 	SF tc \l2 "SF -83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Engine Test Cells/Stands (Renewal) (40 CFR part 63, subpart
PPPPP)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Engine Test Cells/Stands (Renewal) (40 CFR part 63, subpart
PPPPP)

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP),
for Engine Test Cells/Stands were proposed on May 14, 2002 (67 FR
34547), and promulgated on May 27, 2003 (68 FR 28785).  This standard
applies to any new or reconstructed engine test cells/stands located at
major source facilities that are being used for testing internal
combustion engines with a rated power of 25 horsepowers (hp) or more. 
An engine test cell/stand is any apparatus used for testing uninstalled
stationary or uninstalled mobile (motive) engines.  A plant site that is
a major source of HAP emissions emits or has the potential to emit any
single HAP at a rate of 10 tons (9.07 megagrams) or more per year or any
combination of HAP at a rate of 25 tons (22.68 megagrams) or more per
year.  These new or reconstructed sources must be in compliance with the
requirements of the engine test cells/stands NESHAP upon the startup of
a new or reconstructed engine test cell/stand.

Owners and operators must submit an initial notification reports upon
the construction, or reconstruction of any engine test cells/stands used
for testing internal combustion engines.  For new or reconstructed
engine test cells/stands that startup before the effective date of this
subpart, the initial notification is due no later than 120 calendar days
after the affective date of the subpart.  For new or reconstructed
engine test cells/stands with startup on or after the effective date of
this subpart, the initial notification is due no later than 120 calendar
days after the source becomes subject to this subpart.

The respondents are required to submit a semiannual compliance report. 
If there were no deviations from the emission limitation and the
continuous emission monitoring system (CEMS) was operating correctly,
the semiannual report must contain a statement by a responsible official
that no deviation occurred during the reporting period and that no CEMS
or continuous parameter monitoring system (CPMS) was out of control.  If
a deviation occurred from an emission limit, the report must contain
detailed information of the nature of the deviation(s).

Respondents of effected sources must submit a notification of compliance
status, certifying that they have complied with the standard.  In
addition, the affected sources are required to use CEMS to monitor
compliance with the standard and to conduct a performance evaluation

of the CEMS.

Any owner or operator subject to the provisions of this part will
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.  Each file will be on the site for at least two years after
the date of each occurrence, measurement, maintenance, report or record,
and off-site for the remaining three years.  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.

Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

Approximately 18 respondents are currently subject to the regulation,
and it is estimated that no additional respondents per year will become
subject to the regulation in the next three years.  The average annual
cost to industry over the next three years of this Information
Collection Request (ICR) is estimated at $242,864.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (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 will 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, HAP emissions from engine test
cells/stands cause or contribute to air pollution that may reasonably be
anticipated to endanger public health or 

welfare.  Therefore, the NESHAP were promulgated for this source
category at 40 CFR part 63, subpart PPPPP.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard 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 standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.

The notifications required in the standard 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 leaks are being detected and repaired and the standard is
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 PPPPP.

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 a 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 (69 FR 69909) on December 1, 2004.
 No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

For this information collection, we referenced the most recent ICR,
consulted with the preparer of the active ICR, and used several
different resources to obtain the most recent data available.  We
accessed the Air Facility System (AFS) database as maintained by the
Office of Compliance.  We reviewed information available from the United
States Census Bureau, and other websites covering engine test
cells/stands.  We consulted with the EPA(s Office of Air Quality
Planning and Standards, Information Transfer, the Program Integration
Division, Engine Manufacturers Association, Joseph Suchecki, (312)
827-8734, National Marine Manufacturers Association, John McKnight,
(202) 737-9757, and Swindler and Berlin, Robert Taylor,

(202) 945-6903.

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 is useful
technique to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by this standard was collected less frequently, the likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 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 record(s retention requirement is consistent
the Part 70 permit program and the five-year statute of limitations on
which the permit program is based.  Also, the retention of records for
five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, chapter 1, part 2, subpart B -
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
engine test cells/stands.  The United States Standard Industrial
Classification (SIC) codes for the respondents affected by the
standards, which corresponds to the the North American Industry
Classification System (NAICS) codes, are listed below for source
category description.

