SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart YYYY) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart YYYY) 

(Renewal), EPA ICR Number 1967.05, OMB Control Number 2060-0540

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary

Combustion Turbines (40 CFR part 63, subpart YYYY) were proposed on January 14, 2003, 

promulgated on March 5, 2004, and was last amended on April 20, 2006. The regulations apply 

to new sources that commenced construction or reconstruction after January 14, 2003. The 

regulations do not apply to existing sources. On August 18, 2004, these standards were amended 

to stay the effectiveness for the two gas-fired stationary combustion turbine subcategories (i.e., 

lean pre-mix gas-fired turbines and diffusion flame gas-fired turbines). Under this stay, new 

sources in either subcategory that are constructed or reconstructed after January 14, 2003 are 

required to submit initial notifications, but are relieved of the obligation to comply with other

reporting or monitoring requirements until EPA makes a final decision. This information is 

being collected to assure compliance with 40 CFR part 63, subpart YYYY.

In general, all NESHAP 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 NESHAP.

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

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. 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 U.S.

Environmental Protection Agency (EPA) regional office.

There is an average of one 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 average of 96 respondents per year will be subject to these

standards, and 8.7 additional respondents per year will become subject to the standard. The 
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number of existing respondents are comprised of 66.2 gas-fired, 2.9 landfill/digester gas-fired, 

and 26.9 oil-fired stationary combustion turbines. The number of new respondents are 

comprised of 6 gas-fired, 0.3 landfill/digester gas-fired, and 2.4 oil-fired stationary combustion 

turbines. 

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

without any “Terms of Clearance.”

The “Affected Public” are owners or operators of stationary combustion turbines. 

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden 

and Cost – NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart YYYY) 

(Renewal). The burden to the Federal Government is attributed entirely to work performed by

either Federal employees or government contractors, and may be found below in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Stationary Combustion Turbines (40 

CFR Part 63, Subpart YYYY) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, hazardous air pollutants (HAP) emissions from the 

combustion of gaseous and liquid fuels either cause or contribute to air pollution that may

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

were promulgated for this source category at 40 CFR part 63, subpart YYYY.

2(b) Practical Utility/Users of the Data
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The recordkeeping and reporting requirements in the standard ensures compliance with 

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

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

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

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

ensure compliance with the standard at all times. 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 the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated and if the standard is being met. The performance test may also be 

observed.

The required annual or 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 63, subpart 

YYYY.

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 (77 FR 63813) on October 17, 2012. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations
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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. 

Consultations with industry representatives (i.e., respondents) were conducted to 

determine if there is any way for EPA to reduce the recordkeeping and reporting burden or 

improve the language in the standard to make it easier to comply. In developing this ICR, the 

EPA contacted: 1) the Gas Turbine Association, at (202) 488-0101; and 2) the American Fuel & 

Petrochemical Manufacturers, at (202) 552-8461. EPA did not receive any comments from the 

consultations.

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

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 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 

these standards. EPA believes that the five-year records retention requirement is consistent with 

the Part 70 permit program and the five-year statute of limitations on which the permit program 

is based. The retention of records for five years allows EPA to establish the compliance history 

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality
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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

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 owners and/or 

operators of stationary combustion turbines. The United States Standard Industrial Classification 

(SIC) codes and the corresponding North American Industry Classification System (NAICS) 

codes for stationary combustion turbines are provided in the following table.

Standard (40 CFR Part 63, Subpart YYYY) SIC Codes NAICS Codes

Utilities 49 221

Pipeline Transportation 46 486

Oil and Gas Extraction 13 211

Chemical Manufacturing 28 325

Petroleum and Coal Products Manufacturing 29 324

 

4(b) Information Requested

(i) Data Items

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

Stationary Combustion Turbines (40 CFR part 63, subpart YYYY). Note that due to an on-going 

stay of standards for gas-fired subcategories, respondents in the lean premix and diffusion flame 

gas-fired stationary combustion turbine subcategories are only required to comply with the initial 

notification requirements shown below. These subcategories do not need to comply with the 

reporting or monitoring requirements until EPA takes final action.

