18Q Supporting Statement Instructions_draft

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U.S. Environmental Protection Agency
Information Collection Request

Title: NSPS for Greenhouse Gas Emissions for New Electric Utility Generating Units (40 CFR Part 60, Subpart TTTT) (Renewal)
OMB Control Number: 2060-0685
EPA ICR Number: 2465.07
Abstract: The New Source Performance Standards (NSPS) for Greenhouse Gas (GHG) Emissions for New Electric Utility Generating Units (EGUs) (40 CFR Part 60, Subpart TTTT) were proposed on June 2, 2014, and promulgated on October 23, 2015. Amendments to 40 CFR Part 60, Subpart TTTT were proposed on December 6, 2018, but EPA did not finalize amendments to the 2015 final rule. On January 13, 2021, EPA finalized a pollutant-specific significant contribution finding for this source category, which was vacated and remanded on April 5, 2021. The rule was most recently amended on May 4, 2024. These regulations apply to newly constructed, modified or reconstructed facilities with electric utility generating units (EGUs) including any steam generating unit, IGCC, or stationary combustion turbine that either commenced construction or modification after January 8, 2014 or commenced reconstruction after June 18, 2014, but on or before May 23, 2023. To be considered an EGU, the unit must be: (1) capable of combusting more than 250 MMBtu/h heat input of fossil fuel; and (2) serve a generator capable of supplying more than 25 MW net to a utility distribution system (i.e., for sale to the grid). This information is being collected to assure compliance with 40 CFR Part 60, Subpart TTTT. Units that commence construction, reconstruction, or modification after May 23, 2023 will be subject to 40 CFR Part 60, Subpart TTTTa.
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.
The active (previous) ICR had the following Terms of Clearance (TOC): 
“In accordance with 5 CFR 1320, the information collection is approved for three years. As terms of clearance, however, the Agency is asked to ensure that clear and complete instructions exist for the forms included in this collection as part of its renewal request.”
Respondents are required to submit electronic copies of quarterly reports, required in 40 CFR 60.5555, using the Emissions Collection and Monitoring Plan System (ECMPS) Client Tool provided by the Clean Air Markets Division in the Office of Atmospheric Programs of EPA. The ECMPS is a desktop software tool that sources must use to submit quarterly emissions summary reports to EPA to comply with 40 CFR Part 60, Subpart TTTT. Using the ECMPS, the emissions summary reports are submitted to the EPA in extensible-markup language (XML) format. The tool and instructions are available at: https://www.epa.gov/power-sector/reporting-data-using-ecmps. The supplemental files to this ICR renewal contain screenshots showing the ECMPS login screen, the ECMPS interface for reporting emissions data, and the ECMPS reporting instructions for 40 CFR Part 60, Subpart TTTT.
Supporting Statement A
    1. NEED AND AUTHORITY FOR THE COLLECTION
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate 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, CO₂ emissions from electric utility generating units either cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart TTTT. 
    2. PRACTICAL UTILITY/USERS OF THE DATA
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
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.
The rule requires continuous emission monitors to measure CO2 concentration, stack gas flow rate, and stack gas moisture content in accordance with 40 CFR Part 75 in order to determine hourly CO2 mass emissions rates. The rule allows owners or operators of EGUs that burn exclusively gaseous or liquid fuels to install fuel flow meters and monitor fuel flow rate, the gross calorific value (GCV) of the fuel, unit operating time, and gross output in place of a continuous emissions monitor. The initial performance compliance demonstration consists of calculating the CO2 mass emissions rate using the first 12 operating months of data (hourly CO2 average concentration, mass flow rate, and electrical power generation) on a rolling average basis. 
The notifications required in these standards are used to inform the Agency or 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/monitoring devices are properly installed and operated, and that the standards are being met. 
The required quarterly reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures, and for compliance determinations.
    3. USE OF TECHNOLOGY
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
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.
Respondents are required to use the EPA’s ECMPS Client Tool to develop quarterly emissions summary reports that include excess emissions and continuous monitoring systems performance data and submit them through the EPA’s ECMPS, which can be accessed on the EPA’s ECMPS Support website (https://ecmps.camdsupport.com/downloads.shtml). Using the ECMPS, the emissions summary reports are submitted to the EPA in extensible-markup language (XML) format. The ECMPS Client Tool is an application, rather than a form, and the requirement to use the ECMPS is applicable to numerous regulations (Acid Rain Program, Cross-State Air Pollution Rule, Greenhouse Gas Reporting Program, Mercury Air Toxics Standards “MATS” etc.). For purposes of this ICR, it is assumed that there is no additional burden associated with the requirement for respondents to submit the notifications and reports electronically. The supplemental files to this ICR renewal contain screenshots showing the ECMPS login screen, the ECMPS interface for reporting emissions data, and the ECMPS reporting instructions for 40 CFR Part 60, Subpart TTTT.
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.
    4. EFFORTS TO IDENTIFY DUPLICATION
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
For reports required to be submitted electronically, the information is sent through the EPA's ECMPS, 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 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. 
    5. MINIMIZING BURDEN ON SMALL BUSINESSES AND SMALL ENTITIES
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
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.
    6. CONSEQUENCES OF LESS FREQUENT COLLECTION
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the 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.
    7. GENERAL GUIDELINES
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.
    8. PUBLIC COMMENT AND CONSULTATIONS
8a. Public Comment
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.
An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (89 FR 63933) on August 6, 2024. No comments were received on the burden published in the Federal Register for this renewal.
8b. Consultations
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
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 56 respondents will be subject to the standard 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 the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Environmental Council of the States (ECOS) at 202-266-4920, and the Electric Power Research Institute (EPRI) at 650-855-2121. In this case, no comments were received.
It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.
    9. PAYMENTS OR GIFTS TO RESPONDENTS
Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
No payments or gifts are made to respondents.
    10. ASSURANCE OF CONFIDENTIALITY
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
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; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).
    11. JUSTIFICATION FOR SENSITIVE QUESTIONS
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
The reporting or recordkeeping requirements in the standard do not include sensitive questions.
    12. RESPONDENT BURDEN HOURS & LABOR COSTS
Provide estimates of the hour burden of the collection of information. The statement should:
    • Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.
    • If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.
    • Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.
12a. Respondents/NAICS Codes
The respondents to the recordkeeping and reporting requirements are fossil fuel-fired electric utility steam generating units. The United States Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) codes for the respondents affected by the standards are listed in the table below: 