Standard (40 CFR part 63, subpart PPPPP)	

SIC Codes	

NAICS Codes



Turbine and Turbine Generator Set Units Manufacturing	

3511	

333611



Other Engine Equipment Manufacturing	

3519	

333618



All Other Motor Vehicle Parts Manufacturing	

3519	

336399



Hand and Edge Tool Manufacturing	

3523	

332212



Lawn and Garden Tractors and Home Lawn and Garden Equipment
Manufacturing	

3524	

333112



Hand and Edge Tool Manufacturing	

3524	

332212



Construction Machinery Manufacturing	

3531	

333120



Farm Machinery and Equipment Manufacturing	

3559	

333111



Other Commercial and Service Industry Machinery Manufacturing	

3559	

333319



Speed Changers, Industrial High-Speed Drives, and Gears Manufacturing	

3566	

333612



Motors and Generator Manufacturing	

3621	

335312



Automobile Manufacturing	

3711	

336111



Heavy Duty Truck Manufacturing	

3711	

336120



Light Truck and Utility Vehicle Manufacturing	

3711	

336112



Military Armored Vehicle, Tank, and Tank Component Manufacturing	

3711	

336992



Gasoline Engine and Engine Parts Manufacturing	

3714	

336312



Motor Vehicle Transmission and Power Parts Manufacturing	

3714	

336350



Aircraft Manufacturing	

3721	

336411



Research and Development i the Physical, Engineering, and Life Sciences	

3721	

541710



Aircraft Engine and Engine Parts Manufacturing	

3724	

336412



Research and Development in the Physical, Engineering, and Life Sciences


3724	

541710



Guided Missile and Space Vehicle Manufacturing	

3761	

336414



Research and Development in the Physical, Engineering, and Life Sciences


3761	

541710



Guided Missile and Space Vehicle Propulsion Unit and Propulsion Unit
Parts Manufacturing	

3764	

336415



Research and Development in the Physical, Engineering, and Life Sciences


3764	

541710



Scheduled Passenger Air Transportation	

4512	

481111



Other Support Activities for Air Transportation	

4581	

488190



Research and Development in the Physical, Engineering, and Life Sciences


8731	

541710



Testing Laboratories	

8734	

541380



Automobile Driving Schools	

8299	

611692



General Automotive Repair	

7538	

811111



Other Automotive Mechanical and Electrical Repair and Maintenance	

7539	

811118



Commercial and Industrial Machinery and Equipment (except Automotive and
Electronic) Repair and Maintenance	

7699	

811310



Home and Garden Equipment Repair and Maintenance	

7699	

811411



Space Research and Technology	

9661	

927110



National Security	

9711	

928110



This table is not intended to be exhaustive, but rather provides a guide
for readers regarding entities likely to be regulated by this action. 
To determine whether your engine test cell/stand is regulated by this
action, you should examine the applicability criteria in Sec. 63.9285 of
the final rule.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NESHAP for Engine Test Cells/Stands (Renewal) (40 CFR part 63, subpart
PPPPP).

A source must make the following reports:

Notification Reports	

Standard Citation

by Section



Initial notification	

63.9345 (b), 63.5(d), and 63.9(b)



Notification of compliance status	

63.9345(c) and 63.9(h)



Notification of intent to conduct CEMS performance evaluation	

63.9345(d) and 63.8(e)(2)



Initial performance evaluation	

63.9320(b), 63.9345(d), and 63.8(e)(2)



Notification of alternative monitoring method	

63.8(f)(4)



Waiver of recordkeeping or reporting requirements	

63.10(f)



Additional notification	

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(b), 63.9350(a), 63.9350(b), 63.9350(c), 63.9350(d), 63.10(a),
63.10(e)



A source must keep the following records:

Recordkeeping



Maintain records of emission test results and other data needed to
determine compliance with emission limitation	

63.9355(a)(5), 639355(a)(6), and 63.9355(a)(7)



Maintain records of all reports and notifications	

63.9355(a), 63.9350, and 63.10(b)



Maintain records of applicability	

63.10(b)(3)



Maintain records for sources with continuous monitoring systems	

63.9355(a)(2), 63.9355(b), 63.9355(c), 63.10(b), and 63.10(c)



Maintain records for initial notification and notification of compliance
status	

63.9355(a)(1), and 63.10(b)(2)(xiv)



Electronic Reporting

At the present, respondents are using monitoring equipment that
automatically records parameter data, e.g., temperature, pressure drop,
leaks and spills of mercury, etc.  Although personnel at the affected
facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the 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,



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.



