1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection.
"
Recordkeeping
and
Reporting
Requirements
for
the
Engine
Test
Cells/
Stands
National
Emission
Standards
for
Hazardous
Air
Pollutants."
The
tracking
number
is
EPA
ICR
number
2066.02.

(
b)
Short
Characterization.
This
ICR
is
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
rulemaking
developed
under
authority
of
Section
112
of
the
Clean
Air
Act
(
CAA).
The
rulemaking
amends
Title
40,
Chapter
I,
Part
63
of
the
Code
of
Federal
Regulations
(
CFR)
by
adding
a
new
subpart
PPPPP­­
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Engine
Test
Cells/
Stands.
Hereafter,
this
subpart
is
referred
to
as
the
"
engine
test
cells/
stands
NESHAP".
The
engine
test
cells/
stands
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions.
Respondents
are
owners
or
operators
of
major
source
facilities
that
test
uninstalled
engines
in
engine
test
cells/
stands.
An
engine
test
cell/
stand
is
any
apparatus
used
for
testing
uninstalled
stationary
or
uninstalled
mobile
(
motive)
engines.
An
uninstalled
engine
is
defined
as
an
engine
being
tested
in
a
test
cell/
stand
that
is
not
installed
in,
or
an
integrated
part
of,
the
final
product.
A
major
source
of
HAP
emissions
is
a
plant
site
that
emits
or
has
the
potential
to
emit
any
single
HAP
at
a
rate
of
10
tons
or
more
per
year
or
any
combination
of
HAP
at
a
rate
of
25
tons
or
more
per
year.

This
information
collection
applies
only
to
a
new
or
reconstructed
affected
source
located
at
a
major
source
used
in
whole
or
in
part
for
testing
internal
combustion
engines
with
rated
power
of
25
horsepower
(
hp)
or
more.
It
is
estimated
that
18
new
or
reconstructed
major
source
facilities
will
be
subject
to
the
provisions
of
this
NESHAP
in
the
United
States
during
the
three
year
period
after
promulgation.
These
new
or
reconstructed
sources
must
be
in
compliance
with
the
requirements
of
the
engine
test
cells/
stands
NESHAP
upon
startup
of
the
new
or
reconstructed
engine
test
cell/
stand.

The
engine
test
cells/
stands
NESHAP
requires
a
new
or
reconstructed
affected
source
used
in
whole
or
in
part
for
testing
internal
combustion
engines
to
submit
a
one­
time
Initial
Notification.
For
a
new
or
reconstructed
affected
source
with
startup
before
the
effective
date
of
this
subpart,
the
Initial
Notification
is
due
not
later
than
120
calendar
days
after
the
effective
date
of
the
subpart.
For
a
new
or
reconstructed
affected
source
with
startup
on
or
after
the
effective
date
of
this
subpart,
the
Initial
Notification
is
due
not
later
than
120
calendar
days
after
the
source
becomes
subject
to
this
subpart.

Owners
or
operators
of
a
new
or
reconstructed
affected
source
used
in
whole
or
in
part
for
testing
internal
combustion
engines
with
rated
power
of
25
hp
or
more
are
required
to
submit
a
semi­
annual
report.
To
demonstrate
compliance,
affected
sources
are
allowed
to
use
a
continuous
parameter
monitoring
system
(
CPMS)
or
a
continuous
emission
monitoring
system
(
CEMS).
For
costing,
we
assumed
that
facilities
would
use
CPMS,
but
the
discussion
includes
CEMS
as
well.
If
there
were
no
deviations
from
the
emission
2
limitation
and
the
CPMS
or
CEMS
was
operating
correctly,
the
report
must
contain
a
statement
by
the
responsible
official
that
there
was
no
deviation
from
the
emission
limitation
and
that
the
CPMS
or
CEMS
was
not
out­
of­
control
as
defined
in
§
63.8(
c)(
7).
For
each
emission
limitation
deviation
and
CPMS
or
CEMS
deviation,
the
report
must
contain
detailed
information
on
the
nature
of
the
deviation(
s).
All
records
should
be
maintained
for
a
period
of
5
years
and
should
be
maintained
at
the
source
for
a
period
of
at
least
2
years.

Owners
and
operators
of
affected
sources
are
subject
to
the
requirements
of
40
CFR
Part
63,
Subpart
A,
the
General
Provisions,
unless
the
regulation
specifies
otherwise.

The
engine
test
cells/
stands
NESHAP
also
requires
affected
sources
to
submit
a
Notification
of
Compliance
Status.
This
notification
must
be
signed
by
a
responsible
company
official
who
certifies
the
truth,
accuracy,
and
completeness
of
the
content
of
the
report
and
certifies
that
the
source
has
complied
with
the
standards.
In
addition,
the
affected
sources
are
allowed
to
use
CEMS
or
CPMS
to
monitor
compliance
with
the
standard
and
are
required
to
conduct
a
performance
evaluation
of
the
CEMS
or
the
CPMS.
For
new
or
reconstructed
engine
test
cells/
stands
with
startup
before
the
effective
date
of
this
subpart,
the
performance
evaluation
of
the
CEMS
or
CPMS
must
be
completed
within
180
days
after
the
effective
date
of
the
subpart.
For
new
or
reconstructed
engine
test
cells/
stands
with
startup
on
or
after
the
effective
date
of
this
subpart,
the
performance
evaluation
of
the
CEMS
or
CPMS
must
be
completed
within
180
days
after
startup.

The
results
of
the
performance
evaluation
must
be
submitted
to
the
EPA
in
the
Notification
of
Compliance
Status.
For
new
or
reconstructed
affected
sources,
the
Notification
of
Compliance
Status
must
be
submitted
before
the
close
of
business
on
the
30th
calendar
day
following
the
completion
of
the
performance
evaluation
of
the
CEMS
or
CPMS.