A source must make the following reports:
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Notifications

Gas-Fired Stationary Combustion Turbine Subcategories

Initial notification 63.6095(d), 63.6145(b-c), 63.9(b)

Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory

Initial notification 63.6090(b), 63.6145(d)

Oil-Fired Stationary Combustion Turbine Subcategories

Initial notification 63.6145, 63.9(b)

Notification of construction/reconstruction 63.6095(d), 63.6145, 63.5, 

63.9(b)(5)(i)

Notification of actual startup date 63.6095(d), 63.6145, 

63.9(b)(5)(ii)

Notification of performance test 63.7(b)(1), 63.7(c), 63.9(e), 

63.6145(e)

Notification of CMS performance evaluation 63.8(e), 63.9(g)(1), 63.6145(a)

Notification of compliance status 63.9(h), 63.7, 63.8(e), 

63.10(d)(2), 63.10(e)(2), 

63.6145(a), 63.6145(f)

Reports

Gas-Fired Stationary Combustion Turbine Subcategories

No reporting requirements due to on-going stay for this subcategory.

Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory

Annual compliance report 63.6090(b)(2), 

63.6150(c)

Oil-Fired Stationary Combustion Turbine Subcategories

Excess emissions and parameter exceedance reports 63.10(e)(3)

Semiannual compliance reports 63.6150(a)

A source must keep the following records:
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Recordkeeping 

All Subcategories

Maintain records of monitoring data 63.7(g), 63.6155

Maintain records for five years 63.10(b), 63.6160(b)

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 still 

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

use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate the catalyst inlet temperature monitor.

Perform initial performance test, Reference Method 320 test, 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.
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Respondent Activities

Train personnel to be able to respond to a collection of information.

Transmit or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system). Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

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 OTIS. 

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 standard, and to 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. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

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

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 
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EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

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

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. During rule development, EPA conducted a regulatory impact 

analysis and concluded that the rule does not have a significant economic impact on small 

entities. Furthermore, EPA determined that any potential impacts are further reduced by the 

rule’s exclusion of turbines with capacities below 1.0 megawatt.

Due to technical considerations, which involve 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 in below Table 1: Annual Respondent Burden and Cost – NESHAP for Stationary

Combustion Turbines (40 CFR Part 63, Subpart YYYY) (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 1,338 hours (Total Labor Hours from Table 1

below). 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.
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6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $122.49 ($58.33 + 110%) 

Technical $101.28 ($48.23 + 110%)

Clerical $50.80 ($24.19 + 110%)

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

September 2012, “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 (O&M) costs 

are the ongoing costs to maintain the monitors and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent a

(C)

Number of 

New

Respondents

b

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent c

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Catalyst inlet 

temperature

$4,479 2.4 $10,750 0 29.3 0

a

 We estimate a total capital startup cost of $4,479 per respondent, which comprises a purchase cost of $500 and an 

installation cost of $3,979. The installation cost assumes 30 technical, 1.5 managerial, and 3 clerical hours at a labor 

rate of $122.49, $101.28, and $50.80, respectively. As described previously, these rates are based on figures from the 

United States Department of Labor and have been increased by 110 percent to account for private industry benefit 

packages.

b

 At present, only oil-fired subcategories are required to install, operate, and maintain continuous monitoring devices. 

This subcategory comprises 26.9 existing respondents and 2.4 new respondents.

c

 No annual O&M costs are shown because we expect the catalyst inlet temperature monitor to be maintenance-free.

The total capital/startup costs for this ICR are $10,750 (rounded). This is the total of 

column D in the above table. 
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The total O&M costs for this ICR are $0. 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 $10,750.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

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

$27,643.

