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 1967.04, OMB Control Number 2060-0540

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) (40 CFR 

part 63, subpart YYYY) were proposed on January 14, 2003, and promulgated on March 5, 

2004. In addition, the standard was amended on August 18, 2004, to stay the effectiveness of 

two subcategories of turbines: 1) lean pre-mix gas-fired turbines; and 2) diffusion flame gas-fired 

turbines. These regulations apply to new sources that commenced construction or reconstruction 

after the date of the final rule. 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 United 

States Environmental Protection Agency (EPA) regional office.

There is an average of one affected facilities at each plant site and that each plant site has 

only one respondent (i.e., the owner/operator of the plant site). Over the next three years, an 

average of 22 respondents per year will be subject to the standard, and 9 additional respondents 

per year will become subject to the standard.

The previous Information Collection Request (ICR) had the following Terms of 

Clearance (TOC):

The assumptions used to calculate burden and cost for industry and 

the agency need to be updated before resubmitting it for approval.
2

EPA addressed the TOC by updating respondent assumptions using September 2009 

labor rates from the United States Department of Labor, Bureau of Labor Statistics. Agency

assumptions were updated using the Office of Personnel Management (OPM), 2010 General 

Schedule for Agency labor. Respondent and Agency cost assumptions are provided in Sections 

6(b)(i) and 6(c) of this document. 

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 Federal employees or government contractors. This burden may be found below 

in Table 2: Annual Burden and Cost for the Federal Government: NESHAP for Stationary

Combustion Turbines (40 CFR part 63, subpart YYYY) (Renewal).

Compliance with the subject standard includes the option of electronic reporting to the 

extent practicable. Respondents may report to the appropriate authority electronically if they 

choose to do so. Also, regulatory agencies in cooperation with the respondents, continue to 

create reporting systems to transmit data electronically.

Some respondents are using monitoring equipment at the affected facilities that 

automatically records monitoring 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. 

At this point in time, electronic reporting systems have not been widely adopted by the 

respondents. A majority of the respondents prefer to send written reports to the regulating entity. 

At this time, it is estimated that approximately 10 percent of the respondents use electronic 

reporting.

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 
3

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, formaldehyde emissions from the combustion of oil 

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 YYYY.

2(b) Practical Utility/Users of the Data

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 standards. Continuous emission monitors are used to 

ensure compliance with the standards at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor. 

The notifications required in the standards are used to inform the Agency or delegated 

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

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

installed and operated and the standards are being met. The performance test may also be 

observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

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

The requested recordkeeping and reporting are required under 40 CFR part 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, no 

duplication exists.
4

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 (74 FR 38004) on July 30, 2009. 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 Air Facility System (AFS) which is operated and 

maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, 

maintenance, and retrieval of all compliance data. The growth rate for the industry was based on 

our consultations with the Agency’s internal industry experts. Approximately 31 respondents 

will be subject to the standard over the three-year period covered by this ICR.

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.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR part 1320, section 1320.5.

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 five 

years. In addition, 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 (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. Stationary combustion turbines are used in more 

than 34 different industry and government sectors. However, the majority of the sources covered 

by Subpart YYYY fall into five Standard Industrial code (SIC) and North American Industry

Classification System (NAICS) code categories listed in the table below.

Standard SIC NAICS

40 CFR part 63, subpart YYYY 49, 46, 13, 28, 29 221, 486, 211, 325, 324

4(b) Information Requested

(i) Data Items

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

Stationary Combustion Turbines (40 CFR part 63, subpart YYYY).

A source must make the following reports:

Notifications

Initial Notification for Gas-Fired Turbines 63.6095(d)

Notification of Construction/Reconstruction. 63.6145

Notification of Actual Startup. 63.9(b)
6

Notifications

Notification of Performance Test. 63.7(b)(1), 

63.6145(e)

Notification of Compliance Status 63.(h)(2)(ii), 

63.6145(f)

Reports

Performance Test Plan 63.7(c)

Semi-annual Compliance Report. 63.6150(a)

A source must keep the following records:

Recordkeeping

Maintain records of monitoring data. 63.6155

Maintain records for five years. 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.
7

Respondent Activities

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

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

Transmit, or otherwise disclose the information.

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

Management

5(a) Agency Activities

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

storage, and distribution of the required information.

Agency Activities

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

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS).

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. 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 the AFS which is operated and 

maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, 

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

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

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

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

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

years.

