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

OMB: 2060-0610

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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 2227.07, OMB Control Number 2060-0610.


1(b) Short Characterization/Abstract


The New Source Performance Standards (NSPS) for Stationary Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) were promulgated on January 18, 2008, and most-recently amended on August 10, 2022. These regulations apply to existing and new manufacturers, owners, and operators of stationary spark ignition (SI) internal combustion engines (ICE) that commenced construction, modification, or reconstruction either on or after the dates specified at 40 CFR 60.4230(a)(1)-(6). New facilities include those that commenced construction, modification, or reconstruction after the date of proposal. 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 required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where either the delegated state or local authority can review them. If there is no such delegated authority, the EPA’s regional offices can review them. All other reports are sent to either the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the EPA’s regional offices. The use of the term "Designated Administrator" throughout this document refers to the U.S. EPA or a delegated authority, such as a state agency. The term "Administrator" alone refers to the U.S. EPA Administrator. 


The “Affected Public” is composed of manufacturers, owners, and operators of stationary spark ignition internal combustion engines.


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 “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 Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ) (Renewal). There are approximately 19,835 existing facilities. None of the facilities in the United States are owned by either state, or local, or tribal entities or by the Federal government. They are all owned and operated by privately-owned, for-profit businesses. 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 19,835 existing respondents per year will be subject to these standards, and 253 additional respondents per year will become subject to these same standard for an overall average of 20,088 respondents per year.


The Office of Management and Budget (OMB) approved the currently active ICR with the following Terms of Clearance (TOC):


OMB requests that EPA reformat the Supporting Statement A to the standard 18 question format. In addition, OMB requests that EPA cut and paste the regulatory text that includes the ICR requirements, including the instructions in the regulatory text for how to submit any recording and recordkeeping requirements, into a supplementary document that is also uploaded upon renewal of this ICR.”


At the time of this renewal, the standard 18-question format template is not yet available. The Agency will update this ICR to the standard 18-question format once the template is available and upon the next renewal cycle. The relevant regulatory text for these activities is referenced in section 4(b) of this document. We have created a supplementary document, including the regulatory text that describes the ICR requirements as identified in section 4(b)(i) of this document as requested.


All electronic collection in this information collection is submitted through EPA's CEDRI, as discussed in section 4(b)(i) of this document. Additional Paperwork Reduction Act requirements for CEDRI, including the burden statement and OMB control number, are available at: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.


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, nitrogen oxides (NOx), carbon monoxide (CO), hydrocarbon (HC), non-methane hydrocarbon (NMHC), and volatile organic compound (VOC) emissions from stationary spark ignition internal combustion engines 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 JJJJ.


2(b) Practical Utility/Users of the Data


The recordkeeping and reporting requirements in these 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 these emission standards. Continuous emission monitors are used to ensure compliance with these same 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 its delegated authority when a source becomes subject to the requirements of these 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 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.


Additionally, the EPA is requiring electronic reporting for certain notifications or reports. The EPA is requiring that owners or operators of affected sources would submit electronic copies of annual reports through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI). For annual reports, EPA has developed a template for the reporting form in CEDRI specifically for 40 CFR Part 60, Subpart JJJJ.


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


For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as for state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication. 


For all other reports, 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 standards to implement the Federal standards, a copy of the report submitted to either 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 (87 FR 43843) on July 22, 2022. 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 these 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 20,088 respondents will be subject to these standards over the three-year period covered by this ICR.


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 previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both Cummins Incorporated, at (800) 286-6467, and the Engine Manufacturer's Association, at (312) 929-1970.


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 (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978. The respondents to the recordkeeping and reporting requirements are manufacturers, owners, and operators of stationary spark ignition internal combustion engines. The United States Standard Industrial Classification (SIC) codes for the respondents affected by these 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

General Medical and Surgical Hospitals

8062, 8069

62211

Motor and Generator Manufacturing

3621, 7694

335312

Pump and Compressor Manufacturing

3561, 3563, 3586, 3743

33391

Welding and Soldering Equipment Manufacturing

3548, 3699

333992

Pipeline Transportation of Natural Gas

4922, 4923

48621

Crude Petroleum Extraction

1311

211120

Natural Gas Liquid Extraction

1321

211130

National Security

9711

92811

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 Spark Ignition Internal Combustion Engines (40 CFR Part 60, Subpart JJJJ).


