SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal), 

EPA ICR Number 2177.06, OMB Control Number 2060-0582.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Stationary Combustion Turbines

were proposed on February 18, 2005, and promulgated on July 6, 2006. These regulations apply

to new stationary combustion turbines with a heat input at peak load equal to or greater than 10.7 

gigajoules (10 MMBtu) per hour, based on the higher heating value of the fuel. New facilities 

include those that commenced construction, modification or reconstruction after the date of 

proposal. This information is being collected to assure compliance with 40 CFR Part 60, Subpart 

KKKK.

In general, all NSPS standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NSPS. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least two 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.

The “Affected Public” constitutes private-sector businesses that operate stationary

combustion turbines. None of the facilities in the United States are owned by either state, local, 

tribal, or the Federal government. They are all owned and operated by privately-owned, forprofit businesses. We assume they will all respond. The “burden” to the Affected Public may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary

Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal). The Federal Government’s

“burden” is attributed entirely to work performed by either Federal employees or government 

contractors. The burden to the Federal Government may be found below in Table 2: Average 

Annual EPA Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, 

Subpart KKKK) (Renewal).

Based on our consultations with industry representatives, there is an average of one
2

affected facility at each plant site and each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an approximate average of 589 respondents per year will be 

subject to these standards, and 47 additional respondents per year will become subject to these

same standards. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance”.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years.

In addition, section 114(a) states that the Administrator may require any owner/operator 

subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, nitrogen oxide (NOx) and sulfur dioxide (SO2)
3

emissions from stationary combustion turbines either cause or contribute to air pollution that 

may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NSPS 

were promulgated for this source category at 40 CFR Part 60, Subpart KKKK.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure compliance with 

the applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standards. Continuous emission monitors are used to 

ensure compliance with the standards 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 these standards 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, leaks are being detected and repaired, and that the standards 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. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 60, Subpart

KKKK.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register.
4

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. The growth rate for the industry is based on our consultations 

with the Agency’s internal industry experts. 

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 and the standard

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted: 1) the Western States Petroleum Association 

(WSPA), at (916) 498-7750; and 2) the Engine Manufacturers Association (EMA), at (312) 827-

8700. 

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. In this 

case, no comments were received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet 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.

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
5

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 stationary

combustion turbines. The United States Standard Industrial Classification (SIC) codes for 

the respondents affected by the standards and their corresponding North American Industry

Classification System (NAICS) codes are listed below.

Standard (40 CFR Part 60, Subpart KKKK) SIC Codes NAICS Codes

Electric Power Generation, Transmission and

Distribution 4911, 4931, 4939 2211

Pipeline Transportation of Natural Gas 4923, 4922 486210

Crude Petroleum and Natural Gas Extraction 1311 211111

Natural Gas Liquid Extraction 1321, 2819 211112

Utilities 4911, 4931, 4939, 4923, 

4924, 4925, 4932, 4941, 

4971, 4952, 4961

221

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for 

Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK).

A source must make the following reports:

Notifications

Excess emission and monitoring performance report 60.7(c), 60.4375(a)

Report of the results of the performance test 60.8(a), 60.4375(b)

Notification of construction/reconstruction 60.7(a)(1)
6

Notifications

Notification of actual startup 60.7(a)(3)

Notification of performance test 60.8(a)

Notification of CEMS demonstration 60.7(a)(5)

Reports

Semiannual Compliance Report 60.7(d)

A source must keep the following records:

Recordkeeping

Maintain records of occurrence and duration of any startup, shutdown, 

or malfunction in the operation of an affected facility; any malfunction 

of the air pollution control equipment; or any periods during which a 

CMS or monitoring device is inoperative.

60.7(b)

Maintain a file of all measurements, including CMS, monitoring 

device, and performance testing measurements; all CMS performance 

evaluations; all CMS or monitoring device calibration checks; 

adjustments and maintenance performed on these systems or devices; 

and all other information required by this part recorded in a permanent 

form suitable for inspection. The file shall be retained for at least two 

years following the date of such measurements, maintenance, reports, 

and records, except some CEMS sub-hourly measurements. 