5(c) Small Entity Flexibility

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

of small entities potentially affected by this rule could not be determined based on review of 
8

available rule documentation. 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 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. Where 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 435 hours ( Total Labor Hours from Table 1). The 

recordkeeping hours shown below in Table 1 are 255. The reporting requirement hours shown

below in Table 1 are 180. These hours are based on Agency studies and background documents 

from the development of the regulation, Agency knowledge and experience with the NESHAP 

program, the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $114.49 ($54.52 + 110%) 

Technical $98.20 ($46.76 + 110%)

Clerical $48.53 ($23.11 + 110%)

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

September 2009, Table 2. Civilian Workers, by Occupational and Industry group. The rates are 
9

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 standards 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 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

(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)

Catalyst Inlet 

Temperature $500.00 3 $1,500.00 0 17.5 0

The total capital/startup costs for this ICR are $1,500. This is the total of column D in the 

above table. There are no annual operation and maintenance (O&M) costs associated with this 

standard. We expect the catalyst inlet temperature monitor to be maintenance free.

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 $1,500.

6(c) Estimating Agency Burden and Cost

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

information. The EPA compliance and enforcement program includes activities such as the 

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

emissions, and the publication and distribution of collected information. 

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

$11,920. 

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) 2010 General Schedule which 
10

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: Annual Burden and Cost for the Federal Government: 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

13 existing respondents will be subject to the standard. It is estimated that an additional 9 

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

in the table below is 31 per year.

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

years covered by this ICR. 

Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any 

Reports

Year

(A)

Number of 

New

Respondents 1

(B)

Number of 

Existing 

Respondents2

(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 9 13 0 0 22

2 9 22 0 0 31

3 9 31 0 0 40

Average 9 22 0 0 31

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

estimate that six (6) of the nine (9) sources will be gas fired turbines and the remaining three (3) will be oil fired 

turbines. Gas-fired turbines are only subject to a one-time initial notification requirement. 

2 Although there are a number of gas-fired turbines that previously submitted one-time initial notifications 

during the pervious ICR period, they have no additional compliance responsibilities, including recordkeeping and 

reporting, over the next three years. Therefore, they are not included as respondents for the purpose of this ICR.

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 31. The total number 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Initial Notification 6 1 0 6

Notification of Construction 3 1 0 3

Notification of Startup 3 1 0 3

Performance Test Notification 3 1 0 3
11

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 Compliance 3 1 0 3

Semi-Annual Compliance Report 17.512 0 35

Total 53

1 We estimate that there are 13 existing sources currently subject to subpart YYYY. We also estimate that 

three (3) new sources will come on-line each year that will be required to submit semiannual compliance reports. 

Therefore, the average number of respondents submitting semiannual compliance reports over the next three years is 

estimated to be 17.5 (13 existing + 4.5 new sources). The average of 4.5 new sources over the next three years was 

estimated by dividing the total number of new sources over the next three years (9) by two (2).

The number of Total Annual Responses is 53. The total annual labor costs are $41,152. 

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).

The total annual capital/startup and O&M costs to the regulated entities are $1,500. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

The average annual Agency burden and cost over next three years is estimated to be 265 

labor hours at a cost of $11,920. See below Table 2: Annual Burden and Cost for the Federal 

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

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 435. 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 8 (rounded) 

hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,500. 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 265 
12

labor hours at a cost of $11,920. See below Table 2: Annual Burden and Cost for the Federal 

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

(Renewal).

6(f) Reasons for Change in Burden

There is no change in the labor hours to respondents in this ICR compared to the previous 

ICR. This is due to two considerations: 1) the regulations have not changed over the past three 

years and are not anticipated to change over the next three years; and 2) the growth rate for the 

industry is very low, negative or non-existent. Therefore, the labor hours in the previous ICR 

reflect the current burden to the respondents and are reiterated in this ICR. 

The increase in cost to the respondents and the Agency is due to labor rate adjustments to 

reflect the most recent available estimates. 