A source must make the following reports:



Notifications

Initial notification requirements for owners/operators of non-emergency non-certified stationary spark ignition internal combustion engines 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 spark ignition internal combustion engines with a maximum horsepower greater than 500 HP, a copy of their performance test that demonstrates compliance as conducted in §60.4244.

§60.4245(d)



Reports

Annual report for owners/operators of emergency stationary spark ignition internal combustion engines 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 or that operates for purposes specified in §60.4243(d)(3)(i).

§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 horsepower greater than or equal to 500 HP.

§60.4245(a)(1), §60.4245(c)

Maintain records of all maintenance conducted on any stationary spark ignition internal combustion engines.

§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 or certified engine operating in non-certified manner and subject to §60.4243(a)(2) to demonstrate compliance.

§60.4245(a)(4)

Maintain records of the hours of operation for emergency stationary spark ignition internal combustion engines documenting how many hours are spent for emergency operation, including what classified the operation as emergency, and how many hours are spent for non-emergency operation.

§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.


The rule was amended to include electronic reporting provisions on January 30, 2013. Respondents are required to submit electronic copies of annual reports through EPA’s CEDRI. The submittal is an upload of their currently required report in an Excel (xlsx) or XML schema (XSD) file. The annual reports are to be created using Form 5900-596, the electronic template included with this Supporting Statement. The template is an Excel spreadsheet which can be partially completed and saved for subsequent annual reports to limit some of the repetitive data entry. It reflects the reporting elements required by the rule and does not impose additional reporting elements. The OMB Control Number is displayed on the Welcome page of the template, with a link to an online repository that contains the PRA requirements. For purposes of this ICR, it is assumed that there is no additional burden associated with the proposed requirement for respondents to submit the notifications and reports electronically.


Electronic copies of records may also be maintained in order to satisfy federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.


(ii) Respondent Activities


Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate a non-resettable hourly meter.

Perform initial performance test, Reference Method 1 or 1A, 2 or 2C, 3, 3A, or 3B, 4, 7E, 10, 18, 19, 25A, 320, ASTM Method D6522-00, or ASTM Method D6348-03 test, 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


The 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 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 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 both state and local governments in the ICIS Air database, which is operated and maintained by EPA’s Office of Compliance. The EPA uses ICIS for tracking air pollution compliance and enforcement by both local and state regulatory agencies, EPA’s regional offices and EPA headquarters. The 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.


5I 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 these 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.


During development of this 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 4,760 small entities impacted by this ICR.


5(d) Collection Schedule


The specific frequency for each information collection activity within this request is shown at the end of this document in 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. 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 recordkeeping and reporting requirements is estimated to be 38,000 (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of these regulations, 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 $157.61 ($75.05 + 110%)

Technical $123.94 ($59.02 + 110%)

Clerical $62.52 ($29.77 + 110%)


These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.


(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 these regulations. The annual operation and maintenance costs are the ongoing costs to maintain the monitors 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)

(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, (E x F)

Engine Certification for Stationary Use b

 

 

 

 

 

 

- 25-300 hp

 

 

 

$16.69

91

$1,519.01

- 300-600 hp

 

 

 

$41.10

9

$369.91

- >600 hp

 

 

 

$196

14

$2,739.33

Initial Test for Engines not Certified

$1,000

253

$253,000

$0

0

$0

Subsequent Performance Test for Engines > 500 hp c

 

 

 

$1,120

2,380

$2,665,419.29

Total (rounded) d

 

 

$253,000

 

 

$2,670,000


a O&M cost per occurrence for certifications for stationary was increased by 10.5459 percent from previous ICR# 2227.05 to account for the increase in the average annual consumer price index (https://www.bls.gov/cpi/#data) from 2017 to 2021. 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 2,380 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.


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 $2,670,000. This is the total of column G in the above table.


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 $2,920,000. 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. The EPA's overall compliance and enforcement program includes such activities 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 $316,000.


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


Managerial $70.56 (GS-13, Step 5, $44.10 + 60%)

Technical $52.37 (GS-12, Step 1, $32.73 + 60%)

Clerical $28.34 (GS-6, Step 3, $17.71 + 60%)


These rates are from the Office of Personnel Management (OPM), 2022 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 at the end of this document 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 19,835 existing respondents will be subject to these standards. It is estimated that an additional 253 new respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 20,088 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

19,582

0

0

19,835

2

253

19,835

0

0

20,088

3

253

20,088

0

0

20,341

Average

253

19,835

0

0

20,088

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 20,088.


