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 I CR Number 1967.04, OMB Control Number 2060

- 0540 1(b) Short Characterization/Abstract The National Emission Standards for Hazardous Air Pollutants (NESHAP) ( 40 CFR p art 63, subpart YYYY ) w ere 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 an y startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operato r 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 loc al authority

. In the event that there is no such delegated authority , the reports are sent directl y to the United States Environmental Protection Agency (EPA) regional office. There is an average of one affected facilities at each plant site and that ea ch 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 (I CR) 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

la bor. 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 C FR part 63, subpart YYYY) (Renewal) . The burden to the “Federal government” is attributed entirely to work performed b y Federal employees or government contractors. This burden may be found below in Table 2: Annual Burden and Cost for the Federal Governm ent: 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 elec tronicall y if they choose to do so. Also, regulatory agencies in cooperation with the respondents, continue to create reporting s ys tems to transmit data electronically

. Some respondents are using monitoring equipment at the affected facilities that autom atically

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, ele ctronic reporting s ys tems have not been widel y adopted by the respondents. A majorit y 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 electroni c 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 an d 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 re quire 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 emiss ions (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 control3 equipment parameters, production variables or other indire ct data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, for maldeh yde 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 complian ce 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 requi red 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 properl y inst alled 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 directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Fede ral standards, a cop y 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 I CR 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
T he Agenc y’ s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three y ears have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Air Facility S ys tem (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

- ye ar period covered b y this I CR. 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 f irst Federal Register n otice. In this case, no comments were received. 3(d) Effects of Less Frequent Collection Less freque nt 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 a re applied and emission limitations are met. If the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. 3(e) G eneral Guidelines These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifi cations for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the P art 70 permit program and the five

- ye ar statute of limitati ons on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history5

of a source, an y 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 ye ars. 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 A genc y 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; amend ed 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 In formation 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 majorit y of the sources covered by Subpart YYYY fall into five Standard Industrial code (SIC) and North American Industry Classification Sy stem (NAI CS) code categories listed in the table below.

Standard SIC NAICS 40 CF R 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 b y NESHAP for Stationary

Combustion Turbines (40 CFR p art 63, s ubpart 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 y ears. 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, inter nal 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 s ys tems to transmit data electronicall y. Howeve r, electronic reporting s ys tems 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, calibrat e, maintain, and operate the catal ys t 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 re corded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information.7 Respondent Activities Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. 5. The Information Collected: Agency Activities, Collection Methodology, and Information Management 5(a) Agency Activities EPA conducts the following activities in connection with the acquisition, analy sis, storag e, and distribution of the required information. Agency Activities Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and mai ntain data in the AIRS Facility Subsy stem (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 properl y installed an d operated. Performance test reports are used b y the Agency to discern a source’s initial capability to compl y with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement pr ograms. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the AFS which is operated and maintained by

the EP A 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 b y this regulation must be retained by the owner/operator for five ye ars. 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 of8

available rule documentatio n. 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 ty pes of control equipment employed, the rec ordkeeping 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 Respo ndent 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 re quirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specif ic 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 display s a currently val id 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 recordkeepi ng hours shown below in Table 1 are 255. The reporting requirement hours shown below in Table 1 are 1 80 . These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NE SHAP program, the previously

approved ICR, and any

comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the following labor rates: Managerial $114.49 ($54.52 + 110%) Technical $98.20 ($46.76 + 110%) Clerica l $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 are9

from column 1, “Total compensation.” The rates have been increased b y 110 percent to account for the benefit packages available to those employ ed by private industry

. (ii) Estimating Capital/Startup and Operation and Maintenance Costs The ty pe of industry

costs associated with the information collec tion activities in the subject standards are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. T he 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 Tem perature $500.00 3 $1,500.00 0 17.5 0
The total capital/startup costs for this I CR 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. W e expect the catal ys t 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 IC R is estimated to be $1,500. 6(c) Estimating Agency Bu rden and Cost The only costs to the Agency

are those costs associated with anal ys is of the reported information. The EPA compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic ins pection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three y ears of the ICR is estimated to be $11,920. This cost is based on the average hourl y 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 which10

excludes locali ty

rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to government emplo ye es. Details upon which this estimate is based appear below in Table 2: Annual Burden and Cost for the Federal Government: NE SHAP 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 I CR, on average over the next three ye ars, approximately 13 existing resp ondents will be subject to the standard. It is estimated that an additional 9 respondents per ye ar 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 ye ars covered b y this ICR. Number of Respondents

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A)

Number of New Respondents 1 (B)

Number of Existing Respondents 2 (C)

Num ber 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 responde nts 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

