 tc \l2 "SF SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Stationary Combustion Turbines 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

	NESHAP for Stationary Combustion Turbines (40 CFR part 63, subpart
YYYY) (Renewal)

1(b)  Short Characterization/Abstract		

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the regulations published at 40 CFR Part 63, subpart YYYY, were
proposed on January 14, 2003, and promulgated on March 5, 2004.  In
addition, the standard was amended on August 18, 2004, to stay the
effectiveness of two subcategories of turbines: lean pre-mix gas-fired
turbines and diffusion flame gas-fired turbines.  These regulations
apply to new sources that commenced construction or reconstruction after
the date of the final rule.  This information is being collected to
assure compliance with 40 CFR part 63, subpart YYYY.

In general, all NESHAP 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 NESHAP.

Any owner/operator subject to the provisions of this part shall maintain
a file of these measurements, and retain the file for at least five
years following the date of such measurements, 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 United States Environmental Protection
Agency (EPA) regional office.

  There is an average of one affected facilities at each plant site and
that each plant site has only one respondent (i.e., the owner/operator
of the plant site).  Over the next three years, an average of 22
respondents per year will be subject to the standard, and 9 additional
respondents per year will become subject to the standard.  

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 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and shall require the maximum degree of emission reduction. 
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, formaldehyde emissions from the
combustion of oil cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP was promulgated for this source category at 40 CFR
part 63, subpart YYYY.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) ensure
compliance with the applicable regulations which where 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 standard(s).
Continuous emission monitors are used to ensure compliance with the
standard(s) at all times.  During the performance test a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.  

The notifications required in the standard(s) are used to inform the
Agency or delegated authority when a source becomes subject to the
requirements of the regulations.  The reviewing authority may then
inspect the source to check if the pollution control devices are
properly installed and operated and the standard(s) are being met.  The
performance test may also be observed.

The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart YYYY.

3(a)  Nonduplication

 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 the Federal standards.  Therefore, no duplication
exists.

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 (71 FR 58853) on October 5, 2006. 
No comments were received on the burden published in the Federal
Register. 

3(c)  Consultations

	Stationary combustion turbines are used in more than 30 different
industry sectors.  Consultation with industry associations for each of
these industry sectors, if they exist, would be very resource intensive
and is unlikely to produce accurate burden estimates.  Instead, we
relied on data submitted by industry used in the economic analysis as
part of the rule development.  In addition, the Agency’s industry
experts have been consulted, and the Agency’s internal data sources
and projections of industry growth over the next three years were
considered.  The primary source of information as reported by industry,
in compliance with the recordkeeping and reporting provisions in the
standard, is the AFS (AIRS Facility Subsystem) which is operated and
maintained by EPA's Office of Compliance.  AFS is EPA’s database for
the collection, maintenance, and retrieval of all compliance data.  The
growth rate for the industry is based on our consultations with the
Agency’s internal industry experts. Approximately 22 respondents will
be subject to the standard over the three year period covered by this
ICR.

3(d)  Effects of Less Frequent Collection

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.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

	These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five year records retention requirement is consistent
with the part 70 permit program and the five year statute of limitations
on which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

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 the standard 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
owners and/or operators of stationary combustion turbines.  Stationary
combustion turbines are used in more than 34 different industry and
government sectors.  However, the majority of the sources covered by
Subpart YYYY fall into five Standard Industrial code (SIC) and North
American Industry Classification System (NAICS) code categories listed
in the table below.

Standard	

SIC 	

NAICS 



40 CFR part 63, subpart YYYY	

49, 46, 13, 28, 29	

221, 486, 211, 325, 324

  

4(b)  Information Requested 

(i)  Data Items

In this ICR, all the data that is recorded or reported is required by
NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart
YYYY).