Each
facility
is
required
to
submit
all
necessary
reports
to
the
respondent's
Regional,
State,
local
or
tribal
agency,
whichever
has
been
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
that
all
sources
subject
to
the
NESHAP
are
achieving
the
requirements.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.
The
EPA
is
charged
under
Section
112(
d)
of
the
CAA
to
establish
standards
to
limit
HAP
emissions
from
stationary
sources.
In
the
Administrator's
judgment,
the
engine
test
industry
causes
or
contributes
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Engine
test
facilities
were
listed
as
a
source
category
under
the
fuel
combustion
industry
group,
and
rocket
engine
test
firing
was
listed
as
a
source
category
under
the
miscellaneous
processes
industry
group
in
the
Federal
Register
on
July
16,
1992
(
57
FR
31576).
These
two
source
categories
were
combined
and
renamed
engine
test
cells/
stands
in
the
Federal
Register
on
May
14,
2002
(
67
FR
34547).
3
Section
114
of
the
CAA
gives
the
EPA
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
Section
112
of
the
CAA.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to:
(
1)
identify
new
or
reconstructed
sources
subject
to
the
engine
test
cells/
stands
NESHAP,
and
(
2)
ensure
that
the
engine
test
cells/
stands
NESHAP,
based
on
maximum
achievable
control
technology
(
MACT)
for
major
sources,
is
being
achieved.

(
b)
Use/
Users
of
the
Data.
The
EPA's
enforcement
personnel
will
use
the
emissions
data
collected
by
each
engine
test
cells/
stands
facility
to
(
1)
identify
new
or
reconstructed
HAP
emission
sources
subject
to
the
engine
test
cells/
stands
NESHAP,
and
(
2)
ensure
the
proper
regulation
of
HAP
emissions.

The
records
will
also
be
useful
in
identifying
facilities
that
are
out
of
compliance
with
the
terms
of
the
engine
test
cells/
stands
NESHAP.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.
A
search
of
the
EPA's
existing
standards
and
ongoing
ICRs
revealed
no
duplication
of
information
gathering
efforts.
However,
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
engine
test
cells/
stands
NESHAP.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
engine
test
cells/
stands
NESHAP.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.
Since
this
is
a
rule­
related
ICR,
it
is
not
necessary
to
solict
public
comments
prior
to
submittal
of
this
ICR
to
OMB.

(
c)
Consultations.
Consultations
were
conducted
with
various
representatives
of
industry
and
trade
associations
during
the
development
of
the
engine
test
cells/
stands
NESHAP.
The
following
persons
provided
input
during
development
of
the
rule:

Name
Affiliation
Telephone
Jim
Sumner
GE
Aircraft
Engines
(
513)
672­
3986
Chuck
Knauss
Swidler
Berlin
Shereff
Friedman
(
202)
424­
7644
Everett
Douglas
US
DoD­
US
Navy
(
619)
545­
2914
John
McKnight
National
Marine
Manufacturers
Association
(
202)
721­
1604
Jeff
Nobles
Delta
Air
Lines/
ATA
(
404)
714­
0063
Cathy
Jo
Seamon
Ford
Motor
Company
(
313)
390­
3799
Mary
Snow­
Cooper
DaimlerChryler
(
248)
512­
1104
Joe
Suchecki
Engine
Manufacturers
Association
(
312)
827­
8734
Name
Affiliation
Telephone
4
Larry
Keller
Polaris
Industries
Inc.
(
715)
294­
5329
Barbara
Barron
Watson
&
Barron
(
919)
828­
4402
Craig
Dousharm
Mercury
Marine
(
920)
929­
5955
Norman
Helgeson
Naval
Facilities
Engineering
Service
Center
(
805)
982­
1335
(
d)
Effects
of
Less
Frequent
Collection.
If
results
were
collected
less
frequently,
there
would
be
little
assurance
that
each
source
was
in
continuous
compliance
with
the
NESHAP.
Also,
the
EPA's
authority
to
take
administrative
action
would
be
reduced.

(
e)
General
Guidelines.
None
of
the
recordkeeping
or
reporting
requirements
contained
in
40
CFR
Part
63
Subpart
PPPPP
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

(
f)
Confidentiality.
Confidential
business
information
will
be
handled
using
Agency
guidelines
on
confidentiality,
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).

(
g)
Sensitive
Questions.
Information
to
be
reported
consists
of
emission
data
and
other
information
that
are
not
of
a
sensitive
nature.
No
sensitive
personal
or
proprietary
data
are
being
collected.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
and
NAICS
Codes.
Respondents
are
owners
or
operators
of
facilities
that
test
uninstalled
engines
in
engine
test
cells/
stands.
Since
the
government
is
the
process
of
transitioning
from
Standard
Industrial
Classification
(
SIC)
codes
to
North
American
Industrial
Classification
System
(
NAICS)
codes,
both
are
presented
in
the
following
table.
Respondents
in
these
SIC/
NAICS
codes
are
only
affected
if
engine
test
cells/
stands
are
used
for
testing
internal
combustion
engines
with
rated
power
of
25
hp
or
more
and
the
facility
is
a
major
source
of
HAP
emissions.
5
SIC
and
NAICS
Codes
of
Affected
Engine
Test
Cells/
Stands
Facilities
SIC
Codes
NAICS
Codes
3511,
3519,
3523,
3524,
3531,
3559,
3566,
3599,
3621,
3711,
3714,
3721,
3724,
3761,
3764,
4226,
4512,
4581,
5541,
7538,
7539,
7699,
8299,
8711,
8731,
8734,
8741,
9661,
9711
333112,
332212,
333120,
333611,
333612,
333618,
333111,
333319,
335312,
336111,
336120,
336112,
336399,
336992,
336312,
336350,
336411,
336412,
336414,
336415,
481111,
488190,
54171,
541380,
611692,
811111,
811118,
811310,
811411,
92711,
92811
This
list
is
not
meant
to
be
exhaustive;
other
SIC/
NAICS
Codes
could
be
included
if
the
facility
fulfills
the
definition
of
an
engine
test
cell/
stand
and
is
considered
a
major
source
of
HAP
emissions.