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.



Transmit, or otherwise disclose the 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 Air Facility System (AFS).



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might 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 (e.g., 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 requirements the minimum
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 Industry Burden for NESHAP for
Engine Test Cells/Stands (Renewal) (40 CFR part 63, subpart PPPPP).

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
each of the subpart included in this ICR. The individual burdens are
expressed under standardized headings believed to be consistent with the
concept of a 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 3,043
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses the following labor rates:

Managerial	$96.41   ($45.91 + 110%)

Technical	$82.74   ($39.40 + 110%)

Clerical	$42.25   ($20.12 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September, 2004, (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 cost associated with the information collection
activities in the subject standard 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 cost when a facility
becomes subject to the regulation.  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)

Continuous Monitoring Device	

(B)

Capital/Startup Cost for One Respondent 1	

(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)



CPMS	

$500	

0	

$0	

$300	

18	

$5,400



	

	

	

$0	

	

	

$5,400

 1  It is assumed that each new or reconstructed facility will purchase
five thermocouples at a cost of $100 per thermocouple for a total cost
of $500 per facility.

The total capital/startup costs for this ICR are $0.  This is the total
of column D in the above table.  These costs are shown on the OMB 83-I
form in block 14(a), Total annualized capital/startup costs.

The total operation and maintenance (O&M) costs for this ICR are $5,400.
 This is the total of column G.  These costs are shown on the OMB 83-I
form in block 14(b), Total annual costs (O&M).

The total respondent costs in block 14 have been calculated as the
addition of the capital/startup costs, and the annual operation and
maintenance costs.  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 $5,000 (rounded).  This cost is shown on the
OMB 83-I form in block 14(c), Total annualized cost requested.  The
numbers in block 14 of the OMB 83-I form are rounded to show the cost in
thousands of dollars.

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 $7,236.

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

Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) (2004
General Schedule( which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden for NESHAP for Engine Test Cells/Stands (Renewal) (40 CFR part
63, subpart PPPPP) attached.

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately 18 existing sources
are currently subject to the standard.  It is estimated that no
additional source per year will become subject to the standard in the
next three years.

Number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents 1	

(B)

Number of Existing Respondents	

(C)

Number of Existing  Respondents that keep records but do not submit
reports	

(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)



1	

0	

18	

N/A	

0	

18



      2	

0	

18	

N/A	

0	

18



3	

0	

18	

N/A	

0	

18



Average	

	

	

	

	

18



To avoid double-counting respondents column D is subtracted.  As shown
above, the average Number of Respondents over the three year period of
this ICR is 18.  This number appears on the OMB 83-I form in block
13(a), Number of respondents.

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



Compliance status report	

18	

2	

0	

36



Performance evaluation report	

2	

1	

0	

2



Deviation report	

1	

2	

0	

2



	

	

	

Total	

40



The number of Total Annual Responses is 40.  This number is shown on the
OMB 83-I form in block 13(b), Total annual responses.

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor costs are $242,864.  The annual labor costs are
not shown on the OMB 83-I form. Details regarding these estimates may be
found in Table 1.  Annual Respondent Burden and Cost, NESHAP for Engine
Test Cells/Stands (Renewal) (40 CFR part 63, subpart PPPPP) attached.

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.

(i) Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor costs are $242,864.  The annual labor costs are
not shown on the OMB 83-I form. Details regarding these estimates may be
found in Table 1.  Annual Respondent Burden and Cost, NESHAP for Engine
Test Cells/Stands (Renewal) (40 CFR part 63, subpart PPPPP). 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 76 (rounded)
hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $5,000 (rounded).  This number is shown on the OMB 83-I form in
block 14(c), Total annualized cost requested.  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 178 labor hours at a cost of $7,236.  See Table 2. 
Annual Agency Burden and Cost, Average Annual EPA Burden for NESHAP for
Engine Test Cells/Stands (Renewal) (40 CFR part 63, subpart PPPPP).