A source must make the following reports:

Notifications



Initial Notification for Gas-Fired Turbines	63.6095(d)



Notification of Construction/Reconstruction.	63.6145



Notification of Actual Startup.	63.9(b)



Notification of Performance Test.	63.7(b)(1), 63.6145(e)



Notification of Compliance Status	63.(h)(2)(ii), 63.6145(f)



Reports

Performance Test Plan	63.7(c)

Semi-annual Compliance Report.	63.6150(a)



A source must keep the following records:

Recordkeeping



Maintain records of monitoring data.	

63.6155



Maintain records for five years.	

63.6160(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. 

Also, regulatory agencies in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities	

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate the catalyst inlet temperature
monitor



Perform initial performance test, Reference Method 320 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 the purpose of collecting,
validating, and verifying information.



Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.



Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.



Train personnel to be able to respond to a collection of information.



Transmit, or otherwise disclose the information.

.  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 AIRS Facility Subsystem (AFS).



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 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 is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the AFS 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.

 The records required by this regulation must be retained by the
owner/operator for five years.

5(c)  Small Entity Flexibility

	A 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.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Respondent Burden and Cost,
NESHAP for Stationary Combustion Turbines (40 CFR part 63, subpart
YYYY).

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 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.

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 435 (
Total Labor Hours from Table 1).   The recordkeeping hours shown in
Table 1 are 255.3 The reporting requirement hours shown in Table 1 are
179.4.  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.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$105.36 ($50.17 + 110%)   

Technical	$92.09   ($43.85 + 110%)

Clerical	$47.25   ($22.50 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2006, Table 2. Civilian Workers, by
occupational and industry group.  The rates are from column 1, Total
compensation.  The rates have been increased by 110% 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 the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor(s) 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)

Continuous Monitoring Device	

(B)

Capital/Startup Cost for One Respondent	

(C)

Number of New Respondents 	

(D)

Total Capital/Startup Cost,  (B X C)	

(E)

Annual O&M Costs for One Respondent	

(F)

Number of Respondents  with O&M	

(G)

Total O&M,

(E X F)



 Catalyst Inlet Temperature	

$500.00	

3	

$1,500.00	

0	

17.5	

0

 	

The total capital/startup costs for this ICR are $1,500.  This is the
total of column D in the above table.  There are no annual operation and
maintenance costs associated with this standard.  We expect the catalyst
inlet temperature monitor to be maintenance free.

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 $1,500.

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 activities such 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 $11,135.00.  

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

           Managerial	$58.18  (GS-13, Step 5, $36.36 + 60%)   

           Technical	$43.17  (GS-12, Step 1, $26.98 + 60%)

           Clerical		$23.36  (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) 2007
General Schedule which excludes locality rates of pay.  The rates have
been increased by 60% to acco                 unt for the benefit
packages available to government employees.  Details upon which this
estimate is based appear in Table 2: NESHAP for Stationary Combustion
Turbines (40 CFR part 63, subpart YYYY), below.

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 13 existing respondents will be subject to the
standard.  It is estimated that an additional 9 respondents per year
will become subject.  The overall average number of respondents, as
shown in the table below is 31 per year.

The number of respondents is calculated using the following table that
addresses the three years covered by this ICR.  

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents 1	

(B)

Number of Existing Respondents2	

(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	

9	

13	

0	

0	

22



2	

9	

22	

0	

0	

31



3	

9	

31	

0	

0	

40



Average	

9	

22	

0	

0	

31

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.  We estimate that six (6) of the nine (9)
sources will be gas fired turbines and the remaining three (3) will be
oil fired turbines.  Gas fired turbines are only subject to a one-time
initial notification requirement. 

2 Although there are a number of gas fired turbines that previously
submitted one-time initial notifications during the pervious ICR period,
they have no additional compliance responsibilities, including
recordkeeping and reporting, over the next three years.  Therefore, they
are not included as respondents for the purpose of this ICR.

.