(
b)
Information
Requested.
(
i)
Data
items,
including
recordkeeping
requirements
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
PPPPP.
All
new
or
reconstructed
test
cells/
stands
used
for
testing
uninstalled
internal
combustion
engines
located
at
major
source
facilities
must
fulfill
these
requirements.

Notifications
Initial
Notification
63.9345(
b),
63.5(
d),
63.9(
b)

Notification
of
Compliance
Status
63.9345(
c),
63.9(
h)

Notification
of
Intent
to
Conduct
CEMS
or
CPMS
Performance
Evaluation
63.9345(
d),
63.8(
e)(
2)

Performance
Evaluation
63.9306,
63.9307,
63.9320,
63.8(
e)

Notification
of
alternative
monitoring
method
63.8(
f)(
4)

Waiver
of
recordkeeping
or
reporting
requirements
63.10(
f)

Additional
notifications
63.8(
e),
63.8(
f)(
4),
63.8(
f)(
6),
63.9(
b),
63.9(
g)(
1),
63.9(
g)(
2),
63.9(
h),
63.9(
j)

Reports
Semiannual
compliance
report
63.9340,
63.9350,
63.10(
a),
63.10(
e)
6
Recordkeeping
Emission
test
results
and
other
data
needed
to
determine
compliance
with
emission
limitation
63.9355(
a)(
5),
63.9355(
a)(
6),
63.9355(
a)(
7)

All
reports
and
notifications
63.9355(
a)(
1),
63.9350,
63.10(
b)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.9355(
a)(
2),
63.9355(
b),
63.9355(
c),
63.10(
b),
63.10(
c)

Records
for
initial
notification
and
notification
of
compliance
status
63.9355(
a)(
1),
63.10(
b)(
2)(
xiv)

All
MACT
standards
require
5
years
of
record
retention.
The
first
2
years
of
records
must
be
kept
onsite.

(
ii)
Respondent
Activities
Read
regulation
Notifications
Initial
Notification
Notification
of
construction/
reconstruction
Notification
of
anticipated
startup
Notification
of
actual
startup
5.
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

Reporting
requirements
Review
regulation
Review
Initial
Notifications
(
b)
Collection
Methodology
and
Management.

Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
monitoring
systems
(
CEMS
or
CPMS)
are
properly
installed
and
operated.
Performance
evaluation
reports
are
used
by
the
Agency
to
determine
the
capability
of
the
source
to
comply
with
the
emission
standard.
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
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
AIRS
is
EPA's
database
7
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
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
or
operator
for
five
years
and
maintained
at
the
site
for
two
years.

(
c)
Small
Entity
Flexibility.

The
recordkeeping
and
reporting
burden
is
the
same
for
all
entities,
regardless
of
size.
The
requirements
are
viewed
by
the
agency
as
the
minimum
needed
to
ensure
compliance
and
cannot
reduce
them
further
for
small
entities.

(
d)
Collection
Schedule.

Data
collection
will
begin
after
the
promulgation
date
of
the
engine
test
cells/
stands
NESHAP,
tentatively
scheduled
for
February
2003.
The
schedule
for
reports
required
by
the
engine
test
cells/
stands
NESHAP
and
the
General
Provisions
is
detailed
below.

The
Initial
Notification
is
due
not
later
than
120
calendar
days
after
the
promulgation
date
of
the
subpart
or
the
startup
date
of
the
source,
whichever
is
later,
for
all
new
or
reconstructed
major
sources
used
in
whole
or
in
part
for
testing
internal
combustion
engines.

The
Notification
of
Compliance
Status,
including
CEMS
or
CPMS
performance
evaluation
results,
must
be
submitted
no
later
than
30
days
following
the
completion
of
the
performance
evaluation.

Major
sources
of
HAP
emissions
that
contain
a
new
or
reconstructed
affected
source
used
in
whole
or
in
part
for
testing
internal
combustion
engines
with
rated
power
of
25
hp
or
more
are
required
to
submit
periodic
reports
on
a
semiannual
basis.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.

The
major
source
annual
burden
estimates
for
recordkeeping
and
reporting
are
presented
in
Tables
1
through
4.
The
annual
burden
estimates
are
based
on
an
estimated
18
new
or
reconstructed
affected
major
sources
in
the
engine
test
cells/
stands
industry
during
the
three
years
after
promulgation.
Tables
1
through
3
show
the
cost
burden
during
the
first,
second
and
third
year
after
promulgation.
Table
4
shows
the
total
costs
for
the
three
year
period
and
the
average
cost
and
labor
requirements
per
facility.
All
assumptions
made
in
the
labor
estimates
are
included
as
footnotes
to
the
tables.
8
Labor
hours
are
estimated
to
be
5,695
technical
labor
hours,
285
management
labor
hours,
and
569
clerical
hours
for
all
18
major
source
facilities
during
the
first
three
years
after
promulgation.

(
b)
Estimating
Respondent
Costs.

(
i)
Estimating
Labor
Costs
Before
the
costs
of
recordkeeping
and
reporting
were
tabulated,
an
hourly
labor
rate
was
established
for
the
affected
industry.
The
labor
rates
for
technical,
management,
and
clerical
staff
were
calculated
using
Bureau
of
Labor
Statistics
data.
The
hourly
rates
used
for
technical,
managerial,
and
clerical
were
$
45.04,
$
66.73
and
$
28.14,
respectively.
These
rates
include
overhead,
profit,
and
all
employee
benefits.
The
total
impact
is
estimated
to
be
$
10,200
per
facility.
This
estimate
is
based
on
the
assumption
that
there
will
be
18
new
or
reconstructed
affected
sources
used
in
whole
or
in
part
for
testing
internal
combustion
engines
with
rated
power
of
25
hp
or
more
located
at
major
sources
beginning
operation
in
the
three
years
after
promulgation.

