Burden Calculation Tables

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Overview

Table 1
Table 2
Number of respondents

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Source 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	$209,483.89
- Recordkeeping	4.4	1	4.4	35	154	7.7	15.4	$20,948.39
- Certificate/durability testing d	168	1	168	35	5,880	294	588	$799,847.58
- Selective enforcement audits	115	1	115	1	115	5.75	11.5	$15,643.28
- Defect reporting e	125	1	125	4	500	25	50	$68,014.25
B. Certification for stationary/non-road use	1	1	1	200	200	10	20	$27,205.70
2. Surveys and studies	N/A
3. Reporting requirements
A. Read and understand rule requirementf	1	1	1	40	40	2	4	$5,441.14
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	$8,705.82
>10 l/cyl, prime h	2	1	2	8	16	0.8	1.6	$2,176.46
Pre-2007, not certified, prime, >175 hp	N/A
E. Annual report for emergency stationary CI ICEi	16	1	16	10,362	165,792	8,289.6	16,579.2	$22,552,437.07
Subtotal for Reporting Requirements					200,446			$23,709,904
4. Recordkeeping requirements
A. Read and understand rule requirement j	1	1	1	55,955	55,955	2,797.7	5,595.5	$7,611,447.51
B. Train personnel	N/A
C. Recording CDPF corrective actionk	1	1	1	20,724	20,724	1,036.20	2,072.4	$2,819,054.63
D. Recording hours in non-emergency operation l	0.5	1	0.5	207,240	103,620	5181	10362	$14,095,273.17
Subtotal for Recordkeeping Requirements					207,344			$24,525,775
TOTAL LABOR BURDEN AND COST (rounded)m					408,000			$48,200,000
Total Capital/O&M Costsm								$242,000		38
Grand Total (Labor and Capital/O&M Costs)m								$48,400,000		hr/response
Assumptions:
a We have assumed that there are 207,240 sources currently subject to the regulations. EPA estimates that approximately 160 stationary CI engines greater than 3,000 HP are sold each year, and that 20 percent of these engines are used for non-emergency purposes. This means that there are an estimated 32 new non-emergency engines greater than 3,000 HP sold each year that would have to submit an initial notification. EPA also estimates that 8 engines with a displacement of 10 liters per cylinder or more are sold in the U.S. each year. Therefore it is estimated that 40 new sources are expected each year over the next three years.
b This ICR uses the following labor rates: $153.55 per hour for Executive, Administrative, and Managerial labor; $122.20 per hour for Technical labor, and $61.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 “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 that approximately 35 engine families per year will be required to be certified to the emission standards of the rule by manufacturers. We have assumed that it will take 44 hours for all affected facilities to complete the certification application. EPA also estimates that approximately 200 engine families currently certified for nonroad use will be required to be certified to the stationary CI rule and would have minimal burden.
d We assume that approximately 35 engine families per year will be required to be certified to the emission standards of the rule. We have assumed that it will take 168 hours for all affected facilities to complete the certificate/durability testing.
e We assume 10% of new respondents will have to conduct defect-reporting. We have assumed that it will take 125 hours for all affected facilities to complete the defect report.
f We have assumed that each of the 40 respondents will take one hour to read instructions.
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 Applies to 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 for the purposes specified in § 60.4211(f)(2)(ii) and (iii) or that operates for the purposes specified in § 60.4211(f)(3)(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 We have assumed that on average 27% (or 55,955) of the 207,240 respondents will read rule instructions each year.
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.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Stationary Source 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	$4,596.40
2. Certification application
A. Certification for stationary use d	2	1	2	35	70	3.5	7	$4,021.85
B. Certification for stationary/non-road use e	1	1	1	200	200	10	20	$11,491.00
TOTAL ANNUAL BURDEN AND COST (rounded)f					403			$20,100
Assumptions:
a We have assumed that there are 207,240 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: $69.04 for Managerial (GS-13, Step 5, $43.15 + 60%), $51.23 for Technical (GS-12, Step 1, $32.02 + 60%) and $27.73 Clerical (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM) “2014 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 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Number of respondents

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	40	235	206,925	0	207,200
2	40	235	206,965	0	207,240
3	40	235	207,005	0	207,280
Average	40	235	206,965	0	207,240