Burden Calculation Tables

2028t09.xlsx

NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, subpart DDDDD) (Renewal)

Burden Calculation Tables

OMB: 2060-0551

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Overview

SUMMARY TABLE 1
SUMMARY TABLE 2-Agency
SUMMARY TBL 3 UNIT-SUBCAT
BURDEN SUMMARY
Base Data
Agency Base Data
Fac-ExistLrgSolid-Avg
Fac-ExistLrgLiquid-Avg
Fac-ExistLrgGas-Avg
Fac-NewLrgSolid-Avg
Fac-NewLrgLiquid-Avg
Fac-NewLrgGas-Avg
Fac - ExistSmlSolid-Avg
Fac - ExistSmlLiquid-Avg
Fac - ExistSmlGas-Avg
Fac-NewSmlSolid-Avg
Fac-NewSmlLiquid-Avg
Fac-NewSmlGas-avg
Capital vs. O&M


Sheet 1: SUMMARY TABLE 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)



























TOTAL LABOR BURDEN AND COSTS





Boiler Type Number of Respondents per Year (Average) Number of Units (Average) Number of Responses Per Year (Average) Reporting Recordkeeping Total Labor Hours Total Labor Cost Total Annual O&M and Annualized Capital Costs per year Total Costs
No. Response per Respondent Total Annual Response
Existing Large Solid Units 121 1,040 242 135,217 61,410 196,627 $21,531,254.93 $74,866,304 $96,397,558.93
1.99 242
New Large Solid Units 3 26 12 3,857 1,603 5,460 $597,908.52 $3,223,948.00 $3,821,856.52
4.00 12
Existing Small and Limited Use Solid Units 5 41 3 347 156 503 $55,093.72 $98,032.00 $153,125.72
0.56 3
New Small Solid Units 1 2 3 74 48 122 $13,348.42 $4,456.00 $17,804.42
3.00 3
Existing Large Liquid Units 66 570 132 77,487 33,638 111,125 $12,168,470.96 $17,695,826 $29,864,296.96
2.00 132
New Large Liquid Units 0 0 0 0 0 0 $0 $0 $0.00
0.00 0
Existing Small and Limited Use Liquid Units 45 385 23 3,045 1,220 4,265 $467,037.32 $857,780 $1,324,817.32
0.51 23
New Small Liquid Units 0 0 0 0 0 0 $0.00 $0 $0.00
0.00 0
Existing Large Gaseous Units 669 5,733 1,530 142,506 22,654 165,160 $18,085,504.87 $18,867,183 $36,952,687.87
2.29 1530
New Large Gaseous Units 33 261 99 6,258 3,546 9,804 $1,073,571.94 $750,375 $1,823,946.94
2.97 99
Existing Small and Limited Use Gaseous Units 1,027 8,811 514 69,654 27,358 97,012 $10,623,107.89 $13,921,380.00 $24,544,487.89
0.50 514
New Small Gaseous Units 41 326 103 4,725 2,027 6,752 $739,326.22 $726,328.00 $1,465,654.22
2.50 103
Subtotals (all types) 2,012 17,196 2,661 443,169 153,660 596,829 65,354,625 $131,011,612 $196,366,237
1.32 2661
GRAND TOTAL (rounded)1




597,000 $65,400,000 $131,000,000 $196,000,000
224 hours per response






Rounded by Sector1


Total Private Sector 1,891
2,501 416,579 144,441 561,000 $61,400,000 $123,000,000 $185,000,000


Total Public Sector 121
160 26,590 9,220 35,800 $3,920,000 $7,860,000 $11,800,000


1 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.












Sheet 2: SUMMARY TABLE 2-Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters
(40 CFR Part 63, Subpart DDDDD) (Renewal)














Burden Item




EPA hours per occurrence (A) Number of occurrences per year (B) EPA hours per occurrence per year (C=AxB) Technical hours per year (D=C) Mangmt hours per year (E=Dx0.05) Clerical hours per year (F=Dx0.1) (H) Costs, $ k Footnotes
1. Familiarization with rule requirements



10 0 0 0 0 0 $0.00 a
2. Enter and update information into agency recordkeeping system 2 156 312 312 15.6 31.2 $16,823.66 b
3. Required activities












A. Review and approve monitoring plan


20 3 60 60 3 6 $3,235.32 n

B. Review and approve fuel monitoring plan


20 418 8,360 8,360 418 836 $450,787.92 o

C. Observe initial stack/performance test


40 21 840 840 42 84 $45,294.48 c

D. Observe repeat performance test


40 117 4,680 4,680 234 468 $252,354.96 d

E. Review operating parameters


2 104 208 208 10.4 20.8 $11,215.78 e

F. Review continuous parameter monitoring


2 1,714 3,428 3,428 171.4 342.8 $184,844.62 f
4 Excess Emissions Enforcement Activities and Inspections



24 10 0 0 0 0 $0 g
5 Notification requirements












A. Review initial notification that sources are subject to the standard 2 78 156 156 7.8 15.6 $8,411.83 b

B. Review notification of initial performance tests and review test plan 20 104 2,080 2,080 104 208 $112,157.76 e

C. Review notification of compliance status


2 78 156 156 7.8 15.6 $8,411.83 b
6. Reporting requirements





0 0 0 0 $0.00

A. Review semiannual compliance report


4 398 1,592 1,592 79.6 159.2 $85,843.82 h

B. Review annual compliance report


2 660 1,320 1,320 66.0 132.0 $71,177.04 i

C. Review biennial compliance report


1 560 560 560 28 56 $30,169.36 j

B. Review initial report on results of energy audit


2 0 0 0 0 0 $0 L
7. Travel Expenses for Tests Attended



3 days * ($201 hotel + $93 meals/incidentals) + ($600 round trip) = $1482 per trip

$204,516 m
TOTAL BURDEN AND COST (rounded)