(
ii)
Estimating
Monitoring
Costs
This
subpart
assumes
the
use
of
a
continuous
parameter
monitoring
system
(
CPMS)
to
ensure
compliance
with
the
emissions
limitations
for
all
new
or
reconstructed
test
cells/
stands
used
for
testing
internal
combustion
engines
with
rated
power
of
25
hp
or
more.
Monitoring
costs
include
capital
costs
of
the
thermocouples,
estimated
at
$
100
per
thermocouple
and
the
assumption
that
each
facility
will
purchase
5
thermocouples
per
year.
Assuming
18
new
or
reconstructed
facilities
will
be
required
to
purchase
this
equipment,
the
total
capital
investment
is
$
18,000
during
the
first
three
years
after
promulgation.
These
monitoring
costs
are
included
in
Tables
1,
2,
3
and
4.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
engine
test
cells/
stands
NESHAP,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.

Because
recordkeeping
and
reporting
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
operated
and
maintained
by
the
EPA's
OAQPS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
shown
in
5(
a).
Labor
rates
and
associated
costs
are
based
on
9
2000
labor
rates
from
the
U.
S.
Office
of
Personnel
Management
(
OPM).
The
estimated
wage
rates
are
$
67.44/
hr
(
GS­
15/
3
level)
for
management,
$
40.80/
hr
(
GS­
12/
3
level)
for
technical,
and
$
22.99/
hr
(
GS­
6/
3
level)
for
clerical.
Again,
for
this
analysis,
it
is
assumed
that
each
labor
hour
is
composed
of
5
percent
management,
85
percent
technical,
and
10
percent
administrative,
resulting
in
an
hourly
rate
of
$
46.47/
hr.
This
hourly
rate
includes
a
factor
of
1.6
to
account
for
employee
benefits.

Using
the
labor
rates
and
applying
them
to
the
activities
shown
in
5(
a),
the
total
agency
burden
is
$
37,500
for
the
first
three
years
following
promulgation.
All
calculations
are
shown
in
Tables
5,
6,
7,
and
8.
The
tables
include
footnotes
for
all
assumptions
used.

(
d)
Estimating
Respondent
Universe
and
Total
Burden
Cost.

The
number
of
new
or
reconstructed
major
sources
subject
to
MACT
Subpart
PPPPP
is
estimated
to
be
18.
The
total
recordkeeping
and
reporting
burden
for
the
18
new
or
reconstructed
major
sources
is
estimated
to
total
$
397,000
for
the
three
years
following
promulgation.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

Please
refer
to
Tables
1
through
5.

(
f)
Reasons
for
Change
in
Burden.

The
change
in
burden
is
due
to
a
change
in
the
definition
of
an
affected
source.
This
new
definition
changed
the
estimate
of
new
or
reconstructed
sources
from
37
to
18.
This
resulted
in
a
decreased
industry
burden.

(
g)
Burden
Statement.

The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
79
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
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
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
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
10
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2002­
0040,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
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
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
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
Office
for
EPA.
Please
include
the
OMB
Control
Number
2060­
0483
and
EPA
Docket
ID
No.
(
OAR­
2002­
0040)
.
11
PART
B
OF
THE
SUPPORTING
STATEMENT
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
12
Table
1.
Estimated
Burden
to
Industry
to
Implement
Reporting
and
Recordkeeping
Requirements
for
First
Year
after
Promulgation
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,$

(
a)

1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
(
b)
4
1
4
6
24
1.2
2.4
1,229
B.
Notifications
Initial
Notification
2
1
2
6
12
0.6
1.2
614
Notification
of
construction/
reconstruction
(
c,
d)
2
1
2
6
12
0.6
1.2
614
Notification
of
anticipated
startup
(
c,
d)
2
1
2
6
12
0.6
1.2
614
Notification
of
actual
startup
(
c,
d)
2
1
2
6
12
0.6
1.2
614
TOTAL
ONE
TIME
BURDEN
AND
COST
(
R&
R)
72
4
7
3,686
ANNUAL
COSTS
FOR
MONITORING
EQUIPMENT
(
e,
f)
3,000
AVERAGE
ONE
TIME
BURDEN
AND
COST
PER
FACILITY
(
R&
R)
(
g)
12
1
1
1,114
(
a)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
45.04,
management
at
$
66.73,
and
clerical
at
$
28.14.

(
b
)
Assumes
1/
3
of
all
18
new
major
source
facilities
will
come
on
line
in
this
year
and
all
will
read
the
regulation.

(
c)
Person­
hours
per
occurrence
are
from
ESD
manual
Table
3
"
Burden
of
NSPS
and
NESHAP
Notification
Reports,
Excess
Emission
Reports
and
Recordkeeping"
(
Volume
X,
Section
2.2).

(
d)
Assumes
18
facilities
will
comply
over
the
three
year
period
or
6
per
year.

(
e)
Assumes
that
6
new
major
source
facilities
coming
on
line
in
this
year
will
purchase
thermocouples
before
conducting
the
performance
and
monitoring
evaluations.

(
f)
Assuming
the
use
of
thermocouples
for
parameter
monitoring
at
a
cost
of
$
100
per
thermocouple
and
purchasing
5
per
year.