6(g) Burden Statement

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

is estimated to average 8 hours (rounded) 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’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-2009-0544. 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 Avenue, N.W., Washington, D.C. 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 
13

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

Street, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the 

EPA Docket ID Number EPA-HQ-OECA-2009-0544 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.
14

TABLE 1: ANNUAL RESPONDENT BURDEN AND COST: NESHAP FOR STATIONARY COMBUSTION TURBINES (40 CFR PART 63, SUBPART YYYY)

A B C D E F G H I

Reporting/Recordkeeping Requirements

Hours/

Occurrence

Occurrences/

Year

Hours/Year

(C = A x B)

Respondents/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year

 a

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions

b

4 1 4 9 36 1.80 3.60 41.40 3,919.23

B. Required Activities 

c

12 1 12 3 36 1.80 3.60 41.40 3,919.23

Performance Tests

C. Create Information Included in 3B

D. Gather Existing Information Included in 3B

E. Write Report

Notification of Gas-Fired Turbines

 d 2 1 2 6 12 0.60 1.20 13.80 1,306.41

Notification of Construction/Reconstruction

 d 2 1 2 3 6 0.30 0.60 6.90 653.21

Notification of Initial Performance Test d 2 1 2 3 6 0.30 0.60 6.90 653.21

Notification of Actual Startup

 d 2 1 2 3 6 0.30 0.60 6.90 653.21

Notification of Compliance Status

 d 2 1 2 3 6 0.30 0.60 6.90 653.21

Semi-Annual Compliance Report e 8 2 16 3 48 2.40 4.80 55.20 5,225.64

Reporting Subtotal 180 16,983

4. Recordkeeping Requirements

A. Read Instructions Included in 3A

B. Plan Activities Included in 3B

C. Implement Activities Included in 3B

D. Time to Enter Information

Purchase and Install Catalyst Inlet Temperature Monitor 30 1 30 3 90 4.50 9.00 103.50 9,798.08

Records of Operating Parameters e0.5 12 6 22 132 6.60 13.20 151.80 14,370.51

F. Train Personnel N/A

G. Audits N/A

Recordkeeping Subtotal 255 24,169

TOTAL ANNUAL BURDEN 435 41,152

Assumptions:

a)This ICR uses the following labor rates: Managerial $114.49 ($54.52 + 110%); Technical $98.20 ($46.76 + 110%); and Clerical $48.53 ($23.11 + 110%). These rates are from 

the United States Department of Labor, Bureau of Labor Statistics, March 2009, 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. This ICR assumes that 

Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.

b) It is assumed that four hours are required to read instructions.

c) It is assumed that 12 hours are required to complete the performance test.

d) It is assumed that two hours are required to prepare each notification.

d) It is assumed that eight hours are required to prepare semi-annual compliance report.

e) It is assumed that one half-hour is required to record operating parameters.
15

TABLE 2: ANNUAL BURDEN AND COST FOR THE FEDERAL GOVERNMENT: NESHAP FOR STATIONARY COMBUSTION TURBINES (40 CFR PART 63, SUBPART YYYY)

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Activity

EPA

Hours/

Occurrence

Occurrences/

Plant/Year

EPA

Hours/Year

(C=A*B)

Plants/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year a

Report Review b

New or Reconstructed

Review Initial Notification for Gas-Fired Turbines c, d 2 1 2 6 12 0.60 1.20 13.80 621.89

Review Notification of Construction/Reconstruction c, e 2 1 2 3 6 0.30 0.60 6.90 310.95

Review Notification of Actual Startup c 2 1 2 3 6 0.30 0.60 6.90 310.95

Notification of Initial Performance Test c 2 1 2 3 6 0.30 0.60 6.90 310.95

Review Performance Test Results f 8 1 8 3 24 1.20 2.40 27.60 1243.79

Review Semi-Annual Compliance Reports g, h 8 1 8 22 176 8.80 17.60 202.40 9121.11

Report Review Subtotal 265 11,920

TOTAL ANNUAL BURDEN 265 11,920

Assumptions:

a)This ICR uses the following labor rates: Managerial $62.27 (GS-13, Step 5, $38.92 + 60%); Technical $46.21 (GS-12, Step 1, $28.88 + 60%); and Clerical $25.01 (GS-6, Step 3, 

$15.63 + 60%). These rates are from the Office of Personnel Management (OPM), 2010 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. This ICR assumes that Clerical hours are 10 percent of Technical hours and Managerial 

hours are 5 percent of Technical hours.

b) It is assumed that there will be nine new or reconstructed turbines per year.

c) It is assumed that two hours are required to review each notification.

d) It is assumed that six new gas-fired turbines will be added per year.

e) It is assumed that three new oil-fired turbines will be added per year.

f) It is assumed that eight hours are required to review each performance test report.

g) It is assumed that eight hours are required to review each semi-annual compliance report.

h) It is assumed that the average number of existing sources is 22.