Standard (40 CFR Part 60, Subpart TTTT)

SIC Codes

NAICS Codes
Fossil Fuel Electric Power Generation
4931, 4939, 4911
221112
Electric Power Generation, Transmission and Distribution
4931, 4939, 4911
2211
Fossil fuel electric power generating units in American Indian and Alaska Native lands	
8641
921150

Based on our research for this ICR, on average over the next three years, approximately 56 existing respondents will be subject to the standard. It is estimated that no additional respondents per year will become subject, for an overall total of 56 respondents per year. The number of respondents is calculated using the table Number of Respondents that addresses the three years covered by this ICR. None of the facilities in the United States are owned by either state, 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).
The total number of annual responses per year is calculated using the table Total Annual Responses shown below. The number of Total Annual Responses is 224.
12b. Information Requested
In this ICR, all the data that are recorded or reported is required by the NSPS for Greenhouse Gas Emissions for New Electric Utility Generating Units (40 CFR Part 60, Subpart TTTT). Any owner/operator subject to the provisions of this part shall maintain a file of these measurements and retain the file for at least three years following the date of such measurements, maintenance reports, and records.
A source must make the following reports:

Notifications
Notification of construction
§60.7(a)(1), §60.5550(a) 
Notification of startup
§60.7(a)(3), §60.5550(a)


Reports
Electronic quarterly compliance reports (includes excess emissions and downtime)
§§60.5555(a), (b)

A source must keep the following records:

Recordkeeping
Records of hourly and total CO2 mass emissions calculations
§§60.5560(c)-(g)
Records of malfunctions or downtime
§§60.7(b), 
§60.5560(a)
Records of performance evaluations
§§60.7(f), 
§60.5560(a)
Records of electric sales for combustion turbines to determine applicable subcategory
§60.5560(h)
Records to demonstrate affected facility operated during a system emergency
§60.5560(i)

12c. Respondent Activities

Respondent Activities
Familiarization with the regulatory requirements.
Install, calibrate, maintain, and operate CEMS for CO2 or monitors for fuel flow rate, and unit operating time of the EGU.
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.

12d. Respondent Burden Hours and Labor Costs
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 average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 1,550 hours (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 NESHAP program, the previously approved ICR, and any comments received.
This ICR uses the following labor rates:
Managerial	$172.41 ($82.10 + 110%) 
Technical	$141.75 ($67.50 + 110%)
Clerical		$71.36 ($33.98 + 110%)
These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are 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.
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.

    13. Respondent CAPITAL AND O&m CostS 
Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. 

Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.
    14. AGENCY COSTS
Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
14a. Agency Activities
The EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:
•	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.
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 semiannual 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. 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.
14b. Agency Labor Cost
The ‘burden’ to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors. 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 burden and cost during the three years of the ICR is estimated to be 1,030 hours at a cost of $57,300. See Table 2: Average Annual EPA Burden and Cost – NSPS for Greenhouse Gas Emissions for New Electric Utility Generating Units (40 CFR Part 60, Subpart TTTT) (Renewal).
This cost is based on the average hourly labor rate as follows:
		Managerial	$76.91 (GS-13, Step 5, $48.07 + 60%)
		Technical	$57.07 (GS-12, Step 1, $35.67 + 60%)
		Clerical		$30.88 (GS-6, Step 3, $19.30+ 60%)
These rates are from the Office of Personnel Management (OPM), 2024 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. 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 Greenhouse Gas Emissions for New Electric Utility Generating Units (40 CFR Part 60, Subpart TTTT) (Renewal).
14c. Agency Non-Labor Costs
There are no non-labor costs to the Agency associated with this information collection.
    15) REASONS FOR CHANGE IN BURDEN
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.
There is an adjustment decrease in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. The adjustment decrease is due in part to a decrease in the number of existing respondents based on EPA’s ECHO database. Additionally, sources that commence construction, modification, or reconstruction after May 23, 2023 will be subject to 40 CFR Part 60, Subpart TTTTa. Therefore, we do not expect any new sources will become subject to 40 CFR Part 60, Subpart TTTT during the next three years. The labor cost also decreased based on the decrease in the number of respondents. This decrease was offset slightly by the use of updated labor rates. This ICR uses labor rates from the most recent Bureau of Labor Statistics report (December 2023) to calculate respondent burden costs.
    16) PUBLICATION OF DATA
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
Data from sources regarding emissions, allowances, compliance, and facility information will be published on the Clean Air Markets Program Data (CAMPD) site available at https://campd.epa.gov/. Quarterly emissions data submitted via ECMPS is published automatically to CAMPD on a quarterly basis.
    17) DISPLAY OF EXPIRATION DATE
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
 EPA will display the expiration date for OMB approval of the information collection.