(
g)
Assumes
6
facilities.
13
Table
2.
Estimated
Burden
to
Industry
to
Implement
Reporting
and
Recordkeeping
Requirements
for
Second
Year
after
Promulgation
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,$

(
a)

1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
(
b)
4
1
4
6
24
1
2
1,229
B.
Notifications
Initial
Notification
2
1
2
6
12
1
1
614
Notification
of
construction/
reconstruction
(
c,
d)
2
1
2
6
12
1
1
614
Notification
of
anticipated
startup
(
c,
d)
2
1
2
6
12
1
1
614
Notification
of
actual
startup
(
c,
d)
2
1
2
6
12
1
1
614
C.
Required
activities
Initial
performance
evaluation
(
d,
e,
f)
330
1
330
6
1980
99
198
101,357
Monitoring
demonstration
(
d,
e,
f)
100
1
100
6
600
30
60
30,714
Repeat
of
performance
evaluation
(
d,
e,
f,
g)
330
1
330
1.2
396
20
40
20,271
Maintain
monitoring
records
on
a
weekly
basis
(
c)
1.5
50
75
6
450
23
45
23,036
D.
Write
semi­
annual
report
Write
compliance
status
report
(
c)
4
2
8
6
48
2
5
2,433
Write
performance
evaluation
report
(
d,
f,
h)
16
1
16
6
96
5
10
4,914
Write
deviation
report
(
c,
i)
16
2
32
.06
2
0
0
98
TOTAL
ONE
TIME
BURDEN
AND
COST
(
R&
R)
3644
182
364
186,510
ANNUAL
COSTS
FOR
MONITORING
EQUIPMENT
(
j,
k,
l)
6,000
AVERAGE
ONE
TIME
BURDEN
AND
COST
PER
FACILITY
(
R&
R)
(
m)
304
15
30
16,042
(
a)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
45.04,
management
at
$
66.73,
and
clerical
at
$
28.14.

(
b)
Assumes
1/
3
of
all
18
new
major
source
facilities
will
come
on
line
in
this
year
and
all
will
read
the
regulation.

(
c)
Person­
hours
per
occurrence
are
from
ESD
manual
Table
3
"
Burden
of
NSPS
and
NESHAP
Notification
Reports,
Excess
Emission
Reports
and
Recordkeeping"
(
Volume
X,
Section
2.2).

(
d)
Assumes
18
facilities
will
comply
over
the
three
year
period
or
6
per
year.

(
e)
Person­
hours
per
occurrence
are
from
ESD
manual
Table
4
"
Burden
of
Performance
Tests
and
Continuous
Monitoring
System
(
CMS)
Demonstrations"
(
Volume
X,

Section
2.2).

(
f)
Assumes
performance
evaluations
and
monitoring
demonstrations
will
occur
every
5
years
for
the
6
facilities.

(
g)
Assumes
20%
of
performance
evaluations
will
be
failures,
requiring
repeats.

(
h)
Assumes
one
performance
evaluation
for
each
facility.

(
i)
Assumes
1%
of
18
new
major
source
test
sources
will
be
out
of
compliance.
14
(
j)
Assumes
that
6
new
major
source
facilities
coming
on
line
in
this
year
will
purchase
thermocouples
before
conducting
the
performance
and
monitoring
evaluations.

(
k)
Assumes
that
the
6
new
major
source
facilities
coming
on
line
last
year
will
also
purchase
thermocouples.

(
l)
Assuming
the
use
of
thermocouples
for
parameter
monitoring
at
a
cost
of
$
100
per
thermocouple
and
purchasing
5
per
year.

(
m)
Assumes
12
facilities.
15
Table
3.
Estimated
Burden
to
Industry
to
Implement
Reporting
and
Recordkeeping
Requirements
for
Third
Year
after
Promulgation
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,$

(
a)

1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
(
b)
4
1
4
6
24
1
2
1,229
B.
Notifications
Initial
Notification
2
1
2
6
12
1
1
614
Notification
of
construction/
reconstruction
(
c,
d)
2
1
2
6
12
1
1
614
Notification
of
anticipated
startup
(
c,
d)
2
1
2
6
12
1
1
614
Notification
of
actual
startup
(
c,
d)
2
1
2
6
12
1
1
614
C.
Required
activities
Initial
performance
evaluation
(
d,
e,
f)
330
1
330
6
1980
99
198
101,357
Monitoring
demonstration
(
d,
e,
f)
100
1
100
6
600
30
60
30,714
Repeat
of
performance
evaluation
(
d,
e,
f,
g)
330
1
330
1.2
396
20
40
20,271
Maintain
monitoring
records
on
a
weekly
basis
(
c)
1.5
50
75
6
450
23
45
23,036
D.
Write
semi­
annual
report
Write
compliance
status
report
(
c)
4
2
8
12
96
5
10
4,865
Write
performance
evaluation
report
(
d,
f,
h)
16
1
16
6
96
5
10
4,914
Write
deviation
report
(
c,
i)
16
2
32
.12
4
0
0
197
TOTAL
ONE
TIME
BURDEN
AND
COST
(
R&
R)
3694
185
369
189,040
ANNUAL
COSTS
FOR
MONITORING
EQUIPMENT
(
j,
k,
l)
9,000
AVERAGE
ONE
TIME
BURDEN
AND
COST
PER
FACILITY
(
R&
R)
(
m)
205
10
21
11,002
(
a)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
45.04,
management
at
$
66.73,
and
clerical
at
$
28.14.

(
b)
Assumes
1/
3
of
all
18
new
major
source
facilities
will
come
on
line
in
this
year
and
all
will
read
the
regulation.

(
c)
Person­
hours
per
occurrence
are
from
ESD
manual
Table
3
"
Burden
of
NSPS
and
NESHAP
Notification
Reports,
Excess
Emission
Reports
and
Recordkeeping"
(
Volume
X,
Section
2.2).

(
d)
Assumes
18
facilities
will
comply
over
the
three
year
period
or
6
per
year.

(
e)
Person­
hours
per
occurrence
are
from
ESD
manual
Table
4
"
Burden
of
Performance
Tests
and
Continuous
Monitoring
System
(
CMS)
Demonstrations"
(
Volume
X,

Section
2.2).

(
f)
Assumes
performance
evaluations
and
monitoring
demonstrations
will
occur
every
5
years
for
the
6
facilities.

(
g)
Assumes
20%
of
performance
evaluations
will
be
failures,
requiring
repeats.

(
h)
Assumes
one
performance
evaluation
for
each
facility.

(
i)
Assumes
1%
of
18
new
major
source
test
sources
will
be
out
of
compliance.
16
(
j)
Assumes
that
6
new
major
source
facilities
coming
on
line
in
this
year
will
purchase
thermocouples
before
conducting
the
performance
and
monitoring
evaluations.