60.7(f)

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.

(ii) Respondent Activities

Respondent Activities
7

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device.

Perform initial performance test, Reference Method 1, 2, 3A, 7E, 19, and 20 tests, 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.

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information:

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 

and ICIS. 
8

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source 

to determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standards. 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 reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two

years.

5(c) Small Entity Flexibility

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 this 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 and Cost – NSPS for Stationary

Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.
9

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 59,000 (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 NSPS program, the previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “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 only costs to the regulated industry resulting from information collection activities 

required by the subject standards are labor costs. There are no capital/startup or operation and 

maintenance costs involved.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

The only type of industry costs associated with the information collection activity in the 

regulations are labor costs. There are no capital/startup or operation and maintenance costs

involved.

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. 
10

The average annual Agency cost during the three years of the ICR is estimated to be

$87,700. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Stationary

Combustion Turbines (40 CFR Part 60, Subpart KKKK) (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

542 existing respondents will be subject to the standard. It is estimated that an additional 47

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 589 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 

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 47 495 0 0 542

2 47 542 0 0 589

3 47 589 0 0 636

Average 47 542 0 0 589

1

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

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 589. 
11

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

Notification of 

construction/reconstruction 47 1 0 47

Notification of actual startup 47 1 0 47

Notification of performance 

test

199 1 0 199

Notification of demonstration 

of CEMS 15 1 0 15

Initial notification of 

compliance 47 1 0 47

Compliance report 542 2 0 1,084

Total 1,439

The number of Total Annual Responses is 1,439. 

The total annual labor costs are $5,930,000. Details regarding these estimates may 

be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary

Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 59,000 hours. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Stationary

Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 41 hours per response.
12

The total annual capital/startup and O&M costs to the regulated entity are $0. 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 

1,930 labor hours at a cost of $87,700. See (below) Table 2: Average Annual EPA Burden and 

Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in burden hours and costs for both the respondents and 

the Agency as currently identified in the OMB Inventory of Approved Burdens. It should be 

noted that the increase is not due to any program changes. The increase is due to an adjustment 

in labor rates and in the number of new or modified sources. This ICR uses updated labor rates 

from the Bureau of Labor Statistics to calculate burden costs. Additionally, this ICR assumes the 

respondent universe subject to the regulation has continued to grow at a constant rate since the 

last ICR renewal.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 41 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 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 
13

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2012-0524 An electronic version of the public docket is 

available at http://www.regulations.gov/, which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2012-0524 and OMB Control Number 2060-0582 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
14

Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart 

KKKK)(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 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(F=Ex0.05)

(G) 

Clerical 

person 

hours per 

year 

(G=Ex0.1)

(H) 