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 31.The total number of annual responses per year is
calculated using the following table: 

Total Annual Responses



(A)

Information Collection Activity	

(B)

Number of Respondents  	

(C)

Number of Responses	

(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	

(E)

Total Annual  Responses 

E=(BxC)+D



Initial Notification	

6	

1	

0	

6



Notification of Construction	

3	

1	

0	

3



Notification of Startup	

3	

1	

0	

3



Performance Test Notification	

3	

1	

0	

3



Notification of Compliance	

3	

1	

0	

3



Semi-Annual Compliance Report	

17.51	

2	

0	

35



	

Total	

53

1 We estimate that there are 13 existing sources currently subject to
Subpart YYYY.  We also estimate that three (3) new sources will come
on-line each year that will be required to submit semi-annual compliance
reports.  Therefore, the average number of respondents submitting
semi-annual compliance reports over the next three years is estimated to
be 17.5 (13 existing + 4.5 new sources).  The average of 4.5 new sources
over the next three years was estimated by dividing the total number of
new sources over the next three years (9) by two (2).

	The number of Total Annual Responses is 53.  The total annual labor
costs are $38,508.  Details regarding these estimates may be found in
Table 1.  Annual Respondent Burden and Cost, NESHAP for Stationary
Combustion Turbines (40 CFR part 63, subpart YYYY).

The total annual capital/startup and O&M costs to the regulated entities
are $1,500.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

The average annual Agency burden and cost over next three years is
estimated to be 265 labor hours at a cost of  $11,135.  See Table 2. 
Annual Agency Burden and Cost,

NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart
YYYY.)

6(e)  Bottom Line Burden Hours 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, respectively,
and summarized below.  

(i) Respondent Tally

The total annual labor hours are 435.  Details regarding these estimates
may be found in Table 1.  Annual Respondent Burden and Cost, NESHAP for
Stationary Combustion Turbines (40 CFR part 63, subpart YYYY.) 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 8 (rounded) hours
per response.

The total annual capital/startup and O&M costs to the regulated entity
are $1,500.  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 265 labor hours at a cost of  $11,135.  See Table 2. 
Annual Agency Burden and Cost NESHAP for Stationary Combustion Turbines
(40 CFR part 63, subpart YYYY.)

6(f)  Reasons for Change in Burden

The decrease in burden from the most recently approved ICR is due to a
change in the regulation.  On August 18, 2004 (69 FR 51184), the EPA
stayed the effectiveness of this standard for gas fired turbines.  As a
result, only new oil fired turbines located at major HAP sources are
subject to Subpart YYYY at this time.  We do not expect new standards
for the gas fired units under this standard to be promulgated within the
next three years.  However, new gas fired units are required to submit a
one-time initial notification.

	

	The change in the Capital/Startup vs. Operation and Maintenance (O&M)
Costs as  calculated in section 6(b)(iii) also decreased as a result of
the regulatory change on August 18, 2004.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 8 hours (rounded) 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 valid OMB
Control Number.  The OMB Control Numbers for EPA’s 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-2006-0776.  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), EPA
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
Enforcement and Compliance Information 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-2006-0776 and OMB Control Number
2060-0540 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 of the Reporting and Recordkeeping
Requirements:











NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart YYYY)























REPORTING/RECORDKEEPING REQUIREMENT	Hours/  Occur-ence     (A)
Occur-ences/Yr              (B)	Hours/Year (C=A*B)            (C)
Respondents/Yr                  (D)	Technical Hours/Yr                
(E)	Mgt. Hours/Yr (0.05*E)                 (F)	Clerical Hours/Hr
(0.10*E)                  (G)	Total Hours/Yr        (E=C*D)        (H)	 
        Costs/Year                                                 (I)

1.	APPLICATIONS	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

2.	SURVEY AND STUDIES	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

3.	REPORTING REQUIREMENTS











a.	Read Instructions	4	1	4	9	36	1.80	3.60	41.4	$3,667.43

	b.	Required Activities













Performance Tests	12	1	12	3	36	2	4	41.4	$3,667.43

	c.	Create Information

------------------------Included in 3b----------------------------

	 



	d.	Gather Existing Information

------------------------Included in 3b----------------------------

	 



	e.	Write Report





	 