27,300 $1,490,000 p














a Number of hours for agency staff to refamiliarize themselves with the rule requirements.
b Number of occurences is based on the total number of affected facilities that are required to submit initial notifications (all new boilers in the large and small solid, liquid, and gaseous subcategories).
c Number of occurences is based on the assumption that EPA personnel will observe 20% of the initial performance tests that occur.
d Number of occurences is based on the assumption that of the units that test, 10% will have to retest and EPA personnel will observe all these retests. In addition solid fuel units are expected to re-test to obtain worst-case conditions for both Hg and HCl emissions.
e Number of occurences is based on the number of units that will test and set/submit operating limits.
f Number of occurences is based on the number of units maintaining records of control device parameters.












g Number of occurences is based on the assumption that of the units that test, 10% of them will have exceedances and need enforcement.












h Number of occurences is the number of units that will submit these semi-annual compliance reports, 2 reports per year per respondent.
i. Number of occurences is the number of units that will submit these annual compliance reports.












j. Number of occurences is the number units that will submit these biennial compliance reports.












k 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. These rates can be obtained from the OPM web site, http//www.opm.gov/oca/payrates/index/htm.
L Energy audits only occur at existing facilities.












m Total cost is based on the number of trips taken by EPA to observe performance tests in year 1 (4.A. & 4.B.) multiplied by $1482 per trip. The source for hotel and meals/incidental costs is based on FY18 per diem rates, averaged across all locations in the United States. Airfares are estimated based on experience from other rulemakings. See: https://www.perdiem101.com/conus/2018
n Number of occurences is based number of affected facilities which submit monitoring plan, all new and existing large units are required to submit this.












o Number of occurences is based off facilities which have emission limits plus gas units which must perform Hg spec analysis












p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.













Sheet 3: SUMMARY TBL 3 UNIT-SUBCAT

Table 3: Respondents and Units by Subcategory – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters





Year 1 Year 2 Year 3
Boiler Type Respondents per Year (Current) Units per Year (Current) New Respondents per Year New Units Per Year Total Respondents Total Units Total Respondents Total Units Total Respondents Total Units
Large Solid Units 118 1,014 3 26 121 1,040 125 1,066 128 1,092
Small and Limited Use Solid Unitsa 5 40 1 2 5 42 6 44 6 46
Large Liquid Units 66 570 0 0 66 570 66 570 66 570
Small and Limited Use Liquid Units 45 385 0 0 45 385 45 385 45 385
Large Gaseous Units 636 5,472 33 261 669 5,733 703 5,995 736 6,256
Small and Limited Use Gaseous Units 986 8,485 41 326 1,027 8,811 1,068 9,137 1,109 9,463
Subtotals 1,856 15,966 78 615 1,934 16,581 2,012 17,197 2,090 17,812
a For new small solid-fuel units, only one new respondent is anticipated for the duration of the three year period.










Sheet 4: BURDEN SUMMARY

Number of Respondents New Existing Total



Year 1 78 1856 1934

Year 2 78 1934 2012

Year 3 78 2011 2090

Total 234 5801 6036

Average 78 1934 2012













ICRAS SUMMARY REPORTING RECORDKEEPING
Tracy Curtis: Burden hours have increased on an annual basis because 1) number sources have increased to 2012 from 1701 over 3 year period, and 2) all existing sources should be in compliance following 2016 compliance date. Previous workbook had given existing sources three years to come into compliance and phased in # respondents/year accordingly. Annual Burden Hours Tracy Curtis: Number of respondents based on average of 1,934 existing reporters and 78 new reporters per year. Number of Respondents (Facilities) Number of Responses Annualized Capital/Start-up and O&M Annual Burden Hours
Annual Burden 443,169 2,012 2,661 $131,011,612 153,660
Cost per Response


$73,808
Burden Hours per Response


224






INDUSTRY 3- year period Average per year Public Sector Private Sector
Reporting Hours
443,169 26,590 416,579
Recordkeeping Hours
153,660 9,220 144,441
Total HOURS 596,829 198,943 11,937 187,007
TOTAL COSTS (non-labor) $131,011,612 $43,670,537 $2,620,232 $41,050,305
Total LABOR COSTS $65,354,625 $21,784,875 $1,307,092 $20,477,782
TOTAL LABOR AND NON-Labor COSTS $196,366,237 $65,455,412 $3,927,325 $61,528,088
Total Responses
2,661 160 2,501
Tracy Curtis: Previous small entity assumption is based on 151 of 1701 facilities being small entities (or 9%). Adjusted to 9% of 2012 facilities or 181. Small Entity Respondents per year

11 170
Total Respondents per year

121 1,891












AGENCY Average per year Average per year (rounded)


Hours 27,300 27,300


Costs (labor + travel) $1,490,000 $1,490,000



Sheet 5: Base Data


Labor Rates









NEW ASSUMPTIONS:






















Updated existing unit counts to reflect 3 years of growth from prior renewal (Cells D62-D82, added to Cells S17-S46)











Category Rate Note







Assumed 22% of existing coal-fired boilers have been converted to natural gas (decrease # of coal-fired boilers by 22% and increase gas-fired by 22%) (Cells W22-W25_











Technical $112.98 June 2017 Labor Rates







Assumed 18 of existing coal-fired boilers have been shutdown, adjust by subcategory (cells V22-V25)











Clerical $54.81 June 2017 Labor Rates







Updated facility counts by subcategory using revised unit counts and assuming new facility count of 1,856 based on three year growth (cells D46 and H46) - see H16-H46











Managerial $149.35 June 2017 Labor Rates







Updated read and understand rule req's to familiarization with rule requirements (10 hrs) for lg existing sources (5 hrs) for sm existing categories (left at 40 hrs for new)











General Contractor $80.00








Updated labor rates for industry and agency to 2017 values.