Total Cost per 

year, $ b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

A. Familiarization with Regulatory 

Requirements c 4 1 4 589 2,356 117.8 235.6 $272,460.80 

B. Required activities

 - Performance test d12 1 12 199 2,388 119.4 238.8 $276,161.45 

 - Fuel sampling – dual fuel turbines 

e 0.5 52 26 106 2,756 137.8 275.6 $318,719 

 - Fuel sampling – distillate oil only 

turbines f 0.5 5 2.5 7 17.5 0.88 1.75 $2,023.80 

C. Gather existing information See 3D

D. Write report 

 Notification of construction/ 

reconstruction g, h 2 1 2 47 94 4.7 9.4 $10,870.68 

 Notification of actual startup g, h 2 1 2 47 94 4.7 9.4 $10,870.68 

 Notification of performance test g2 1 2 199 398 19.9 39.8 $46,026.91 

 Notification of demonstration of 

CEMS i 2 1 2 15 30 1.5 3 $3,469.37 

 Initial notification of complianceg, h 2 1 2 47 94 4.7 9.4 $10,870.68 

 Compliance report j, k 8 2 16 542 8,672 433.6 867.2 $1,002,877.78 
15

Subtotal for Reporting Requirements 19,434 $1,954,351

4. Recordkeeping requirements

A. Familiarization with Regulatory 

Requirement c See 3A

B. Train personnel h40 1 40 47 1,880 94 188 $217,413.54 

C. Continuous monitoring

 - Record information k, l 5 12 60 542 32,520 1,626 3,252 $3,760,791.66 

Subtotal for Recordkeeping 

Requirements 39,560 $3,978,205

TOTAL LABOR BURDEN AND 

COST (rounded)m 59,000 $5,930,000 

Capital and O&M Cost $0 

Grand Total $5,930,000 

Assumptions:

a

 We have assumed that there is an average of 542 sources currently subject to the regulations and an additional 47 respondents per year will become subject. It was established that 

there will be about 355 new stationary combustion turbines installed in the United States over the first five years of rule implementation. The ICR for the initial rule assumed 71 

new sources for the first three years, and the most recent ICR assumed a growth of 47 new sources per year. This ICR assumes the industry continues to grow at a constant rate 

since the previous renewal. 

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for 

Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, 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 it will take 4 hours for respondents to familiarize with regulatory requirements and that all sources will have to familiarize with requlatory requirements.

d

 We have assumed that 199 respondents will each take 12 hours to conduct annual stack testing to demonstrate compliance with NOx emission limitation.

e

 We have assumed that 106 respondents will each take 0.5 hours at 52 times per year to complete fuel sampling for the dual fuel turbines.

f We have assumed that seven respondent will each take 0.5 hours 5 times per year to complete the fuel sampling for the distillate oil only turbines.

g

 We have assumed that it will take each respondent 2 hours to write notification report.

h

 We have assumed that this is a one-time report for new respondents.

i

 We have assumed that of the 47 new respondents each year, 15 of these respondents will write reports demonstrating CEMS compliance.

j

 We have assumed that each of the respondents will take 8 hours twice per year to write the compliance report.

k

 The average number of existing respondents is 542.

l

 We have assumed that it will take each respondent 5 hours twelve times per year to record information.

m

 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
16

Table 2: Average Annual EPA Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart 

KKKK)(Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours 

per plant 

per year 

(C=AxB)

(D) 

Plants 

per 

year 

a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

personhours per 

year 

(F=Ex0.05)

(G) 

Clerical 

personhours per 

year 

(G=Ex0.1)

(H) 

Cost, $ b

Report Review

1. Notification of 

construction/reconstruction c 1 1 1 47 47 2.35 4.7 $2,459.98 

2. Notification of actual startup d0.5 1 0.5 47 23.5 1.18 2.35 $1,229.99 

3. Notification of performance test 2 1 2 199 398 19.9 39.8 $20,831.32

4. Notification of demonstration of CEMS e2 1 2 15 30 1.5 3 $1,570.20 

5. Initial notification of compliance 2 1 2 47 94 4.7 9.4 $4,919.96 

6. Compliance report f2 1 2 542 1,084 54.2 108.4 $56,736.56

TOTAL ANNUAL BURDEN AND 

COST (rounded)g 1,930 $87,700 

Assumptions:

a

 We have assumed that there is an average of 542 sources currently subject to the regulations and an additional 47 respondents per year will become subject. The ICR assumes the 

industry continues to grow at a constant rate after the rule has been fully implemented.

b

 This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for Managerial, $46.67 for 

Technical, and $25.25 Clerical. These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality rates of pay.

c

 We have assumed that each respondent will take one hour each to review the notification of construction/reconstruction report.

d

 We have assumed that it will take 0.5 hours for each respondent to review the actual startup report.

e

 We have assumed that of the 47 new respondents, only 15 of these respondents will review the notification of demonstration of CEMS report.

f

 We have assumed that it will take 2 hours once per year to review the compliance report.

g

 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.