	Notification for Gas-Fired Turbines	2	1	2	6	12	0.60	1	13.8	$1,222.48



	Notification of Construction/Reconstruction	2	1	2	3	6	0.30	1	6.9
$611.24



	Notification of Initial Performance Test	2	1	2	3	6	0.30	1	6.9	$611.24



	Notification of Actual Startup	2	1	2	3	6	0.30	1	6.9	$611.24



	Notification of Compliance Status	2	1	2	3	6	0.30	1	6.9	$611.24



	Semi-Annual Compliance Report	8	2	16	3	48	2	5	55.2	$4,889.90

4.	RECORDKEEPING REQUIREMENTS











a.	Read Instructions

------------------------Included in 3a----------------------------







b.	Plan Activities

------------------------Included in 3b----------------------------







c.	Implement Activities

------------------------Included in 3b----------------------------







e.	Time to Enter Information*













Purchase and Install Catalyst Inlet Temperature Monitor	30	1	30	3	90
4.50	9.00	103.5	$9,168.57



	Records of Operating Parameters	0.5	12	6	22	132	6.60	13.20	151.8
$13,447.24

	f.	Train Personnel	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

	g.	Audits	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A















	TOTAL ANNUAL BURDEN







435	$38,508











	(rounded)	(rounded)































	Assumptions













Number of plants	22











	Time required to read instructions (hours)	4











	Time required to complete performance test (hours)	12











	Time required to record operating parameters (hours)	0.5











	Time Required to Prepare Semi-Annual Compliance Report (hours)	8











	Time Required for notification preparation (hours)	2











	Technical Labor Rate	$92.09











	Management Labor Rate	$105.36











	Clerical Labor Rate	$45.15

























Ta-ble

2



Annual Agency Burden and Cost, NESHAP for Stationary Combustion Turbines
(40 CFR Part 63, Subpart YYYY)



















	REPORTING/RECORDKEEPING REQUIREMENT	EPA Hours/ Occurence     (A)
Occurences/Plant/Yr       (B)	EPA Hours/   Yr     (C=A*B)    (C)
Plants/Yr       (D)	Technical Hours/Yr                 (E)	Mgt. Hours/Yr
(0.05*E)                 (F)	Clerical Hours/Hr (0.10*E)                 
(G)	Total       Hours/ Yr (E=C*D)        (H)	Cost/ Yr        (I)

REPORT REVIEW



	 	 	 	 	 

	New or Reconstructed



	 	 	 	 	 



Review Initial Notification for Gas-Fired Turbines	2	1	2	6	12	0.6	1.2
13.8	$580.98



Review Notification of Construction/Reconstruction	2	1	2	3	6	0.3	0.6	6.9
$290.49



Review Notification of Actual Startup	2	1	2	3	6	0.3	0.6	6.9	$290.49



Notification of Initial Performance Test	2	1	2	3	6	0.3	0.6	6.9	$290.49



Review Review Performance Test Results	8	1	8	3	24	1.2	2.4	27.6	$1,161.96



Review Semi-Annual Compliance Reports	8	1	8	22	176	8.8	17.6	202.4
$8,521.04













	TOTAL ANNUAL BURDEN







265	$11,135











(Rounded)	(Rounded)









































	Assumptions











	Average Number of Exisitng Sources	22











Number of new or reconstructed turbines  per year	9











Number of New Gas Fired Turbines	6











Number of New Oil Fired Turbines	3











Time Required to Review Notifications (hours)	2











Time Required to Review Performance Test Reports (hours)	8











Time Required to Semi-Annual Compliance Reports (hours)	8











Technical Labor Rate	$43.17











Management Labor Rate	$58.18











Clerical Labor Rate	$23.36





















	

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