SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP)
(Renewal)

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 horsepower (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 hazardous air pollutant (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 report 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 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 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) is 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.  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.

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.  

There are approximately 18 engine test cells/stands facilities in the
United States, which are owned and operated by the engine test cells
industry.  None of the 18 facilities in the United States are owned by
state, local, tribal or the Federal government.  They are owned and
operated by privately owned for-profit businesses.  You can find the
burden to the “Affected Public” listed below in Table 1: Annual
Industry Burden and Cost - NESHAP for Engine Test Cells/Stands (40 CFR
Part 63, Subpart PPPPP) (Renewal).  The Federal government burden does
not include work performed by Federal employees.  The burden refers only
to work performed by contractors, which could be found listed below in
Table 2: Average Annual EPA Burden - NESHAP for Engine Test Cells/Stands
(40 CFR Part 63, Subpart PPPPP) (Renewal).

In the development of the ICR, we addressed the Office of Management and
Budget (OMB) “Terms of Clearance (TOC)” on the active ICR.  The TOC
are as follows:

When this ICR is renewed, EPA should review the respondent burden,
universe, labor rates, and capital costs and ensure these estimates have
been updated.

EPA has addressed each item of concern in the TOC.  The respondent
burden, universe, labor rates, and capital cost have been thoroughly
checked, and all estimates updated.

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 (HAP). 
These standards are applicable to new or existing sources of HAP and
shall require the maximum degree of emission reduction.  In addition,
section 114(a) states that the Administrator may require any owner or
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
was 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.  In addition, the collected
information is 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.  During the performance tests, 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 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 ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

	The information generated by the monitoring, recordkeeping, and
reporting requirements described in this ICR is used by the Agency to
ensure that facilities affected by the NESHAP continue to operate the
control equipment in compliance with the regulation.

3.  Non-duplication, Consultations, and Other Collection Criteria

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

3(a)  Non-duplication

If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted their 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 (76 FR 26900) on May 9, 2011.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

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 have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by the EPA Office of Compliance.
 OTIS is the EPA 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.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed.  In developing this ICR, we contacted the Engine
Manufacturers Association at (312) 827-8734, and the National Marine
Manufacturers Association at (202) 737-9757.  

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.

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

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 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 the five years.  Without the five-year
record retention, 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 (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 which correspond to the North American
Industry Classification System (NAICS) codes are listed below for each
source category description.

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 in 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



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

In this ICR, all the data recorded or reported is required by National
Emission Standards for Hazardous Air Pollutants for Engine Test
Cells/Stands (40 CFR Part 63, Subpart PPPPP).

A source must make the following reports:

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 performance evaluation
63.9345(d), 63.8(e)(2)

Initial performance evaluation	63.9320(b), 63.9345(d), 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)

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), 63.9355(a)(7)

Maintain records of all reports and notifications	63.9355(a), 63.9350,
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), 63.10(c)

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



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 not widely used.  At this time, it is
estimated that approximately 10 percent of the respondents are reporting
electronically.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CEMS for opacity.

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 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

Observe initial performance tests and repeat performance tests if
necessary.

Review notifications and reports, including performance test reports,
excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
System (OTIS).



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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions under which
compliance was achieved.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.

Information contained in the reports is entered into OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is the
EPA database for the collection, maintenance, and retrieval of
compliance data for approximately 125,000 industrial and
government-owned facilities.  EPA uses OTIS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA
regional offices, and EPA headquarters.  EPA edits, stores, retrieves,
and analyzes the data.

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

5(c)  Small Entity Flexibility

	All of the current 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 below in Table 1: Annual Respondent Burden -
NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP)
(Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Wherever 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 

Managerial	$118.92 ($56.63 + 110%)   

Technical	$97.78 ($46.56 + 110%)

Clerical	$48.76 ($23.22 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2010, "Table 2. Civilian Workers, by
Occupational and Industry group."  The rates are from column 1, "Total
Compensation."  The rates have been increased by 110 percent to account
for the benefit packages available to those employed by private
industry.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection
activities in the subject standard 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 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. 

The total operation and maintenance (O&M) costs for this ICR are $5,400.
 This is the total of column G

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).

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $8,043.

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2011
General Schedule, which excludes locality rate of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2: Average Annual EPA Burden - NESHAP for
Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (Renewal).

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

	Based on our research for this ICR, on average over the next three
years, approximately 18 respondents will be subject to the standard.  It
is estimated that no new respondents per year will become subject to the
standard.  The overall average number of respondents, as shown in the
table below is 18 per year. 

	

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

Number of Respondents

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	0	18	N/A	0	18

1 New respondents include sources with constructed, reconstructed, and
modified affected facilities.

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.

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 Number of Annual Responses

	Total	40



The number of Total Annual Responses is 40.

The total annual labor costs are $288,361.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart
PPPPP) (Renewal).

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 3,043.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart
PPPPP) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 76 hours per
response.

The total annual capital/startup and Operation and Maintenance (O&M)
costs to the regulated entity are $5,000.

(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 $8,043.  See below Table 2:
Annual Agency Burden and Cost – NESHAP for Engine Test Cells/Stands
(40 CFR Part 63, Subpart PPPPP) (Renewal).

6(f)  Reasons for Change in Burden

There is no increase in the number of affected facilities or the number
of responses as compared to the previous ICR.  There is, however, an
increase in the estimated burden cost as currently identified in the OMB
Inventory of Approved Burdens.  The increase is not due to any program
changes.  The change in burden cost is due to the use of the most
updated labor rates.