Certfied Energy Audit Contractor $56.78








Additional assumptions updated in following spreadsheets (see comments)



































Existing Boiler Data
















































ADJUSTED UNIT COUNTS IN COLUMN D TO ACCOUNT FOR SUBCATEGORY CHANGES




















Sum of Unit Count


Sum of Facility Count


















Mact Floor Fuel Category Size Category Total
Mact Floor Fuel Category Size Category Total



Count of Limited Use Units


Sum of Unit Count
UPDATED COLUMN TO ADJUST UNIT CATEGORY TOTALS TO ADD 3-YEAR GROWTH TO EXISTING VALUES





Biomass Limited Use 4
Biomass Limited Use 1



Mact Floor Fuel Category Size Category Total
Mact Floor Fuel Category Size Category Total + 3-year growth Prior Total




<10 21
<10 2



Biomass <10 0
Biomass <10 21 17




>=10 to 100 277
>=10 to 100 32
306

>=10 to 100 1
>=10 to 100 278 231




100 to 250 115
100 to 250 13
59

100 to 250 3
100 to 250 118 100




>250 171 584 >250 20 67


>250 0
>250 171 158
ADJUSTMENTS TO NEW COAT AND NG UNIT COUNTS BASED ON SUBCATEGORY CHANGES:


Coal Limited Use 15
Coal Limited Use 2












#Units Shutdown # Units Converted to NG Total Number of Units Removed

<10 0 Updated formula for total removed <10 0



Coal <10 0
Coal <10 0 0 0 0 0 0

>=10 to 100 104 Updated formula for total removed >=10 to 100 12



>=10 to 100 7
>=10 to 100 147 147 0.236714975845411 4 32 36

100 to 250 196 Updated formula for total removed 100 to 250 23
1035

100 to 250 7
100 to 250 271 271 0.436392914653784 8 60 68

>250 151 451 >250 18 53 1014

>250 1
>250 203 203 0.326892109500805 6 45 51

Gas 1 (NG Only) Limited Use 333
Gas 1 (NG Only) Limited Use 39
1033







621

Tracy Curtis: Provided by EPA 18 Tracy Curtis: Conversion based on data provided by EPA 137 155

<10 8101 Updated formula for total coal converted <10 942



Gas 1 (NG Only) <10 7
Gas 1 (NG Only) <10 8108 7130




>=10 to 100 3732 Updated formula for total coal converted >=10 to 100 434



>=10 to 100 215
>=10 to 100 3915 3362




100 to 250 1119 Updated formula for total coal converted 100 to 250 130



100 to 250 89
100 to 250 1148 983




>250 543 Updated formula for total coal converted >250 63



>250 22
>250 520 454




Gas 1 (Other Gases) Limited Use

Gas 1 (Other Gases) Limited Use

















<10

<10




Gas 1 (Other Gases) <10

Gas 1 (Other Gases) <10






>=10 to 100

>=10 to 100




>=10 to 100

>=10 to 100






100 to 250
large gas 1 (for tune-ups) 100 to 250




100 to 250

100 to 250






>250
5394 >250




>250

>250






Gas 2 Limited Use 4
Gas 2 Limited Use 0
















<10 47
<10 5



Gas 2 <10 0
Gas 2 <10 47 47




>=10 to 100 28
>=10 to 100 3



>=10 to 100 0
>=10 to 100 28 28




100 to 250 22 total large gas 2 units 100 to 250 3 total large gas facilities


100 to 250 4
100 to 250 26 26




>250 28 78 >250 3 636


>250 0
>250 28 28




Liquid Limited Use 125
Liquid Limited Use 15
















<10 260
<10 30



Liquid <10 13
Liquid <10 273 273




>=10 to 100 359
>=10 to 100 42



>=10 to 100 57
>=10 to 100 416 416




100 to 250 147
100 to 250 17



100 to 250 40
100 to 250 187 187




>250 64 570 >250 7 33


>250 15
>250 79 79




Grand Total
ERG/Tracy Curtis: Updated to reflect new units from 3-year growth. 15966
Grand Total
ERG/Tracy Curtis: Updated to reflect 1,856 existing facilities/respondent count based on 3-year growth (assuming existing facilities grow by 78 facilities per year) 1856



Grand Total
481
Grand Total
15984 14140




























Mercury Fuel Spec Analysis (for other Gas 1 units)


Number which will repeat stack test due to switching fuels






<10 20 x
<10 8449





Number estimated to test Tracy Curtis: Assume this remains the same. 387

Tracy Curtis: Changed to be the sum of all solid fuel units >=10 mmbtu, which is a slight decrease since previously. 1014 (applicable to solid units)





>=10 to 100 280 x
>=10 to 100 4784

















100 to 250 143 x
100 to 250 1750





Notification of Alternative fuel use (15.8% reported the use of liquid, large gas 1 units)










>250 38 x
>250 1001





852














































Notes:






















PM CEMS required for all units >250 that are firing liquid or solid fuels






















Tune-ups required for all units <10 and all gas 1 units, regardless of size






























2087














GGibson: Projection of new units did not change from reconsideration proposal to reconsideration final, so these counts will also not change. New Boiler Data

ASSUMPTIONS: Assume constant growth same as prior proposal (no coal, no liquid, no gas 2)











































Sum of 2013- Estimated number of new boilers


Sum of 2013- Estimated number of Facilities


















Standard Fuel Category SizeCategory Total New/3-Year Pd
Standard Fuel Category SizeCategory Total New/3-Year Pd




