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, 
2

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 
3

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 
4

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 
5

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
6

40 CFR part 63, subpart PPPPP SIC Codes NAICS Codes

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 
7

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.
8

(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.
9

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.
10

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 
11

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:
12

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 
13

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 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 

personhours 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 c4 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 d4 2 8 18 144 7.2 14.4 $15,638.68

 Performance evaluation report e16 1 16 2 32 1.6 3.2 $3,475.26

 Deviation report f16 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, j330 1 330 0.4 132 6.6 13.2 $14,335.46

 D. Maintain records of CEMS performance k1.5 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 
15

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.
16

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

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

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

2. Repeat performance evaluation

a. Retesting preparation 12 1 12 0 0 0 0 $0

b. Attend retesting 32 1 32 0 0 0 0 $0

3. Deviation – enforcement activities c16 1 16 3.6 57.6 2.88 5.76 $2,985.10

4. Reporting requirements

a. Review regulation 2 2 4 0 0 0 0 $0

b. Review waivers 2 2 4 0 0 0 0 $0

c. 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 f2 1 2 18 36 1.8 3.6 $1,865.69

 Deviation report g2 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.