are non-certified and required to record hours in non-emergency operation. The number of non-certified emergency engines submitting reports has been incremented since the original ICR (421 respondents in year 1 of ICR #2227.02) to the number of 490 for year 2 of this ICR. We assume 5% of emergency stationary SI ICE will be required to report to conservatively estimate respondent burden for this activity. (490 x 0.05 = 25 (rounded))
e Totals have been rounded to 3 significant figures. Figures may not add 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				$177	14	$2,482.59
Initial Test for Engines not Certified	$1,000	253	$253,000	$0	0	$0
Subsequent Performance Test for Engines > 500 hp c				$1,013	2,289	$2,319,565.30
Total (rounded) d			$253,000			$2,320,000		$2,573,000
a O&M cost per occurrence for certifications for stationary was increased by 1.33 percent from previous ICR# 2227.04 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 2,289 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.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
	Number of Respondents
		Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
		(A)	(B)	(C)	(D)	(E)
	Year	Number of New Respondents a	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	18,823	0	0	19,076
	2	253	19,076	0	0	19,329
	3	253	19,329	0	0	19,582
	Average	253	19,076	0	0	19,329
Total Annual Responses						ICR#	Year	Existing Respondents	Respondents w/ Emergency Engines
(A)	(B)	(C)	(D)	(E)		2227.02	2010	16,285	421
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D		2227.03	2011	16,546	427
Initial notification (>500 hp non-certified engines) a	30	1	n/a	30		2227.03	2012	16,799	433
Record Engine Maintenance	19,329	1	n/a	19,329		2227.03	2013	17,052	439
Recording hours in non-emergency operation b	490	1	n/a	490		2227.04	2014	17,305	446
Annual Report for emergency stationary SI ICE b	25	1	n/a	25		2227.04	2015	17,558	452
Total (rounded) c				19,874		2227.04	2016	17,811	458
a We assume 12% of the 253 new respondents, or 30 respondents, will have engines rated at >500 hp.						2227.05	2017	18,064	465
b In the 2007 Cost Impacts memo for this rule, EPA estimated that, based on information obtained from the Engine Manufacturers Association, emergency engines make up approximately 5 percent of the total SI population. EPA also assumed that only 50% of engines seek certification. Of the 253 new engines per year, approximately 2.5% (6.3) are non-certified and required to record hours in non-emergency operation. The number of non-certified emergency engines has been incremented since the original ICR (#2227.02) to the number of 490 for year 2 of this ICR. We assume 5% of emergency stationary SI ICE will be required to report to conservatively estimate respondent burden for this activity. (490 x 0.05 = 25 (rounded))						2227.05	2018	18,317	471
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.						2227.05	2019	18,570	477
						2227.06	2020	18,823	484
						2227.06	2021	19,076	490
						2227.06	2022	19,329	496