New Respondents/Year


Existing Respondents/Year Yr1 Yr 2 Yr 3 Avg


Biomass <10 4
Biomass <10 1




Small Biomass
1
Large Solid 118 121 124 121


>=10 to 100 47
>=10 to 100 6




Large Biomass
3
Large Liquid 66 66 66 66


>100 to 250 18 26 >100 to 250 2




Small Coal
0
Large Gas 636 669 702 669


>250 13 78 >250 2 10



Large Coal
0
Small Solid 5 6 6 6


Coal <10 0
Coal <10 0




Small Gas 1
41
Small Liquid 45 45 45 45


>=10 to 100 0
>=10 to 100 0




Large Gas 1
33
Small Gas 986 1027 1068 1027


>100 to 250 0
>100 to 250 0




Small Gas 2
0
Total Existing 1856 1934 2011 1934


>250 0
>250 0




Large Gas 2
0








Gas 1 <10 978
Gas 1 <10 123




Small Liquid
0








>=10 to 100 553
>=10 to 100 70




Large Liquid
0








>100 to 250 165 784 >100 to 250 21




Total New
78








>250 66 261.333333333333 >250 9 100















Gas 2 <10 0
Gas 2 <10 0
















>=10 to 100 0
>=10 to 100 0
















>100 to 250 0
>100 to 250 0
average # of boilers per facility














>250 0
>250 0
8














Liquid <10 0
Liquid <10 0
















>=10 to 100 0
>=10 to 100 0
















>100 to 250 0
>100 to 250 0
















>250 0
>250 0
















Grand Total
1844
Grand Total
ERG/Tracy Curtis: Maintain assumption of an average of 8 boilers/facility 231 234







































Mercury Fuel Spec Analysis (for other Gas 1 units)


Number which will repeat stack test due to switching fuels


















Number estimated to test



(applicable to solid units)

























































































5_AffectedSector 8_Small Entity Count % of Total



















Not-for-Profit False 22



% public New + Existing















Not-for-Profit True 6 0.94 Private %

0.06















Not-for-Profit Unknown 3 0.06 Public %


















Private Enterprise False 1276




















Private Enterprise True 131




















Private Enterprise Unknown 80




















Public Sector False 82
% Small Entity


















Public Sector True 14 Private Sector 0.1


















Public Sector Unknown 6 Public Sector 0.15


















Did not use these unknowns:






















Unknown False 3




















Unknown Unknown 78












































5_AffectedSector 8_Small Entity Count




















Not-for-Profit False 22




















Not-for-Profit True 6 151 8%










































Private Enterprise False 1276




















Private Enterprise True 131












































Public Sector False 82




















Public Sector True 14












































Did not use these unknowns:






















Unknown False 3




















Unknown Unknown 78




















Not-for-Profit Unknown 3




















Private Enterprise Unknown 80




















Public Sector Unknown 6




































































Fuel Monitoring Plan






















For facilities which have emission limits or for Gas facilities which perform the Hg gas spec






















830














































Sheet 6: Agency Base Data

Agency Labor Rates






Managerial $64.80 Updated Labor rates to 2017 General Schedule
Clerical $26.02

Technical $48.08









Per Diem Info






Hotel $201 average 2018 rates, https://www.perdiem101.com/conus/2018
Meals $93 average 2018 rates, https://www.perdiem101.com/conus/2018
Airfare $600

Trip Length 3









Other Data






Percent of Stack Tests Observed 20%
Estimated Percent Retesting 10%
Estimated Percent Emission Exceedences 10%

Sheet 7: Fac-ExistLrgSolid-Avg

Table 1.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)
Existing Large Solid Fuel Units
Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Stack Testing and Fuel Analysis Cost Per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes
1. Applications na













2. Surveys and Studies na













3. Reporting Requirements














A. Familiarization with Rule Requirements 10 $0 $0 $0 1 10 121 1,210 121 61 $152,373 $0 121 a
B. Required Activities














1. Conduct Energy Audit














a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d
b) Industrial 20 $18,292 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d
2. Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 c,h
3. Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 c
4. Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 c
5. Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0 0 c
6. Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 1,040 12,480 1,248.0 624.0 $1,571,588 $5,200,000 0 c,h,i
7. Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 1,040 12,480 1,248.0 624.0 $1,571,588 $8,320,000 0 c, i
8. Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 1,040 12,480 1,248.0 624.0 $1,571,588 $8,320,000 0 c, i
9. Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 1,040 12,480 1,248.0 624.0 $1,571,588 $7,280,000 0 c, i
10. Repeat Stack Test and Report if Switch Fuels
(for Hg and HCl)
24 $0 $16,000 $0 1 24 1,040 24,960 2,496 1,248 $3,143,175 $16,640,000 0 c,j
11. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 c,g
12. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0 0 c,g
13. Annual Tune-up 12 $0 $2,875 $0 1 12 1,040 12,480 1,248.0 624.0 $1,571,588 $2,990,000 0 c,k
14. Continuous Parameter Monitoring












m
Establish Site-specific monitoring plan (all) 40 $0
$0 1 40 0 0 0 0 $0 $0 0 c
Opacity














a) initial 10 $0 $0 $43,100 1 10 0 0 0.0 0.0 $0 $0 0 c,m
b) annual 10 $0 $0 $14,700 1 10 528 5,280 528.0 264.0 $664,902 $7,761,600 0 c,m
PM (only sources greater than 250 mmBtu/hr)














a) initial 10 $0 $0 $158,000 1 10 0 0 0.0 0.0 $0 $0 0 c,L,m
b) annual 10 $0 $0 $56,100 1 10 207 2,070 207.0 103.5 $260,672 $11,612,700 0 c,L,m
O2














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0 0 c,m
b) annual 10 $0 $0 $1,436 1 10 1,114 11,140 1,114 557 $1,402,843 $1,599,704 0 c,m
Scrubber System Monitoring and Operation
(for units with wet scrubbers)