- tim e initial notifications during the pervious ICR period, they have no additional compliance responsibilities, including rec ordkeeping 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 thr ee - ye ar 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 0 311 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 Compli ance 3 1 0 3 Semi

- Annual Compliance Report 17.5 1 2 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 sub mi t 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 Tab le 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 Sectio n 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. The average annual Agency burden and cost over next three y ears is estimated to be 265 labor hours at a cost of $11,920. See below Table 2: Annual Burden and Cost for the Federal Gov ernment: 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 Tab les 1 and 2, respectivel y, 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 re gulated 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 y ears is estimated to be 26512

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 labo r hours to respondents in this I CR compared to the previous ICR. This is due to two considerations: 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three years; and 2) the growth rate for the i ndustry 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 adju stments 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 s ys tems 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 an y 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 re quired to respond to, a collection of information unless it display s 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 a ccuracy 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 I CR under Docket ID Number EPA

- HQ

- OECA

- 2009

- 0544. An e lectronic 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 acce ss those documents in the public docket that are available electronically . When in the sy stem , 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 Compl iance 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 le gal holiday s. 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 the13

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 ap plicable because no statistical methods were used in collecting this information.14

TA BL E 1:A

NNU AL RESPONDENT BU RDEN A

ND COST:NESH

AP FOR STATI ONA RY COMBUSTI ON TU

RBINES ( 40 CFR PA RT 63, SUBPA

RT Y YYY)
A B C D E F G H I

Re po rt ing /Re cordk eep ing Re quire me nt s Hou rs / Occu rre nc e Occu rre nc es/

Ye ar Hou rs /Y

ea r (C = A x B ) Re sp on de nts /

Ye ar Te ch nic al

Hou rs /Y ear (C* D) Ma nag er ial Hou rs /Y ea r (E*0.05) Cle ric al

Hou rs /Y ear (E* 0.10) To tal

Hou rs /Y ear (H =E+F +G

) To tal Cos ts /Y ear a 1. Ap plica

tions N/ A 2. S urv ey

a nd Studie s N/ A 3. Re po rt ing Re quire me nts A. Read Instru cti ons b 4 1 4 9 36 1.80 3. 60 41. 40 3,919. 23 B. Req ui red Activitie s c 12 1 12 3 36 1.80 3. 60 41. 40 3,919. 23 Perfo rm an ce T ests C. Create Inform

ati on Incl ude d in 3 B D. Gather Exis ti

ng Informa ti

on Incl ude d in 3 B E. Wri te Report Noti fi cat ion of G as-Fi re d Turbi ne s d 2 1 2 6 12 0.60 1. 20 13. 80 1,306. 41 Noti fi cat ion of Cons truc ti

on/R econs truc ti

on d 2 1 2 3 6 0.30 0. 60 6. 90 653. 21 Noti fi cat ion of Ini ti al Performa nc e T est d 2 1 2 3 6 0.30 0. 60 6. 90 653. 21 Noti fi cat ion of Actu al S tartu pd 2 1 2 3 6 0.30 0. 60 6. 90 653. 21 Noti fi cat ion of Compli ance S tatus d 2 1 2 3 6 0.30 0. 60 6. 90 653. 21 Se mi -An nua l Compl

ia nc e Rep ort

e 8 2 16 3 48 2.40 4. 80 55. 20 5,225. 64 Re portin g Subtot

al 180 16,983 4. Re cordk eep ing Re quir em en ts A. Read Instru cti ons Incl ude d in 3 A B. Pl an Acti vi ti es Incl ude d in 3 B C. Im ple me nt Ac ti

vitie s Incl ude d in 3 B D. Ti me toEnte r Inform

ation Pu rch as e an d Insta ll Catal

ys t In le t Tem pe ratu re M onit or 30 1 30 3 90 4.50 9. 00 103. 50 9,798. 08 Records o f Operati

ng Param

eters e 0. 5 12 6 22 132 6.60 13. 20 151. 80 14,370. 51 F. Trai n Personne l N/ A G. Au dit s N/ A Re cordk eeping Subt

ot al 255 24,169 TOTAL ANNUAL B URDEN 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 i ncreased by 110 percent to account for the benefit packages available to those employed by private industry. This ICR assume s that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. b) It is assumed th at 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 pre pare 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 Turbinesc, 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 Startupc 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 Resultsf 8 1 8 3 24 1.20 2.40 27.60 1243.79 Review Semi-Annual Compliance Reportsg, 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%); Techn ical $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 p ercent to account for the benefit packages available to government employees. This ICR assumes that Clerical hours are 10 pe rcent of Technical hours and Managerial hours are 5 percent of Technical hours. b) It is assumed that there will be nine new or rec onstructed 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 ne w oil

- fired turbines will be added per year. f) I t 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.