(
k)
Assumes
that
the
6
new
major
source
facilities
coming
on
line
last
year
will
also
purchase
thermocouples.

(
l)
Assuming
the
use
of
thermocouples
for
parameter
monitoring
at
a
cost
of
$
100
per
thermocouple
and
purchasing
5
per
year.

(
m)
Assumes
18
facilities.
17
Table
4.
Estimated
Total
Burden
to
Industry
to
Implement
Reporting
and
Recordkeeping
Requirements
Year
Technical
hours
Management
hours
Clerical
hours
Total
hours
Labor
costs
Capital
costs
Total
costs
Year
1
72
4
7
83
$
3,686
$
3,000
$
6,686
Year
2
3,643
182
364
4,190
$
186,510
$
6,000
$
192,510
Year
3
3,694
185
369
4,248
$
189,040
$
9,000
$
198,040
Totals
8,521
$
379,236
$
18,000
$
397,236
Table
5.
Estimated
Recurrent
Burden
and
Cost
to
the
Agency
to
Implement
Reporting
and
Recordkeeping
Requirements
for
Engine
Test
Cells/
Stands
NESHAP
during
the
First
Year
After
Promulgation
Date
Burden
item
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)

Cost,
$

(
a)

Reporting
requirements
Review
regulation
(
b)
2
1
2
1.00
2
0
0
93
Review
waivers
(
c)
2
1
2
0.00
0
0
0
0
Review
Initial
Notification
2
1
2
6.00
12
1
1
558
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
14
1
1
651
ANNUAL
AVERAGE
TRAVEL
EXPENSES
(
d)
0
AVERAGE
TOTAL
COST
=
ANNUAL
AVERAGE
COST
+
ANNUAL
AVERAGE
TRAVEL
EXPENSES
651
(
a)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.

(
b)
Assumes
the
Agency
will
review
the
regulation
once
prior
to
reviewing
the
Initial
Notifications.

(
c)
Assumes
no
new
or
reconstructed
major
source
facilities
will
apply
for
a
waiver.

(
d)
Assumes
performance
evaluations
require
4
days
per
facility
and
enforcement
visits
require
2
days
per
facility.
18
Table
6.
Estimated
Recurrent
Burden
and
Cost
to
the
Agency
to
Implement
Reporting
and
Recordkeeping
Requirements
for
Engine
Test
Cells/
Stands
NESHAP
during
the
Second
Year
After
Promulgation
Date
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilitie
s
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)

Cost,
$

(
a)

1.
Attend
performance/
monitoring
demonstration
(
b,
c)
32
1
32
6
192
10
19
8,922
2.
Repeat
performance/
monitoring
evaluation
A.
Retesting
preparation
(
b,
d)
12
1
12
1
12
1
1
558
B.
Attend
retesting
(
b,
c)
32
1
32
1
32
2
3
1,487
3.
Deviations
 
enforcement
activities
(
f,
g)
16
1
16
1.2
19
1
2
892
4.
Reporting
requirements
A.
Review
regulation
(
h)
2
2
4
6
24
1
2
1,115
B.
Review
waivers
(
i)
2
1
2
0
0
0
0
0
C.
Review
reports
and
notifications
i.
Review
Initial
Notification
2
1
2
6
12
1
1
558
ii.
Review
compliance
status
report
(
j)
2
2
4
4.8
19
1
2
892
iii.
Review
performance
evaluation
report
(
k,
l)
2
1
2
6
12
1
1
558
iv.
Review
deviation
report
(
g)
2
2
4
1.2
5
0
0
223
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
327
16
33
15,205
ANNUAL
AVERAGE
TRAVEL
EXPENSES
(
m)
2,160
AVERAGE
TOTAL
COST
=
ANNUAL
AVERAGE
COST
+
ANNUAL
AVERAGE
TRAVEL
EXPENSES
17,365
(
a)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.

These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

(
b)
Assumes
1
CEMS
or
CPMS
per
facility
(
c)
Assumes
EPA
will
attend
all
performance
evaluations
for
6
facilities
(
d)
Assumes
20%
of
facilities
will
fail
the
initial
performance
evaluation
and
all
will
repeat
it
(
assumed
one).

(
e)
Assumes
EPA
will
attend
all
retests
(
assumed
one).

(
f)
Assumes
an
EPA
follow­
up
visit
of
2
days
per
deviation
report
(
g)
Assumes
20%
of
6
major
sources
will
be
out
of
compliance.

(
h)
Assumes
Agency
will
review
regulation
once
per
facility.

(
i)
Assumes
no
new
or
reconstructed
major
source
facilities
will
apply
for
a
waiver.
19
(
j)
Assumes
80%
of
6
major
source
facilities
will
be
in
compliance.

(
k)
Assumes
one
performance
evaluation
per
facility.

(
l)
Assumes
18
facilities
will
comply
or
6
per
year.

(
m)
Assumes
performance
evaluations
require
4
days
per
facility
and
enforcement
visits
require
2
days
per
facility:

[
Travel
costs=
[(
1
person
x
(#
of
facilities)/
yr
x
4
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(#
of
facilities)
round
trips/
yr)]
+

[(
1
person
x
(#
of
enforcement
facilities)/
yr
x
2
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(#
of
enforcement
facilities)
round
trips/
yr)]
20
Table
7.
Estimated
Recurrent
Burden
and
Cost
to
the
Agency
to
Implement
Reporting
and
Recordkeeping
Requirements
for
Engine
Test
Cells/
Stands
NESHAP
during
the
Third
Year
After
Promulgation
Date
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilitie
s
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)

Cost,
$

(
a)