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, disclose or provide information to or for
a Federal agency.  This includes the time needed to review instructions;
to 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; to adjust the existing ways to comply with any previously
applicable instructions and requirements; to train personnel to be able
to respond to a collection of information; to search data sources; to
complete and review the collection of information; and to 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-2011-0203.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/"
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 content of the docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search” than 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 Avenue, N.W., 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 Docket 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, N.W.,
Washington, DC 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OECA-2011-0203 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 this information.Table 1:  Annual Respondent Burden and Cost
– NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP)
(Renewal)

Burden item	(A)

Person hours per occurrence	(B)

No. of occurrences per respondent per year	(C)

Person hours per respondent per year

(C=AxB)	(D)

Respondents per year  a	(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 b



1.  Applications	N/A







	2.  Surveys and studies	N/A







	3.  Reporting requirements









    A.  Read instructions c 	4	1	4	0	0	0	0	$0

    B.  Notifications c









          Initial notifications	2	1	2	0	0	0	0	$0

          Notification of construction/reconstruction	2	1	2	0	0	0	0	$0

          Notification of anticipated startup	2	1	2	0	0	0	0	$0

          Notification of actual startup	2	1	2	0	0	0	0	$0

    C.  Create information	See 3B







	    D.  Gather existing information	See 3E







	    E.  Write report









          Compliance status report d	4	2	8	18	144	7.2	14.4	$15,638.68

          Performance evaluation report e	16	1	16	2	32	1.6	3.2	$3,475.26

          Deviation report f	16	2	32	1	32	1.6	3.2	$3,475.26

Subtotal  for Reporting  Requirements





239.2



4.  Recordkeeping requirements









    A.  Initial performance evaluation g, h, i	330	1	330	2	660	33	66
$71,677.32

    B.  Monitoring demonstration g, h, i	148	1	148	2	296	14.8	29.6
$33,146.20

    C.  Repeat performance evaluation g, h, j	330	1	330	0.4	132	6.6	13.2
$14,335.46

    D.  Maintain records of CEMS performance k	1.5	50	75	18	1,350	67.5
135	$146,612.70

Subtotal  for Recordkeeping Requirements  





2,803.7







	2,646	132.3	264.6	$288,360.88

TOTAL LABOR BURDEN AND COST (rounded)





3,042.9

3,043                      

$288,361



Assumptions:

a  We have assumed that the average number of existing sources subject
to the rule will be 18.  There will be no additional new sources per
year that will become subject to the rule over the three-year period of
this ICR.

b  This ICR uses the following labor rates:  $118.92 per hour for
Executive, Administrative, and Managerial labor; $97.78 per hour for
Technical labor, and $48.76 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December, 2010, Table 2. Civilian Workers, by Occupational
and Industry group.  The rates are from column 1, Total Compensation. 
The rates have been increased by 110 percent to account for the benefit
packages available to those employed by private industry.

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

d  We have assumed that compliance status reports are required
semiannually.

e  We have assumed that 10 percent will have to write a performance
evaluation report once a year.

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

g  We have assumed that all 18 sources are in compliance.

h  The technical persons-hours per occurrence were taken from the ESD
manual Table 4 “Burden of Performance Tests and Continuous Monitoring
System (CMS) Demonstrations” (Volume X, Section 2.2).

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

j  We have assumed that 20 percent of respondents will have to repeat
the performance evaluations due to failure.

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

	

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

Activity	(A)

EPA person- hours per occurrence	(B)

No. of occurrences per plant per year	(C)

EPA person- hours per plant per year

(C=AxB)	(D)

Plants per year  a	(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)

Cost, $ b

1.  Attend CEMS performance evaluation	32	1	32	0	0	0	0	$0

2.  Repeat performance evaluation









 Retesting preparation	12	1	12	0	0	0	0	$0

 Attend retesting 	32	1	32	0	0	0	0	$0

3.  Deviation – enforcement activities c	16	1	16	3.6	57.6	2.88	5.76
$2,985.10

4.  Reporting requirements









 Review regulation 	2  	2	4	0	0	0	0	$0

 Review waivers	2	2	4	0	0	0	0	$0

 Review reports 









             Review initial notification	2	1	2	0	0	0	0	$0

             Compliance status report d, e	2	2	4	14.4	57.6	2.88	5.76
$2,985.10

             Performance evaluation report f	2	1	2	18	36	1.8	3.6
$1,865.69

             Deviation report g	2	2	4	1	4	0.2	0.4	$207.29

Subtotals Labor Burden and cost



	155.2	7.76	15.52	$8,043.18

TOTAL ANNUAL BURDEN AND COST 

 (rounded)



	178.48

178 (rounded)	$8,043



Assumptions:

a   We have assumed that the average number of existing sources subject
to the rule will be 18 and that no additional new sources will become
subject to the rule over the three-year period of this ICR.

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses: $62.27 Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21
Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate
(GS-6, Step 3, $15.63 x 1.6).  These rates are from the Office of
Personnel Management (OPM) 2011 General Schedule which excludes locality
rates of pay.

c  We have assumed that 20 percent of respondents will be out of
compliance.

d  We have assumed that 80 percent of respondents will be in compliance.

e  Compliance status reports review is required semiannually.

f   We have assumed that owners and operators are required to review
performance evaluation reports once a year.

g  We have assumed that one respondent will have their deviation report
reviewed on a semiannual basis. 

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