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0 c,m
b) annual 10 $0 $0 $5,600 1 10 401 4,010 401 201 $504,973 $2,245,600 0 c,m
Bag Leak Detection System Operation
(sources that have fabric filters)















a) initial 10 $0 $0 $25,500 1 10 0 0 0 0.0 $0 $0 0 c,m
b) annual 10 $0 $0 $9,700 1 10 61 610 61 30.5 $76,816 $591,700 0 c,m
DIFF Monitor














a) initial 10 $0 $0 $43,500 1 10 0 0 0 0.0 $0 $0 0 c,m
b) annual 10 $0 $0 $26,500 1 10 76 760 76 38.0 $95,706 $2,014,000 0 c,m
Carbon Injection Monitoring System
(all sources that use ACI to control Hg)















a) initial 10 $0 $0 $115,000 1 10 0 0 0 0.0 $0 $0 0 c,m
b) annual 10 $0 $0 $9,700 1 10 30 300 30 15.0 $37,779 $291,000 0 c,m
C. Create Information na













D. Gather Information na













E. Report Preparation














1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0 a
2) Notification of Compliance Status 8 $0 $0 $0 1 8 0 0 0.0 0.0 $0 $0 0 c
3) Initial Report on results of Energy Audit 5 $0 $0 $0 1 5 0 0 0.0 0.0 $0 $0 0 c
4) Semi-annual Compliance Report 20 $0 $0 $0 2 40 121 4,840 484 242 $609,494 $0 242 a
Reporting Subtotal






135,217 $14,806,673 $74,866,304 242

4. Recordkeeping Requirements














A. Familiarization with Rule Requirements Included in 3a













B. Implement Activities na













C. Develop Record System na











e
D. Record Information














1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 1,040 20,800 2,080 1,040 $2,619,313 $0 0 c
2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 1,040 15,600 1,560.0 780.0 $1,964,485 $0 0 c,n
3) Records of Stack Tests 2 $0 $0 $0 1 2 1,040 2,080 208.0 104.0 $261,931 $0 0 c
4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 1,040 2,080 208.0 104.0 $261,931 $0 0 c
5) Records of All Compliance Reports Submitted 2 $0 $0 $0 2 4 1,040 4,160 416.0 208.0 $523,863 $0 0 c
6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 1,040 6,240 624.0 312.0 $785,794 $0 0 c
E. Personnel Training 40 $0 $0 $0 1 40 61 2,440 244 122 $307,266 $0 0 f
F. Time for Audits na













Recordkeeping Subtotal






61,410 $6,724,582 $0 0

Totals






196,627 $21,531,255 $74,866,304 242

a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 10 hours.














b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 88% of facilities are in the industrial sector while the remaining 12% of facilities are in the commercial sector.


c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting semi-annual reports and conducting the required recordkeeping.


d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.
f For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.














e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.














g Existing large solid units are expected to determine compliance through stack testing and not fuel analysis














h Units not equipped with PM CPMS wil perform stack testing for PM.














i Annual testing is based on the average number of existing units.


j Only applies to large solid fuel boilers, because solid fuel boilers may fire a mix of non-homogeneous fuels. Assumed all solid fuel units would perform a repeat stack test.














k Tune-ups are required as work practice standards in lieu of dioxin/furan testing. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.
L PM CPMS is only required for coal boilers, biomass boilers which are not 100% biomass, and residual oil boilers which are >= 250 mmBtu/hr that were construction prior to June 4, 2010. This affects approximately 207 units.














m Estimated number of units expected to require each type of parameter monitoring are consistent with the estimated number of units expected to install controls, as outlined in the memorandum: "Revised (November 2011) Methodology for Estimating Cost and Emissions Impacts for Industrial, Commercial, Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants – Major Source." Small edits to the MACT floor dataset were made after the impacts analysis and ICR burden estimates were prepared. These edits are not reflected in the ICR or impacts analysis, but the changes are incorporated into the burden estimates for the final rule.


n Includes enhanced recordkeeping provisions for demonstration of compliance with the alternative definition of "startup" (paragraph (2) of the definition) that document when useful thermal energy is provided, what fuels are used during startup,














parametric monitoring data to verify relevant controls are engaged, and the time when PM controls are engaged. It is assumed that no one is using the compliance alternatives at this time.















Sheet 8: Fac-ExistLrgLiquid-Avg

Table 2.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)
Existing Large Liquid Fuel Units
Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Stack Testing and Fuel Analysis Cost Per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes
1. Applications na













2. Surveys and Studies na













3. Reporting Requirements














A. Familiarization with Rule Requirements 10 $0 $0 $0 1 10 66 660 66 33 $83,113 $0 66 a
B. Required Activities














1. Conduct Energy Audit














a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d
b) Industrial 20 $18,292 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d
2. Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0 0 c,h
3. Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 c
4. Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 c
5. Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0 0 c,i
6. Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 570 6,840 684 342 $861,351 $2,850,000 0 c,h,j
7. Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 c,j
8. Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 c,j
9. Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 570 6,840 684 342 $861,351 $3,990,000 0 c,j
10. Repeat Stack Test and Report if Switch Fuels
(for Hg and HCl)
24 $0 $16,000 $0 1 24 0 0 0 0 $0 $0 0 c,f
11. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0.0 0.0 $0 $0 0 c,g
12. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 570 34,200 3,420 1,710 $4,306,755 $2,736,000 0 c,g
13. Annual Tune-up 12 $0 $2,875 $0 1 12 570 6,840 684 342 $861,351 $1,638,750 0 c,L
14. Continuous Parameter Monitoring












n
Establish Site-specific monitoring plan (all) 40 $0
$0 1 40 0 0 0 0 $0 $0 0 c
Opacity














a) initial 10 $0 $0 $43,100 1 10 0 0 0 0.0 $0 $0 0 c
b) annual 10 $0 $0 $14,700 1 10 30 300 30 15.0 $37,779 $441,000 0 c
PM (only sources greater than 250 mmBtu/hr)














a) initial 10 $0 $0 $158,000 1 10 0 0 0 0.0 $0 $0 0 c,m
b) annual 10 $0 $0 $56,100 1 10 21 210 21 10.5 $26,445 $1,178,100 0 c,m
O2














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0 0 c,n
b) annual 10 $0 $0 $1,436 1 10 316 3,160 316 158 $397,934 $453,776 0 c,n
Scrubber System Monitoring and Operation
(for units with wet scrubbers)