    18) CERTIFICATION STATEMENT
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
There are no exceptions to the topics of the certification statement.

Table 1: Annual Respondent Burden and Cost – NSPS for Greenhouse Gas Emissions for New Electric Utility Generating Units (40 CFR Part 60, Subpart TTTT) (Renewal)
 
(A)
Hours per Occurrence
 (B) Occurrences/ Respondent/ Year
(C)
Hours/ Respondent/
Year 
(D) Respondents/ Yeara
(E) Technical Hours/Year
(F)
Managerial Hours/Year
(G)
Clerical Hours/Year
(H)
Cost/ Yearc

 
 
(A x B)
 
(C x D)
(E x .05)
(E x .10) 
 
1. Applications
 
 
 
 
 
 
 
 
2. Survey and studies
 
 
 
 
 
 
 
 
3. Acquisition, installation, and utilization of technical systems
 
 
 
 
 
 
 
 
4. Reporting Requirements
 
 
 
 
 
 
 
 
A. Familiarization with regulatory requirements b
 
 
 
 
 
 
 
 
 Existing Facilities
8
1
8
56
448
22
45
$70,562.91
 New Facilities
30
1
30
0
0
0
0
$0.00
B. Required activities
 
 
 
 
 
 
 
 
 Notification of construction
2
1
2
0
0
0
0
$0.00
 Notification of startup
2
1
2
0
0
0
0
$0.00
C. Create information
See 4E
 
 
 
 
 
 
 
D. Gather existing information
See 4E
 
 
 

 
 
 
E. Prepare/Submit Emissions Summary Report
Includes reporting of excess emissions & downtime
4
4
16
56
896
45
90
$141,125.82
Reporting Subtotal
 
 
 
 
1,546
$211,689
5. Recordkeeping requirements
See 4A-E
 
 


 
 
 
Recordkeeping Subtotal d

 
 
 
0
$0
TOTAL LABOR BURDEN AND COST (rounded)e


 
 
1,550
$212,000
TOTAL CAPITAL AND O&M COSTS (rounded)e
 
 
 
 
 
 
 
$0
GRAND TOTAL (rounded)e
 
 
 
 
 
 
 
$212,000









Assumptions








a We have assumed there are approximately 56 existing sources and no new sources per year anticipated over the next 3 years, resulting in overall average of 56 respondents per year.
b Assumes one-time burden of 30 hours for new sources to read and understand rule requirements. Assumes existing respondents will spend 8 hours to refamiliarize with the regulatory requirements each year.

c This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
d All recordkeeping burden is accounted for in the listed reporting activities.
e 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 Greenhouse Gas Emissions for New Electric Utility Generating Units (40 CFR Part 60, Subpart TTTT) (Renewal)
Burden Item
(A)
Hours per Occurrence
(B) Occurrences/ Respondent/ 
(C)
Hours/ Respondent/ Year 
(D) Respondents/ Yeara
(F) Technical Hours/ Year
(G)
Managerial Hours/ Year
(H) Clerical Hours/Year
(I)
Cost/ Yearb

 
Year
(A x B)
 
(C x D)
(E x .05)
(E x .10) 
 
Notification of construction
1
1
1
0
0
0
0
$0
Notification of startup
1
1
1
0
0
0
0
$0
Review Emissions Summary Report
Includes reporting of excess emissions & downtime
4
4
16
56
896
45
90
$57,347
GRAND TOTAL (rounded)c
 
 
 
 
1,030
$57,300
 








Assumptions








a We have assumed there are approximately 56 existing sources and no new sources per year anticipated over the next 3 years, resulting in overall average of 56 respondents per year.
b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 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), 2024 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c 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 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
0
56
0
0
56
2
0
56
0
0
56
3
0
56
0
0
56
Average
0
56
0
0
56
1 New respondents include sources with constructed, reconstructed and modified affected facilities. 


Total Annual Responses
(A)
(B)
(C)
(D)
(E)
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
Prepare/Submit Emissions Summary Report
56
4
0
224
Notification of construction
0
1
0
0
Notification of startup
0
1
0
0
 
 
 
Total
224