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 2227.06, 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 proposed on June 12, 2006; promulgated on January 18, 2008; and most-recently amended on February 27, 2014. 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 containing these documents and retain the file for at least two years following the generation date of such maintenance reports and records. All reports are sent to the delegated state or local authority. In the event that there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.
The “Affected Public” is composed of manufacturers, owners, and operators of stationary SI ICE. None of the respondents in the United States are owned by either state, local, tribal or the Federal government. They are all privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries. The ‘burden’ to the Affected Public 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). The Federal Government’s ‘burden’ is attributed entirely to work performed by either Federal employees or government contractors and may be found 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).
Over the next three years, approximately 19,076 existing respondents per year will be subject to these standards, and 253 additional new respondents per year will become subject to these same standards. This ICR reflects an increase in the number of existing respondents from the prior ICR based on continued growth in the manufacturing and use of SI ICE.
The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance”.
2. Need for and Use of the Collection
2(a) Need/Authority for the Collection
The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:
. . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).
The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every eight years. In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:
(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.
In the Administrator's judgment, nitrogen oxides (NOx), carbon monoxide (CO), hydrocarbon (HC), non-methane hydrocarbon (NMHC), and volatile organic compound (VOC) emissions from SI ICE either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart 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 the emission standards. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance.
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 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.
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
If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by these 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 (84 FR 19777) on May 6, 2019. 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 standards, 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 19,329 respondents will be subject to these standards over the three-year period covered by this ICR. This ICR reflects an increase in the number of existing respondents from the prior ICR based on continued growth in the manufacturing and use of SI ICE.
Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Engine Manufacturers Association, at (312) 929-1970, and Cummins Incorporated, at (800) 343-7357.
It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as for those submitted in response to the first Federal Register notice. In this case, no comments were received.
3(d) Effects of Less-Frequent Collection
Less-frequent information collection would decrease the margin of assurance that facilities are continuing to meet these standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.
3(e) General Guidelines
These reporting or recordkeeping requirements do not violate any of these regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.
3(f) Confidentiality
Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).
3(g) Sensitive Questions
The reporting or recordkeeping requirements in these standards do not include sensitive questions.
4. The Respondents and the Information Requested
4(a) Respondents/SIC Codes
The respondents to the recordkeeping and reporting requirements are manufacturers, owners, and operators of SI ICE. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standard and the corresponding North American Industry Classification System (NAICS) codes are 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/Reports |
||
Initial notification requirements for owners/operators of non-emergency non-certified stationary SI ICE 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 SI ICE 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) |
|
Annual report for owners/operators of emergency stationary SI 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 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 SI ICE. |
§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 SI ICE 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. This rule requires that respondents submit electronic copies of certain required performance test reports through CDX using the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI). The CDX is the EPA’s portal for submittal of electronic data
using the EPA-provided ERT to generate electronic reports of performance tests and evaluations. The ERT generates an electronic report package that will be submitted using the CEDRI. The submitted report package will be stored in the CDX archive (the official copy of record) and the EPA’s public database called WebFIRE. The amendment notes that if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written report must be submitted to the Administrator at the appropriate address listed in §60.4.
(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. |
5. The Information Collected: Agency Activities, Collection Methodology, and Information Management
5(a) Agency Activities
EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:
Agency Activities |
Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry. |
Audit facility records. |
Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS. |
5(b) Collection Methodology and Management
Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission 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 state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. 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.
5(c) Small Entity Flexibility
The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. 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 the 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 4,639 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 36,600 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously-approved ICR, and any comments received.
6(b) Estimating Respondent Costs
(i) Estimating Labor Costs
This ICR uses the following labor rates:
Managerial $141.06 ($67.17+ 110%)
Technical $120.27 ($57.27 + 110%)
Clerical $58.67 ($27.94 + 110%)
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.
(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 |
|
|
|
$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 |
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. |
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 $2,320,000. 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 $2,570,000. These are the costs of recordkeeping.
6(c) Estimating Agency Burden and Cost
The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcement program includes 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 $288,000.
This cost is based on the average hourly labor rate as follows:
Managerial $66.62 (GS-13, Step 5, $41.64 + 60%)
Technical $49.44 (GS-12, Step 1, $30.90 + 60%)
Clerical $26.75 (GS-6, Step 3, $16.72 + 60%)
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 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 19,076 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 19,329 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 a |
(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 |
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 |
a 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 19,329.
The total number of annual responses per year is calculated using the following table:
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 |
|
Initial notification (>500 hp non-certified engines) a |
30 |
1 |
n/a |
30 |
|
Record Engine Maintenance |
19,329 |
1 |
n/a |
19,329 |
|
Recording hours in non-emergency operation b |
490 |
1 |
n/a |
490 |
|
Annual Report for emergency stationary SI ICE b |
25 |
1 |
n/a |
25 |
|
Total (rounded) c |
|
|
|
19,874 |
|
a We assume 12% of the 253 new respondents, or 30 respondents, will have engines rated at >500 hp. |
|||||
b In the 2007 Cost Impacts memo for this rule1, 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)) |
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c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
The number of Total Annual Responses is 19,874.
The total annual labor costs are $4,290,000. 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 36,600 hours. Details regarding these estimates may be found 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 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 1.8 hours per response.
The total annual capital/startup and O&M costs to the regulated entity are $2,570,000. 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 5,920 labor hours at a cost of $288,000; 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 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 recordkeeping and reporting costs.
6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1.8 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-OECA-2013-0353. An electronic version of the public docket is available at http://www.regulations.gov/, which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2013-0353 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) |
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|
|
|
|
|
|
|
|
|
|
Burden Item |
(A)
|
(B)
|
(C)
|
(D)
|
(E) |
(F)
|
(G)
|
(H)
|
|
1. Applications |
N/A |
|
|
|
|
|
|
|
|
2. Surveys and Studies |
N/A |
|
|
|
|
|
|
|
|
3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
A. Familiarize with regulatory requirements c |
0.5 |
1 |
0.5 |
19,329 |
9,665 |
483 |
966 |
$1,287,214.76 |
|
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 |
|
||
TOTAL LABOR BURDEN AND COST (rounded) g |
|
|
|
|
36,600 |
$4,290,000 |
|
||
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. |
Table 2: Average Annual EPA Burden –
NSPS for Stationary Spark Ignition Internal Combustion Engines
|
||||||||
|
|
|
|
|
|
|
|
|
Activity |
(A) |
(B)
|
(C)
|
(D)
|
(E) |
(F)
|
(G)
|
(H)
|
Report Review |
|
|
|
|
|
|
|
|
1. Initial notification (>500 hp non-certified engines) c |
2 |
1 |
2 |
30 |
60 |
3 |
6 |
$3,326.76 |
2. Engine Certification for Non-certified Engine c |
2 |
1 |
2 |
253 |
506 |
25.3 |
50.6 |
$28,055.68 |
3. Engine Certification from nonroad to stationary |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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. |
1 Tanya Parise, Alpha-Gamma Technologies, Inc., Memo to Jaime Pagán, EPA Energy Strategies Group, “Cost Impacts and Emission Reductions Associated with Final NSPS for Stationary SI ICE and NESHAP for Stationary RICE”, dated December 18, 2007.
File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
File Title | ICR Package Instructions |
Author | rmarshal |
File Modified | 0000-00-00 |
File Created | 2021-01-13 |