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0.0 $0 $0 0 c,n
b) annual 10 $0 $0 $5,600 1 10 271 2,710 271 135.5 $341,266 $1,517,600 0 c,n
Bag Leak Detection System Operation
(sources that have fabric filters)















a) initial 10 $0 $0 $25,500 1 10 0 0 0 0.0 $0 $0 0 c,n
b) annual 10 $0 $0 $9,700 1 10 262 2,620 262 131.0 $329,933 $2,541,400 0 c,n
DIFF Monitor














a) initial 10 $0 $0 $43,500 1 10 0 0 0 0 $0 $0 0 c,n
b) annual 10 $0 $0 $9,700 1 10 28 280 28 14 $35,260 $271,600 0 c,n
Carbon Injection Monitoring System
(all sources that use ACI to control Hg)















a) initial 10 $0 $0 $115,000 1 10 0 0 0 0 $0 $0 0 c,n
b) annual 10 $0 $0 $9,700 1 10 8 80 8 4 $10,074 $77,600 0 c,n
C. Create Information na













D. Gather Information na













E. Report Preparation














1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0 a
2) Notification of Compliance Status 8 $0 $0 $0 1 8 0 0 0.0 0.0 $0 $0 0 c
3) Initial Report on results of Energy Audit 5 $0 $0 $0 1 5 0 0 0.0 0.0 $0 $0 0 c
4) Semi-annual Compliance Report 20 $0 $0 $0 2 40 66 2,640 264 132 $332,451 $0 132 c
Reporting Subtotal






77,487 $8,485,062 $17,695,826 132

4. Recordkeeping Requirements














A. Familiarization with Rule Requirements Included in 3a













B. Implement Activities na













C. Develop Record System na











e
D. Record Information














1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 570 11,400 1,140 570 $1,435,585 $0 0 c
2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 570 8,550 855 428 $1,076,689 $0 0 c,o
3) Records of Stack Tests 2 $0 $0 $0 1 2 570 1,140 114 57 $143,558 $0 0 c
4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 570 1,140 114 57 $143,558 $0 0 c
5) Records of All Compliance Reports Submitted 2 $0 $0 $0 2 4 570 2,280 228 114 $287,117 $0 0 c
6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 570 3,420 342 171 $430,675 $0 0 c
E. Personnel Training 40 $0 $0 $0 1 40 33 1,320 132 66 $166,226 $0 0 k
F. Time for Audits na













Recordkeeping Subtotal






33,638 $3,683,409 $0 0

Totals






111,125 $12,168,471 $17,695,826 132

















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 10 hours.














b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 88% of facilities are in the industrial sector while the remaining 12% of facilities are in the commercial sector.


c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting semi-annual reports and conducting the required recordkeeping.


d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.
e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.














f Only applies to large solid fuel boilers, because solid fuel boilers may fire a mix of non-homogeneous fuels. Assumed zero respondents for liquid and gas units.




g Existing large liquid units are expected to determine compliance for Hg and HCl through fuel analysis not stack testing.














h Units not equipped with PM CPMS wil perform stack testing for PM.














j Annual testing is based on the number of existing units in the three years following promulgation of the November 20, 2015 final rule.


k For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.














L Tune-ups are required as work practice standards in lieu of dioxin/furan testing. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.

m PM CPMS is required for coal boilers, biomass boilers which are not 100% biomass, and residual oil boilers which are >= 250 mmBtu/hr














n Estimated number of units expected to require each type of parameter monitoring are consistent with the estimated number of units expected to install controls, as outlined in the memorandum: "Revised (November 2011) Methodology for Estimating Cost and Emissions Impacts for Industrial, Commercial, Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants – Major Source." Small edits to the MACT floor dataset were made after the impacts analysis and ICR burden estimates were prepared. These edits are not reflected in the ICR or impacts analysis, but the changes are incorporated into the burden estimates for the final rule.


o Includes enhanced recordkeeping provisions for demonstration of compliance with the alternative definition of "startup" (paragraph (2) of the definition) that document when useful thermal energy is provided, what fuels are used during startup,














parametric monitoring data to verify relevant controls are engaged, and the time when PM controls are engaged. It is assumed that no one is using the compliance alternatives at this time.















Sheet 9: Fac-ExistLrgGas-Avg

Table 3.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)
Existing Large Gas Fuel Units
Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Stack Testing and Fuel Analysis Cost Per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes
1. Applications na













2. Surveys and Studies na













3. Reporting Requirements














A. Familiarization with Rule Requirements 10 $0 $0 $0 1 10 669 6,690 669 335 $842,462 $0 0 a
B. Required Activities














1. Conduct Energy Audit














a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d
b) Industrial 20 $18,292 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d
2. Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 c,j,k
3. Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 c,j,k
4. Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 c,j,k
5. Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 c,j,k
6. Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 78 936 93.6 46.8 $117,869 $390,000 0 c,j,k
7. Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 c,j,k
8. Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 c,j,k
9. Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 78 936 93.6 46.8 $117,869 $546,000 0 c,j,k
10. Repeat Stack Test and Report if Switch Fuels
(for Hg and HCl)
24 $0 $16,000 $0 1 24 0 0 0 0 $0 $0 0 c,f
11. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 c,g
12. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 78 4,680 468 234 $589,345 $374,400 0 c,g
13. Continuous Parameter Monitoring












o
Establish Site-specific monitoring plan (all) 40 $0
$0 1 40 0 0 0 0 $0 $0 0 c
Opacity














a) initial 10 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0 c,h
b) annual 10 $0 $0 $14,700 1 10 0 0 0 0 $0 $0 0 c,h
PM (only sources greater than 250 mmBtu/hr)














a) initial 10 $0 $0 $158,000 1 10 0 0 0 0 $0 $0 0 c,h
b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0 0 c,h
O2














