**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** N SPS for Stationary

Combustion Turbines (40 CFR Part 6 0 , Subpart KKKK) (Renewal), EPA I CR 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 gi gajoules (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 gene ral, 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 an y startup, shutdown, or malfunction in the operat ion of an affected facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS

. Any owner/oper ator 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 l ocal 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 b y privately

- owned, for

profit 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)

. T he Federal Government ’s

“burden ” is attributed entirely to work performed by either F ederal emplo yees 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 6 0, Subpart KKKK) (Renewal)

. Based on our consultations with industry representatives, there is an average of one2

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 ye ars, an approximate average of 589 respondents per year will be subject to the se standard s , and 47 additional respondents per ye ar will become subject to the se same standard s
. The Office of Management and Budget ( OMB ) approved the currentl y active I CR 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 pe rformance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or an y non - air quality health and environmental impact and energy requirements) the Administrat or determines has been adequatel y 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 su ch standards e very 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 moni toring 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 reasonabl y 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 end anger 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 reportin g requirements in the standard s 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 s . Continuous emission monitors are used to ensure compliance with the standard s at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuou s emission monitor. The notifications required in the se standard s are used to inform the Agency or delegated authority when a source becomes subj ect to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated, leaks are being detected and repaired , and that the standard s are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures , and for compliance determinations. **3. Non**
**- duplication,**  **Consultations, and Other Collection Criteria** The requested recordkeeping an d 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y of the report submitted to the st ate 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 I CR 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**
T he Agency

has con sulted i ndustry

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 pro visions in the standard, is the Integrated Compliance Information Sy stem (I CI S). IC IS 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 I CR, 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 f irst Federal Register n otice. In this case, no comments were received. **3(d) Effec ts 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detectin g violations would be less likely

. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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, C hapter 1, P art 2, S ubpart 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

T he 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 ( SI C ) code s for the respondents affected by the standards and their corresponding North American Industry Classification System (NAI CS ) 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 b y the NSPS for Stationary

Combustion Turbines (40 CFR Part 60, Subpart KKKK)

. A source must make the following reports:

**Notification s**  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
**Notification s**  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 sy stems or devices; and all other information required b y this part recorded in a permanent form suitable for inspection. The file shall be retained for at least two ye ars following the date of such measurements, maintenance, reports, and records, except some CEMS sub

- hourly measurements. 60.7(f)

Electronic Reporting Some of the r espondents 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 sy stems for the purpose of collecting, validating, and verif yi ng information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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, analy sis, 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, anal yz e, and maintain data in the Enforcement and Compliance History Online (ECHO) and I CI S.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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s init ial capability to compl y with the emission standard s
. 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.
In formation contained in the reports is reported b y state and local governments in the IC IS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s data

base for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for two ye ars. **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 th is regulation. Due to technical considerations involving the process operations and the typ es 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 furth er 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

– N SPS for Stationary Combustion Turbines (40 CFR Part 6 0 , 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 I CR. 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 con duct 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 thes e recordkeeping and reporting requirement s is estimated to be 59,000 ( Total Labor Hours from Table 1). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NSP S program, the previously approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 9

. 93 ($ 61.87 + 110%) Technical $ 10 3

. 97 ($4 9

. 51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 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 b y 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 b y the subject standard s are labor costs. There are no capital/startup or o peration and maintenance costs involved

.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only t ype of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or o peration and maintenance costs involved

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are th ose costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the pub lication 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 hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 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

– N SPS for Stationary Combustion Tur

bines (40 CFR Part 6 0 , Subpart KKKK) (Renewal) **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 542 existing respondents will be subject to the standard. It is estimated that an additional 47 respondents per ye ar 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 ye ars covered b y this ICR : **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 589

.11

The total number of annual responses per ye ar 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 Com pliance 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

– N SPS for Stationary Combustion Turbines (40 CFR Part 6 0 , 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 6 0 , Subpart KKKK) (Renewal)

. We assume that burdens for managerial tasks take 5% of the time requir ed for technical tasks because the ty

pical 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 ty pical duties of clerical staff are to proofread the reports, m ake 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 ar e $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

– N SPS for Stationary Combustion Turbines (40 CFR Part 6 0 , Subpart KKKK) (Renewal)

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

pical 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 ty pical duties of clerical staff are to proofread the reports, make cop ies 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 I CR 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 b y persons to generate , maintain, retain, or disclo se or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 the13

use of automated collection techniques, EPA has established a public docket for t his I CR under Docket ID Number EPA

- HQ

- OECA

- 201 2

- 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 informat ion, 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 sy stem , select “search,” then key in the docket ID number identi fied 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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 ho**  **urs per respondent**  **per year (C=AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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 d 12 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 g 2 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 compliance g, 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 $1,002,877.7815

**Subtotal for Reporting Requirements 19,434**  **$1,954,351** 4. Recordkeeping requirements A. Familiarization with Regulatory Requirement c See 3A B. Train personnel h 40 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 Cap**  **i tal 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 h our 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 per cent to account for the benefit packages available to those empl oyed by private industry.
c We have assumed that it will take 4 hours for respondents to familiarize with regulatory requirements and that all sources wi ll have to familiarize with r equlatory 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 fo r 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 demon strating 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 exi sting respondents is 542. l We have assumed that it will take each respond ent 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 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)** 

**Man agem**  **ent person**  **** **hours per year**  **(F=Ex0.05) (G)** 

**Clerical person**  **** **hours 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 d 0.5 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 e 2 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 f 2 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 i mplemented. b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government o verhead 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 exclud es locality rates of pay.
c We have assumed that each respondent will take one hour each to review the notification of constructi on/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 demo nstration of CEMS report. f We have assumed that it will take 2 hours once per year to revi ew the compliance report. g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.