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) a

30

1

n/a

30

Record Engine Maintenance

20,088

1

n/a

20,088

Recording hours in non-emergency operation b

509

1

n/a

509

Annual Report for emergency stationary SI ICE b

25

1

n/a

25

Total (rounded) c

 

 

 

20,700

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

b I n 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 509 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. (509 x 0.05 = 25 (rounded)).

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


The number of Total Annual Responses is 20,700.


The total annual labor costs are $4,620,000. Details regarding these estimates may be found at the end of this document 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 at the end of this document, respectively, and summarized below.


(i) Respondent Tally


The total annual labor hours are 38,000 hours. 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).


We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to both 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 2 hours per response.


The total annual capital/startup and O&M costs to the regulated entity are $2,920,000. 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 6,130 labor hours at a cost of $316,000; see 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).


We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to both 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 an increase in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes or changes in regulatory requirements. The change in the burden and cost estimates is due primarily to an increase in the number of existing sources subject to rule requirements. This increase is based on the growth rate from the prior ICR and assumes continued growth in the manufacture and use of SI ICE. This has led to an increase in O&M costs, as well as in recordkeeping and reporting costs.


There is also a slight increase in costs, which is wholly due to the use of updated labor rates. This ICR uses labor rates from the most recent Bureau of Labor Statistics report (September 2021) to calculate respondent burden costs.


6(g) Burden Statement


The annual public reporting and recordkeeping burden for this collection of information is estimated to average 2 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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-OAR-2022-0038. 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. Due to COVID-19 precautions, entry to the Reading Room is available by appointment only. Please contact personnel in the Reading Room to schedule an appointment. 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-OAR- EPA-HQ-OAR-2022-0038 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
(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

20,088

10,044

502

1004

$1,386,800.19

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

$4,142.18

Subsequent Performance Test (>500 hp certified engines) e

1

1

1

2,380

2,380

119

238

$328,640.16

Annual report for emergency stationary SI ICE f

16

1

16

25

400

20

40

$55,229.00

Subtotal for Reporting Requirements

 

 

 

 

14,322

$1,774,812

4. Recordkeeping Requirements

 

 

 

 

 

 

 

 

A. Record Engine Maintenance

1

1

1

20,088

20,088

1004

2,009

$2,773,600.38

B. Train personnel

N/A

 

 

 

 

 

 

 

C. Recording hours in non-emergency operation f

1

1

1

509

509

25

51

$70,265.10

D. Records of initial notification, manufacturer's certifications, and performance tests

See 3D

 

 

 

 

 

 

 

Subtotal for Recordkeeping Requirements

 

 

 

 

23,686

$2,843,865

TOTAL LABOR BURDEN AND COST (rounded) g

 

 

 

 

38,000

$4,620,000

TOTAL CAPITAL AND O&M COST (rounded) g

 

 

 

 

 

 

 

$2,920,000

GRAND TOTAL (rounded) g

 

 

 

 

 

 

 

$7,540,000










Assumptions:









a We assume there are an average of 19,835 existing respondents and an additional 253 respondents will become subject to the rule each year.

b This ICR uses the following labor rates: Managerial $157.61, Technical $123.94, and Clerical $62.52. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.

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.

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 509 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. (509 x 0.05 = 25 (rounded))

g 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 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

 

 

 

 

 

 

 

 

1. Initial notification (>500 hp non-certified engines) c

2

1

2

30

60

3

6

$3,523.92

2. Engine Certification for Non-certified Engine c

2

1

2

253

506

25.3

50.6

$29,718.39

3. Engine Certification from nonroad to stationary

1

1

1

0

0

0

0

$0

4. Performance Tests c

2

1

2

2,380

4,760

238.02

476.04

$279,587.81

5. Annual reports for emergency stationary SI ICE d

2

1

2

25

50

2.5

5

$2,936.60

TOTAL (rounded) e

 

 

 

 

6,130

$316,000










Assumptions:









a We assume there are an average of 19,835 existing respondents per year and an additional 253 respondents will become subject to the rule each year.

b This cost is based on the average hourly labor rate as follows: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.71 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2022 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 509 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. (509 x 0.05 = 25 (rounded))

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


Appendix A – Draft Electronic Reporting Template

(see Docket ID Number EPA-HQ-OAR-2022-0038)


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