1.
Attend
performance/
monitoring
demonstration
(
b,
c)
32
1
32
6
192
10
19
8,922
2.
Repeat
performance/
monitoring
evaluation
A.
Retesting
preparation
(
b,
d)
12
1
12
1
12
1
1
558
B.
Attend
retesting
(
b,
c)
32
1
32
1
32
2
3
1,487
3.
Deviations
 
enforcement
activities
(
f,
g)
16
1
16
2.4
38
2
4
1,784
4.
Reporting
requirements
A.
Review
regulation
(
h)
2
2
4
6
24
1
2
1,115
B.
Review
waivers
(
i)
2
1
2
0
0
0
0
0
C.
Review
reports
and
notifications
i.
Review
Initial
Notification
2
1
2
6
12
1
1
558
ii.
Review
compliance
status
report
(
j)
2
2
4
9.6
38
2
4
1,784
iii.
Review
performance
evaluation
report
(
k,
l)
2
1
2
6
12
1
1
558
iv.
Review
deviation
report
(
g)
2
2
4
2.4
10
0
1
446
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
370
19
37
17,213
ANNUAL
AVERAGE
TRAVEL
EXPENSES
(
m)
2,280
AVERAGE
TOTAL
COST
=
ANNUAL
AVERAGE
COST
+
ANNUAL
AVERAGE
TRAVEL
EXPENSES
19,493
(
a)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.

These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

(
b)
Assumes
1
CEMS
or
CPMS
per
facility
(
c)
Assumes
EPA
will
attend
all
performance
evaluations
for
6
facilities.

(
d)
Assumes
20%
of
facilities
will
fail
the
initial
performance
evaluation
and
all
will
repeat
it
(
assumed
one).

(
e)
Assumes
EPA
will
attend
all
retests
(
assumed
one).

(
f)
Assumes
an
EPA
follow­
up
visit
of
2
days
per
deviation
report
(
g)
Assumes
20%
of
12
major
sources
will
be
out
of
compliance.

(
h)
Assumes
Agency
will
review
regulation
once
per
facility.

(
i)
Assumes
no
new
or
reconstructed
major
source
facilities
will
apply
for
a
waiver.

(
j)
Assumes
80%
of
12
major
source
facilities
will
be
in
compliance.
21
(
k)
Assumes
one
performance
evaluation
per
facility.

(
l)
Assumes
18
facilities
will
comply
or
6
per
year.

(
m)
Assumes
performance
evaluations
require
4
days
per
facility
and
enforcement
visits
require
2
days
per
facility:

[
Travel
costs=
[(
1
person
x
(#
of
facilities)/
yr
x
4
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(#
of
facilities)
round
trips/
yr)]
+

[(
1
person
x
(#
of
enforcement
facilities)/
yr
x
2
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(#
of
enforcement
facilities)
round
trips/
yr)]
22
Table
8.
Estimated
Total
Burden
to
Agency
to
Implement
Reporting
and
Recordkeeping
Requirements
Year
Technical
hours
Management
hours
Clerical
hours
Total
hours
Labor
costs
Travel
costs
Total
costs
Year
1
14
1
1
16
$
651
$
0
$
651
Year
2
327
16
33
376
$
15,205
$
2,160
$
17,365
Year
3
370
19
37
426
$
17,213
$
2,280
$
19,493
Totals
818
$
33,069
$
4,440
$
37,509
23
ATTACHMENT
1
Burden
and
Cost
of
Monitoring,
Recordkeeping,
and
Reporting
Requirements
For
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date
24
BURDEN
AND
COST
OF
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
THE
FOURTH,
FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
The
Information
Collected
 
­
Respondent
Activities
and
Agency
Activities
(
a)
Respondent
Activities
As
shown
in
the
Supporting
Statement,
there
are
activities
that
occur
in
the
three
years
between
the
effective
date
and
the
compliance
date
of
the
regulation.
These
include
the
Initial
Notifications
and
buying
monitoring
equipment.

In
the
three
years
following
the
compliance
date,
there
are
recurrent
activities
that
are
required
of
the
respondents.
These
include
compiling
and
maintaining
records
of
monitoring,
writing
semiannual
reports,
writing
compliance
status
reports,
and
writing
deviation
reports
(
if
necessary).

(
b)
Agency
Activities
As
shown
in
the
Supporting
Statement,
the
agency
burden
includes
the
review
of
Initial
Notifications,
performance/
monitoring
evaluation
reports,
compliance
reports,
and
conducting
enforcement
visits
during
the
three
years
between
the
effective
date
and
the
compliance
date.
During
the
three
years
following
the
compliance
date,
the
agency
burden
includes
recurrent
activities
such
as
responding
to
deviations
through
enforcement
activities,
reviewing
the
regulation,
and
reviewing
reports.

2.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
and
Costs
(
i)
Estimating
respondent
burden
and
labor
costs.

The
labor
rates
for
technical,
management,
and
clerical
staff
were
calculated
using
Bureau
of
Labor
Statistics
data.
The
hourly
rates
used
for
technical,
managerial,
and
clerical
were
$
45.04,
$
66.73
and
$
28.14,
respectively.
These
rates
include
overhead,
profit,
and
all
employee
benefits.

Since
the
respondent
activities
are
recurrent
for
years
four,
five,
and
six,
the
information
is
shown
in
Table
1,
along
with
all
assumptions
made.
For
these
three
years,
the
total
burden
to
the
18
major
sources
is
estimated
to
be
$
175,000
annually.
The
labor
requirements
total
3,900
hours
per
year.

(
ii)
Estimating
capital
costs.

The
only
capital
costs
estimated
for
the
three
years
following
the
compliance
date
are
the
purchase
of
thermocouples
for
parameter
monitoring.
25
(
b)
Estimating
Agency
Burden
and
Costs
Labor
rates
and
associated
costs
are
based
on
2000
labor
rates
from
the
U.
S.
Office
of
Personnel
Management
(
OPM).
The
estimated
wage
rates
are
$
67.44/
hr
(
GS­
15/
3
level)
for
management,
$
40.80/
hr
(
GS­
12/
3
level)
for
technical,
and
$
22.99/
hr
(
GS­
6/
3
level)
for
clerical.
These
hourly
rates
include
a
factor
of
1.6
to
account
for
employee
benefits.