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), 2012 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 – NESHAP for 

Stationary Combustion Turbines (40 CFR Part 63, Subpart YYYY) (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

96 existing respondents will be subject to the standard. It is estimated that an additional 8.7 

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

in the table below, is 105 (rounded) respondents per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
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Number of Respondents

Year

(A)

Number of New 

Respondents a

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports b

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

Gas-Fired Stationary Combustion Turbine Subcategories

1 6 0 60.2 0 66.2

2 6 0 66.2 0 72.2

3 6 0 72.2 0 78.2

Average 6 0 66.2 0 72.2

Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory

1 0.3 2.6 0 0 2.9

2 0.3 2.9 0 0 3.2

3 0.3 3.2 0 0 3.5

Average 0.3 2.9 3.2

Oil-Fired Stationary Combustion Turbine Subcategories

1 2.4 24.5 0 0 26.9

2 2.4 26.9 0 0 29.3

3 2.4 29.3 0 0 31.7

Average 2.4 26.9 29.3

TOTAL 8.7 29.7 66.2 0 104.7

a

 New respondents include sources with affected facilities constructed or reconstructed after January 14, 2003.

b

 Due to the ongoing stay of the NESHAP, existing gas-fired sources that have previously submitted initial 

notifications are not subject to any additional monitoring or reporting requirements. For this reason, we have 

accounted for them in Column C.

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 105 (rounded).

The total number of annual responses per year is calculated using the following table:

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondentsa 

(C)

Number 

of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual 

Responses 

E=(BxC)+D

Gas-Fired Stationary Combustion Turbine Subcategories

Initial notification 6 1 0 6

Subtotal 6

Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory

Initial notification 0.3 1 0 0.3
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Total Annual Responses

Annual compliance reportb2.9 1 0 2.9

Subtotal 3.2

Oil-Fired Stationary Combustion Turbine Subcategories

Initial notification 2.4 1 0 2.4

Notification of construction/reconstruction 2.4 1 0 2.4

Notification of actual startup 2.4 1 0 2.4

Notification of performance test 2.4 1 0 2.4

Notification of CMS performance evaluation 2.4 1 0 2.4

Notification of compliance status 2.4 1 0 2.4

Semiannual compliance reportc26.9 2 0 53.8

Subtotal 68.2

TOTAL 77.4

a

 We estimate 6 gas-fired, 0.3 landfill/digester gas-fired, and 2.4 oil-fired stationary combustion turbines will become 

subject to the rule over the three-year period of this ICR. We also estimate 66.2 gas-fired, 2.9 landfill/digester gasfired, and 26.9 oil-fired stationary combustion turbines are currently subject to the rule. Note that due to the ongoing 

stay, existing gas-fired sources that have previously submitted initial notifications are not subject to any additional 

monitoring or reporting requirements.

b

 This activity applies to new and existing sources (i.e., 3.2 sources comprising 2.9 existing sources and 0.3 new

sources).

c

 This activity applies to new and existing sources (i.e., 29.3 sources comprising 26.9 existing sources and 2.4 new

sources).

The number of Total Annual Responses is 77 (rounded).

The total annual labor costs are $154,306. Details regarding these estimates may be 

found below in Table 1: NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart 

YYYY) (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 are summarized below. 

(i) Respondent Tally

The total annual labor hours are 1,338 hours at a cost of $154,306. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost –

NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart YYYY) (Renewal). 

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

of information is estimated to average 17 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $10,750. 
14

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 613

labor hours at a cost of $27,643. See below Table 2: Average Annual EPA Burden and Cost –

NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart YYYY) (Renewal).

6(f) Reasons for Change in Burden

There is an increase of 903 hours in the total estimated respondent burden compared with 

the ICR currently approved by OMB. This increase is due to several adjustments. 

First, we have revised the number of respondents to make ICR estimates consistent with 

the economic impact analysis, which contains the most recent information on existing and new 

sources. Based on the analysis, an average of 96 existing and 8.7 new sources per year will be 

subject to the standard. In contrast, the most recently approved ICR estimated 22 existing and 

9 new sources per year, and did not provide a clear basis for its estimates and underlying 

assumptions. The increase in labor burden and cost for both respondents and the Agency is 

primarily due to the revised number of sources, particularly existing sources which accounts 

for industry growth.

Second, we have revised respondent and Agency labor burdens and costs so that 

they accurately reflect the reporting and recordkeeping requirements associated with each 

subcategory. The previous ICR only reflected burdens attributed to new sources in the gas-fired 

and oil-fired subcategories, and did not account for any sources in the landfill/digester gas-fired 

subcategory. Specific revisions that contributed to overall burden increases include: 

 Adding a burden item for initial CMS performance evaluations for new sources in the 

oil-fired subcategory. The previous ICR did not account for this burden.