6(f)  Reasons for Change in Burden

There is an increase in burden hours from the most recently approved
ICR.  This is partly due to the fact that the rule requires that all
sources are in compliance with the standard and have additional
reporting requirements.   These sources are accounted for in increments
of six for each year over the three-year period of the active ICR,
therefore, all eighteen sources are in compliance in the renewal ICR. 
The number of respondents is eighteen, and it is noted that no new
sources are expected over the next three years. 

Also contributing to the increase in burden hours is the rule requires
that all sources will conduct a performance evaluation and monitoring
demonstration every five years.  Because of this ruling, the first six
sources in the active ICR will be required to conduct this test on the
third year of this renewal. Since the annualized burden for initial
evaluation and demonstration is computed by averaging over the 3 year
period of the ICR, we have also averaged the additional six update
sources to reflect two additional sources per year for the 5-year
update.

6(g)  Burden Statement					

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 76 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 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
OECA-2004-0041, which is available for public viewing at the Enforcement
and Compliance Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Avenue, 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 Docket and
Information Center is (202) 566-1752.  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.  When 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
Officer for EPA.  Please include the EPA Docket ID Number OECA-2004-0041
and OMB Control Number 2060-0483 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting the information.

Table 1:  Annual Respondent Burden and Cost - NESHAP for Engine Test
Cells/Stands (Renewal) (40 CFR part 63, subpart PPPPP)

	Burden item	

(A)

Technical

Person-

hours per

occurrence	

(B)   

No.  of

occurrences

per respondent

per year	

(C)

Technical

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year b	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours per

year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Total Cost

 per year a



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Reporting requirements 	

	

	

	

	

	

	

	





  A.  Read Instructions c	

4	

1	

4	

0	

0	

  0	

0	

$0



  B.  Notifications	

	

	

	

	

	

	

	





     Initial notification c	

2	

1	

2	

0	

0	

0	

0	

$0



     Notification of construction/                          
reconstruction c, d	

2	

1	

1	

0	

0	

0	

0	

$0



     Notification of anticipated startup c, d	

2	

1	

2	

0	

0	

0	

0	

$0



     Notification of actual startup c, d	

2	

1	

2	

0	

0	

0	

0	

$0



  C.  Required activities	

	

	

	

	

	

	

	





     Initial performance evaluation e, f, g	

330	

1	

330	

2	

660	

33	

66	

$60,578.43



     Monitoring demonstration e, f, g	

148	

1	

148	

2	

296	

14.8	

29.6	

$27,168.53



     Repeat of performance evaluation e, f, g 	

330	

1	

330	

 0.4 h	

132	

6.6	

13.2	

$12,115.69



     Maintain records of CEMS                             performance i	

1.5	

50	

75	

18	

1,350	

67.5	

135	

$123,910.43



  D.  Create information	

Included in 3C	

	

	

	

	

	





  E.  Gather existing information	

Included in 3C	

	

	

	

	

	





  F.  Write report	

	

	

	

	

	

	

	





       Compliance status report j	

4	

2	

8	

18	

144	

7.2	

14.4	

$13.217.11



       Performance evaluation report k	

16	

1	

16	

2	

32	

1.6	

3.2	

$2,937.14



       Deviation report l	

16	

2	

32	

1	

32	

1.6	

3.2	

$2,937.14



Subtotal Labor Burden	

	

	

	

	

2,646	

132.3	

264.6	

$242,864.47



TOTAL LABOR  BURDEN AND COST 	

	

	

	

	

3,043	

$242,864



Assumptions:

a  This ICR uses the following labor rates:  $96.41 per hour for
Executive, Administrative, and Managerial labor; $82.74 per hour for
Technical labor, and $42.25

per hour for Clerical labor.  These rates are from the United States
Department of Labor, Bureau of Labor Statistics, December 2004, (Table
10. Private industry, 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.

b  We have assumed that there are eighteen existing sources, and that no
additional new or reconstructed sources will become subject to the rule
over the next three years.