Since
the
agency
activities
are
recurrent
for
years
four,
five,
and
six,
the
information
is
shown
in
Table
2,
along
with
all
assumptions
made.
For
these
three
years,
the
total
agency
burden
is
estimated
to
be
$
17,300
annually.
The
labor
requirements
total
370
hours
annually.
26
Table
1.
ESTIMATED
RECURRENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
ENGINE
TEST
CELLS/
STANDS
NESHAP
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,$

(
a)

1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
(
b)
4
1
4
18
72
4
7
3,686
B.
Required
activities
Initial
performance
evaluation
(
d,
e)
330
1
330
3.6
1,188
59
119
60,814
Monitoring
demonstration
(
d,
e)
100
1
100
3.6
360
18
36
18,429
Repeat
of
performance
evaluation
(
d,
e,
f)
330
1
330
0.7
238
12
24
12,163
Maintain
monitoring
records
on
a
weekly
basis
(
c)
1.5
50
75
18.0
1,350
68
135
69,107
C.
Write
semi­
annual
report
Write
compliance
status
report
(
c)
4
2
8
18
144
7
14
7,371
Write
performance
evaluation
report
(
d,
g)
16
1
16
3.6
58
3
6
2,949
Write
deviation
report
(
c,
h)
16
2
32
0.18
23
0
1
295
TOTAL
RECURRENT
BURDEN
AND
COST
(
R&
R)
3,415
171
341
174,814
ANNUAL
COSTS
FOR
MONITORING
EQUIPMENT
(
i)
9,000
AVERAGE
RECURRENT
COSTS
PER
FACILITY
(
MONITORING
and
R&
R)
10,212
(
a)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
45.04,
management
at
$
66.73,
and
clerical
at
$
28.14.

(
b)
Assumes
all
18
new
major
source
facilities
will
read
the
regulation.

(
c)
Person­
hours
per
occurrence
are
from
ESD
manual
Table
3
"
Burden
of
NSPS
and
NESHAP
Notification
Reports,
Excess
Emission
Reports
and
Recordkeeping".

(
d)
Assumes
18
facilities
will
comply
every
five
years
or
3.6
per
year
.

(
e)
Person­
hours
per
occurrence
are
from
ESD
manual
Table
4
"
Burden
of
Performance
Tests
and
Continuous
Monitoring
System
(
CMS)
Demonstrations".

(
f)
Assumes
20%
of
performance
evaluations
will
be
failures,
requiring
repeats.

(
g)
Assumes
one
evaluation
for
each
facility.

(
h)
Assumes
1%
of
18
new
major
sources
will
be
out
of
compliance.

(
i)
Assuming
the
use
of
thermocouples
for
parameter
monitoring
at
a
cost
of
$
100
per
thermocouple
and
purchasing
5
per
year.
27
Table
2.
ESTIMATED
RECURRENT
BURDEN
AND
COST
TO
THE
AGENCY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
ENGINE
TEST
CELLS/
STANDS
NESHAP
Burden
item
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)

Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
personhours
per
year
(
F
=
E
x
0.05)
(
G)

Clerical
personhours
per
year
(
G
=
E
x
0.1)
(
H)

Cost,
$

(
a)

1.
Attend
monitoring
demonstration
(
b,
c)
32
1
32
3.6
115
6
12
5,353
2.
Repeat
performance
evaluation
A.
Retesting
preparation
(
b,
d)
12
1
12
1
12
1
1
558
B.
Attend
retesting
(
b,
e)
32
1
32
1
32
2
3
1,487
3.
Deviations­­
enforcement
activities
(
f,
g)
16
1
16
3.6
58
3
6
2,677
4.
Reporting
requirements
A.
Review
regulation
2
2
4
6
24
1
2
1,115
B.
Review
waivers
(
h)
2
2
4
0
0
0
0
0
C.
Review
semi­
annual
reports
Review
compliance
status
report
(
i)
2
2
4
14.4
58
3
6
2,677
Review
performance
evaluation
report
(
j,
k)
2
1
2
3.60
7
0
1
335
Review
deviation
report
(
g)
2
2
4
3.6
14
1
1
669
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
320
16
32
14,871
ANNUAL
AVERAGE
TRAVEL
EXPENSES
(
l)
2,400
AVERAGE
TOTAL
COST
=
ANNUAL
AVERAGE
COST
+
ANNUAL
AVERAGE
TRAVEL
EXPENSES
320
16
32
17,271
(
a)
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
These
costs
are
based
on
2000
wages
listed
by
U.
S.

Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

(
b)
Assumes
1
CEMS
or
CPMS
per
facility
(
c)
Assumes
EPA
will
attend
20%
of
performance
evaluations
for
3.6
facilities
(
18
every
5
years)

(
d)
Assumes
20%
of
facilities
will
fail
the
initial
performance
evaluation
and
all
will
repeat
it
(
assumed
one)

(
e)
Assumes
EPA
will
attend
25%
of
the
retests
(
assumed
one)

(
f)
Assumes
an
EPA
follow­
up
visit
of
2
days
per
deviation
report
(
g)
Assumes
20%
of
18
major
sources
will
be
out
of
compliance.

(
h)
Assumes
no
new
or
reconstructed
major
source
facilities
will
apply
for
a
waiver.

(
i)
Assumes
80%
of
18
major
source
facilities
will
be
in
compliance.

(
j)
Assumes
one
performance
evaluation
per
facility.

(
k)
Assumes
18
facilities
will
comply
over
a
5
year
period
or
3.6
per
year.

(
l)
Assumes
performance
evaluations
require
4
days
per
facility
and
enforcement
visits
require
2
days
per
facility:

[
Travel
costs=
[(
1
person
x
(#
of
facilities)/
yr
x
4
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(#
of
facilities)
round
trips/
yr)]
+

[(
1
person
x
(#
of
enforcement
facilities)/
yr
x
2
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(#
of
enforcement
facilities)
round
trips/
yr)]