 Adding a burden item for annual compliance reporting for new sources in the 

landfill/digester gas-fired subcategory. The previous ICR did not account for this 

burden.

 Correcting the semiannual compliance reporting burden to include burden to existing 

sources. 

 Adding an Agency burden item for compliance status notification review. The 

previous ICR presented a respondent burden for this activity, but neglected to include 

a corresponding Agency review burden.

Finally, there is an increase in the capital/startup cost as compared to the previous ICR. 

This increase is the result of including contractor labor associated with catalyst inlet temperature 

monitor installation. This labor was presented in the previous ICR as a respondent burden rather 

than a capital cost. Since the contractor labor applies solely to a capital/startup activity, it should 
15

be presented as a capital/startup cost rather than a respondent burden. We also have updated the 

labor rates to reflect current private-industry rates.

6(g) Burden Statement

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

is estimated to average 17 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 

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

Docket ID Number EPA-HQ-OECA-2012-0687. 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), EPA 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-2012-0687 and OMB Control Number 2060-0540 in any

correspondence. 

Part B of the Supporting Statement

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

information.
16

Table 1: Annual Respondent Burden and Cost – NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart

 YYYY) (Renewal)

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(C=AxB)

Respondents 

per year a

Technical 

hours

per year

(E=CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year b

($)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions c4 1 4 8.7 34.8 1.74 3.48 $4,615.66 

B. Required Activities

Initial CMS performance evaluation d12 1 12 2.4 28.8 1.44 2.88 $3,819.86 

Performance test e12 1 12 2.4 28.8 1.44 2.88 $3,819.86 

C. Create Information See 3B

D. Gather Existing Information See 3B

E. Write Report

Initial notification f2 1 2 8.7 17.4 0.87 1.74 $2,307.83 

Notification of 

construction/reconstruction g2 1 2 2.4 4.8 0.24 0.48 $636.64 

Notification of actual startup g2 1 2 2.4 4.8 0.24 0.48 $636.64 

Notification of performance test g2 1 2 2.4 4.8 0.24 0.48 $636.64 

Notification of CMS performance 

evaluation g2 1 2 2.4 4.8 0.24 0.48 $636.64 

Notification of compliance status g2 1 2 2.4 4.8 0.24 0.48 $636.64 

Annual compliance report h8 1 8 2.9 23.2 1.16 2.32 $3,077.11 

Semiannual compliance reports i8 2 16 26.9 430.4 21.52 43.04 $57,085.67

 Subtotal for Reporting Requirements 675.51 $77,909.19

4. Recordkeeping Requirements

A. Read Instructions See 3A

B. Plan Activities See 3B
17

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(C=AxB)

Respondents 

per year a

Technical 

hours

per year

(E=CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year b

($)

C. Implement Activities See 3B

D. Time to Enter Information

Records of operating parameters j0.5 12 6 96 576 28.8 57.6 $76,397.18 

F. Train Personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 662.4 $76,397.18

TOTAN ANNUAL BURDEN AND COST (rounded) 1,338 $154,306

Assumptions:

a.

 We estimate 8.7 new sources, comprising 6 gas-fired, 0.3 landfill/digester gas-fired, and 2.4 oil-fired stationary combustion turbines, will become subject to the 

rule over the three-year period of this ICR. We also estimate 96 existing sources are subject, comprising 66.2 gas-fired, 2.9 landfill/digester gas-fired, and 26.9 

oil-fired stationary combustion turbines. Note that due to the ongoing stay, existing gas-fired sources that have previously submitted initial notifications are 

not subject to any additional monitoring or reporting requirements.

b.

 This ICR uses the following labor rates: $101.28 for technical, $122.49 for managerial, and $50.80 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, September 2012, “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 private industry employees.

c.