c  We have assumed that there will be no new or reconstructed sources
over the next three years.

d  Technical persons-hours per occurrence were taken from ESD manual
Table 3 (Burden of NSPS and NESHAP Notification Reports, Excess Emission
Reports and             Recordkeeping( (Volume X, Section 2.2).

e  It is assumed that all eighteen sources are in compliance.

f  Technical persons-hours per occurrence were taken from ESD manual
Table 4 (Burden of Performance Tests and Continuous Monitoring System
(CMS)

Demonstrations( (Volume X, Section 2.2).

g   It is assumed that performance evaluations and monitoring
demonstrations will occur every five years.  According to our
calculations the fifth year will fall on the last years of this renewal
ICR, thus the requirements will only pertain to the first six facilities
of the active ICR. Therefore, six facilities averaging over three years
(6x3) =2/yr. 

h  We have assumed that 20% of performance evaluations will be repeated
due to failures.

i  We have assumed that owners or operators will have to maintain
monitoring records on a weekly basis.

j  Compliance status reports are required semiannually.

k We have assumed that two of the eighteen sources will have to write a
performance evaluation report once a year.

l  We have assumed that one of the eighteen sources will write a
deviation report.



Table 2:  Average Annual EPA Burden -  NESHAP for Engine Test
Cells/Stands (Renewal) (40 CFR part 63, subpart PPPPP)

	Burden item	

(A)

Technical

Person

Hours Per

Occurrence	

(B)   

Number  of

Occurrences

Per Year	

(C)

Technical

Person Hours Per Plant Per

Year

(C=AxB)	

(D)

Plants Per  Year	

(E)

Technical Hours 

Per Year

(E=CxD)	

(F)

Management   Hours Per Year

(F=0.05xE)	

(G)

Clerical

Hours Per

Year

(G=0.1xE)	

(H)

Total

Cost, 

Per Yeara



1.  Attend CEMS performance                         evaluation b	

32	

1	

32	

0	

0	

0	

0	

              $0



2. Repeat performance evaluation	

	

	

	

	

	

	

	





   a.  Retesting preparation b	

12	

1	

12	

0	

0	

0	

0	

$0



   b.  Attend retesting b	

32	

1	

32	

0	

0	

0	

0	

$0



3.  Deviations -enforcement activities c, d	

16	

1	

16	

3.6	

57.6	

2.88	

5.76	

$2,685.37



4.  Reporting requirements	

	

	

	

	

	

	

	





   a.  Review regulation b	

2	

2	

4	

0	

0	

0	

0	

$0



   b.  Review waivers b	

2	

2	

4	

0	

0	

0	

0	

$0



   c.  Review reports      	

	

	

	

	

	

	

	





       Review initial notification b	

2	

1	

2	

0	

0	

0	

0	

$0



       Compliance status report e, f	

2	

2	

4	

14.4	

57.6	

2.88	

5.76	

$2,685.37



       Performance evaluation report c, g	

2	

1	

2	

18 c	

36	

1.8	

3.6	

$1,678.36



       Deviation report h	

2	

2	

4	

1	

4	

0.2	

0.4	

$186.48



TOTAL LABOR BURDEN AND COST (ROUNDED 	

	

	

	

	

	

178	

	

$7,236



Assumptions:

a  This cost is based on the following hourly labor rates times a 1.6
benefits multiplication factor to account for government overhead
expenses: $56.02 for Managerial (GS-13, Step 5, $35.01 x 1.6), $41.57
for Technical (GS-12, Step 1, $25.98 x 1.6) and $22.50 Clerical (GS-6,
Step 3, $14.06 x 1.6).  These rates are from the Office of Personnel
Management (OPM) (2004 General Schedule( which excludes locality rates
of pay.

b  We have assumed that no additional new or reconstructed sources will
become subject to the rule over the next three years.

c  We have assumed that there are eighteen existing sources 

d  We have assumed that 20% of sources will be out of compliance.

e  We have assumed that 80% of sources will be in compliance.

f   Compliance status reports( reviews are required semiannually.

g  We have assumed that performance evaluation reports are reviewed once
a year.

h  We have assumed that one respondent will have its deviation report
reviewed on a semiannual basis.

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