 We assume four hours are required to read instructions. This activity applies to new sources in all subcategories (i.e., 8.7 new sources comprising 6 gas-fired, 

2.4 oil-fired, and 0.3 landfill/digester gas-fired turbines).

d.

 We assume 12 hours are required to complete the CMS performance evaluation. This activity only applies to new sources in the oil-fired turbine subcategories 

(i.e., 2.4 oil-fired turbines).

e.

 We assume 12 hours are required to complete the performance test. This activity only applies to new sources in the oil-fired turbine subcategories (i.e., 2.4 oilfired turbines).

f.

 We assume two hours are required to prepare each notification. This activity applies to new sources in all subcategories (i.e., 8.7 new sources comprising 6 gasfired, 2.4 oil-fired, and 0.3 landfill/digester gas-fired turbines).

g.

 We assume two hours are required to prepare each notification. These activities only apply to new sources in the oil-fired turbine subcategories (i.e., 2.4 oilfired turbines).

h.

 We assume eight hours are required to prepare annual compliance reports. This activity only applies to existing sources in the landfill/digester gas-fired turbine 

subcategory (2.9 existing sources).

i.

 We assume eight hours are required to prepare semiannual compliance reports. This activity only applies to existing sources in the oil-fired turbine 

subcategories (26.9 existing sources).
18

j.

 We assume one half-hour is required to record operating parameters. This activity applies to existing sources in all subcategories (i.e., 96 existing sources 

comprising 26.9 oil-fired, 66.2 gas-fired, and 2.9 landfill/digester gas-fired turbines).
19

Table 2: Average Annual EPA Burden and Cost – NESHAP for Stationary Combustion Turbines (40 CFR Part 63, Subpart

 YYYY) (Renewal)

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)a

Respondents 

per year

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year b

($)

Report Review

Initial notification c2 1 2 8.7 17.4 0.87 1.74 $901.75

Notification of construction/reconstruction d2 1 2 2.4 4.8 0.24 0.48 $248.76

Notification of actual startup d2 1 2 2.4 4.8 0.24 0.48 $248.76

Notification of performance test d2 1 2 2.4 4.8 0.24 0.48 $248.76

Notification of CMS performance evaluation d2 1 2 2.4 4.8 0.24 0.48 $248.76

Notification of compliance status e18 1 18 2.4 43.2 2.16 4.32 $2,238.82

Annual compliance report f8 1 8 2.9 23.2 1.16 2.32 $1,202.33

Semiannual compliance reports g8 2 16 26.9 430.4 21.52 43.04 $22,305.26

TOTAL ANNUAL BURDEN AND COST (rounded) 613 $27,643

Assumptions:

a.

 We estimate 8.7 new sources, comprising 6 gas-fired, 0.3 landfill/digester gas-fired, and 2.4 oil-fired stationary combustion turbines, will become subject to the 

rule over the three-year period of this ICR. We also estimate 96 existing sources are subject, comprising 66.2 gas-fired, 2.9 landfill/digester gas-fired, and 26.9 

oil-fired stationary combustion turbines. Note that due to the ongoing stay, existing gas-fired sources that have previously submitted initial notifications are 

not subject to any additional monitoring or reporting requirements.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel 

Management (OPM), 2011 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.

c.

 We assume two hours are required to review each initial notification. This activity applies to new sources in all subcategories (i.e., 8.7 new sources comprising 

6 gas-fired, 2.4 oil-fired, and 0.3 landfill/digester gas-fired turbines).

d.

 We assume two hours are required to review each notification. This activity only applies to new sources in the oil-fired turbine subcategories (i.e., 2.4 oil-fired 

turbines).

e.

 We assume that performance test and CMS performance evaluation reports will be submitted for review concurrently with the notification of compliance status, 

and that a total of 16 hours will be required to review each compliance notification (2 hours), performance test report (8 hours), and performance evaluation 

report (8 hours).
20

f. We assume eight hours are required to review each annual compliance report. This activity only applies to existing sources in the landfill/digester gas-fired 

turbine subcategory (2.9 existing sources).

g. We assume eight hours are required to review each semiannual compliance report. This activity only applies to existing sources in the oil-fired turbine 

subcategories (26.9 existing sources).