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0.0 $0 $0 0 c,o
b) annual 10 $0 $0 $1,436 1 10 78 780 78 39.0 $98,224 $112,008 0 c,o
Scrubber System Monitoring and Operation
(for units with wet scrubbers)















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0.0 $0 $0 0 c,o
b) annual 10 $0 $0 $5,600 1 10 6 60 6 3.0 $7,556 $33,600 0 c,o
Bag Leak Detection System Operation
(sources that have fabric filters)















a) initial 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0 c,o
b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0 0 c,o
14. Annual Tune-up 12 $0 $2,875 $0 1 12 5,733 68,796 6,879.6 3,439.8 $8,663,377 $16,482,375 0 c,k
15. Mercury Fuel Spec Analysis 5 $0 $200 $0 12 60 387 23,220 2,322 1,161 $2,924,060 $928,800 0 c,i
C. Create Information na













D. Gather Information na













E. Report Preparation














1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0 a
2) Notification of Compliance Status 8 $0 $0 $0 1 8 0 0 0.0 0.0 $0 $0 0 c
3) Initial Report on results of Energy Audit 5 $0 $0 $0 1 5 0 0 0 0 $0 $0 0 c
4) Annual Compliance Report 20 $0 $0 $0 1 20 660 13,200 1,320 660 $1,662,256 $0 660 c, L
5) Semi-annual Compliance Report 20 $0 $0 $0 2 40 9 360 36 18 $45,334 $0 18 c, L
6) Notification of Alternative Fuel Use 5 $0 $0 $0 1 5 852 4,260 426.0 213.0 $536,455 $0 852 c,m
Reporting Subtotal





142,506 $15,604,808 $18,867,183 1,530

4. Recordkeeping Requirements














A. Familiarization with Rule Requirements Included in 3a













B. Implement Activities na













C. Develop Record System na











e
D. Record Information














1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 78 1,560 156 78 $196,448 $0 0 c
2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 78 1,170 117 59 $147,336 $0 0 c,p
3) Records of Stack Tests 2 $0 $0 $0 1 2 78 156 15.6 7.8 $19,645 $0 0 c
4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 78 156 15.6 7.8 $19,645 $0 0 c
5) Records of All Annual Compliance Reports Submitted 2 $0 $0 $0 1 2 660 1,320 132.0 66.0 $166,226 $0 0 c, L
6) Records of All Semi-Annual Compliance Reports
Submitted
2 $0 $0 $0 2 4 9 36 3.6 1.8 $4,533 $0 0 c, L
7) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 78 468 46.8 23.4 $58,935 $0 0 c
8) Records of Annual Tune-up 0.25 $0 $0 $0 1 0.25 5,733 1,433 143.3 71.7 $180,487 $0 0 c
E. Personnel Training 40 $0 $0 $0 1 40 335 13,400 1,340 670 $1,687,442 $0 0 n
F. Time for Audits na













Recordkeeping Subtotal






22,654 $2,480,697 $0


Totals






165,160 $18,085,505 $18,867,183 1,530

















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 10 hours.














b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 87.4% of facilities are in the industrial sector while the remaining 12.6% of facilities are in the commercial sector.


c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting semi-annual reports and conducting the required recordkeeping.


d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.
e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.














f Only applies to large solid fuel boilers, because solid fuel boilers may fire a mix of non-homogeneous fuels. Assumed zero respondents for liquid and gas units.




g Existing large gas 2 units are expected to determine compliance through stack testing.














h Gas units are exempt from PM CPMS and opacity monitoring.














i Number based on units which reported firing fuels other than natural or refinery gas.














j The units firing other process gases other than natural gas, refinery gases or other on-spec gas 1 fuels have limits for PM, HCl, Hg, and CO and are subject to testing and monitoring requirements for each pollutant.
k The recordkeeping and reporting requirements for natural gas fired units is to conduct an annual tune-up and document that the tune-up was completed. The documentation does not need to be submitted as a report unless requested by the Administrator. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.
L Only facilities with process gas (gas 2 units) subject to numerical emission limits are expected to be required to submit semi-annual compliance reports. Natural gas and refinery gas units are required to submit reports annually.














m Number based on 17.8% of the large gas 1 units using liquid instead of gas at some point.














n For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.














o Estimated number of units expected to require each type of parameter monitoring are consistent with the estimated number of units expected to install controls, as outlined in the memorandum: "Revised (November 2011) Methodology for Estimating Cost and Emissions Impacts for Industrial, Commercial, Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants – Major Source." Small edits to the MACT floor dataset were made after the impacts analysis and ICR burden estimates were prepared. These edits are not reflected in the ICR or impacts analysis, but the changes are incorporated into the burden estimates for the final rule.


p Includes enhanced recordkeeping provisions for demonstration of compliance with the alternative definition of "startup" (paragraph (2) of the definition) that document when useful thermal energy is provided, what fuels are used during startup,














parametric monitoring data to verify relevant controls are engaged, and the time when PM controls are engaged. It is assumed that no one is using the compliance alternatives at this time.















Sheet 10: Fac-NewLrgSolid-Avg

Table 4.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)
New Large Solid Fuel Units
Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Stack Testing and Fuel Analysis Cost Per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes
1. Applications na













2. Surveys and Studies na













3. Reporting Requirements














A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 3 120 12 6 $15,111 $0 0 a
B. Required Activities














1. Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 26 312 31.2 15.6 $39,290 $130,000 0 a
2. Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 26 312 31.2 15.6 $39,290 $208,000 0 a
3. Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 26 312 31.2 15.6 $39,290 $208,000 0 a
4. Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 26 312 31.2 15.6 $39,290 $182,000 0 a
5. Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 a
6. Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 a
7. Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 a
8. Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0.0 0.0 $0 $0 0 a
9. Repeat Stack Test and Report if Switch Fuels
(for Hg and HCl)
24 $0 $16,000 $0 1 24 26 624 62.4 31.2 $78,579 $416,000 0 a,d
10. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 a,e
11. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0 0 a,e
12. Annual Tune-up 12 $0 $2,875 $0 1 12 26 312 31.2 15.6 $39,290 $74,750 0 a,g
13. Continuous Parameter Monitoring












i
Establish Site-specific monitoring plan (all) 40 $0
$0 1 40 3 120 12 6 $15,111 $0 0 a
Opacity














a) initial 10 $0 $0 $43,100 1 10 26 260 26 13 $32,741 $1,120,600 0 a
b) annual 10 $0 $0 $14,700 1 10 0 0 0 0 $0 $0 0 a
PM (only sources greater than 250 mmBtu/hr)














a) initial 10 $0 $0 $158,000 1 10 0 0 0 0 $0 $0 0 a,h
b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0 0 a,h
O2














a) initial 10 $0 $0 $8,523 1 10 26 260 26 13 $32,741 $221,598 0 a
b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0 0 a
Scrubber System Monitoring and Operation
(for units with wet scrubbers)















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0 a
b) annual 10 $0 $0 $5,600 1 10 0 0 0 0 $0 $0 0 a
Bag Leak Detection System Operation
(sources that have fabric filters)















a) initial 10 $0 $0 $25,500 1 10 26 260 26 13 $32,741 $663,000 0 a
b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0 0 a
Carbon Injection Monitoring System
(all sources that use ACI to control Hg)















a) initial 10 $0 $0 $115,000 1 10 0 0 0 0 $0 $0 0 a
b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0 0 a
C. Create Information na













D. Gather Information na













E. Report Preparation














1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 3 6 0.6 0.3 $756 $0 3 b
2) Notification of Compliance Status 8 $0 $0 $0 1 8 3 24 2.4 1.2 $3,022 $0 3 b
3) Semi-annual Compliance Report 20 $0 $0 $0 2 40 3 120 12 6 $15,111 $0 6 b
Reporting Subtotal






3,857 $422,364 $3,223,948 12

4. Recordkeeping Requirements














A. Read and Understand Rule Requirements Included in 3a













B. Implement Activities na













C. Develop Record System na











c
D. Record Information














1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 26 520 52 26 $65,483 $0 0 a
2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 26 390 39 20 $49,112 $0 0 a, j
3) Records of Stack Tests 2 $0 $0 $0 1 2 26 52 5.2 2.6 $6,548 $0 0 a
4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 26 52 5.2 2.6 $6,548 $0 0 a
5) Records of All Compliance Reports Submitted 2 $0 $0 $0 2 4 26 104 10.4 5.2 $13,097 $0 0 a
6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 26 156 15.6 7.8 $19,645 $0 0 a,g
E. Personnel Training 40 $0 $0 $0 1 40 3 120 12 6 $15,111 $0 0 f
F. Time for Audits na













Recordkeeping Subtotal






1,603 $175,544 $0 0

Totals






5,460 $597,909 $3,223,948 12

















a In order to calculate a per year estimate of the number of boilers and facilities required to meet these rule requirements, the number of projected boilers and facilities is each divided by 3.


b Assumed reporting activities would start the first year a boiler is applicable to rule.


c Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.


d Only applies to large solid fuel boilers, because solid fuel boilers may fire a mix of non-homogeneous fuels. Assumed all solid fuel units would perform a repeat stack test.
e Existing large solid units are expected to determine compliance through stack testing and not fuel analysis














f For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes all new respondents will conduct training.














g Tune-ups are required as work practice standards in lieu of dioxin/furan testing. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.
h PM CPMS is required for coal boilers, biomass boilers which are not 100% biomass, and residual oil boilers which are >= 250 mmBtu/hr. It was assumed all new solid fuel boilers are firing 100% biomass.



i Estimated number of units expected to require each type of parameter monitoring are consistent with the estimated number of units expected to install controls, as outlined in the memorandum: "Revised (November 2011) Methodology for Estimating Cost and Emissions Impacts for Industrial, Commercial, Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants – Major Source." Small edits to the MACT floor dataset were made after the impacts analysis and ICR burden estimates were prepared. These edits are not reflected in the ICR or impacts analysis, but the changes are incorporated into the burden estimates for the final rule.


j Includes enhanced recordkeeping provisions for demonstration of compliance with the alternative definition of "startup" (paragraph (2) of the definition) that document when useful thermal energy is provided, what fuels are used during startup,














parametric monitoring data to verify relevant controls are engaged, and the time when PM controls are engaged. It is assumed that no one is using the compliance alternatives at this time.















Sheet 11: Fac-NewLrgLiquid-Avg

Table 5.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, subpart DDDDD) (Renewal)
New Large Liquid Fuel Units
Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Stack Testing and Fuel Analysis Cost Per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes
1. Applications na












2. Surveys and Studies na












3. Reporting Requirements













A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 0 0 0 0 $0 $0 0 a
B. Required Activities













1. Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0 0
2. Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0
3. Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0
4. Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0 0
5. Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0 0
6. Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0
7. Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0
8. Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0 0
9. Repeat Stack Test and Report if Switch Fuels
(for Hg and HCl)
24 $0 $16,000 $0 1 24 0 0 0 0 $0 $0 0
10. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0
11. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0 0
12. Annual Tune-up 12 $0 $2,875 $0 1 12 0 0 0 0 $0 $0 0
13. Continuous Parameter Monitoring













Establish Site-specific monitoring plan (all) 40 $0
$0 1 40 0 0 0 0 $0 $0 0
Opacity











0
a) initial 10 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0
b) annual 10 $0 $0 $14,700 1 10 0 0 0 0 $0 $0 0
PM (only sources greater than 250 mmBtu/hr)













a) initial 10 $0 $0 $158,000 1 10 0 0 0 0 $0 $0 0
b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0 0
O2













a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0 0
b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0 0
Scrubber System Monitoring and Operation
(for units with wet scrubbers)














a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0
b) annual 10 $0 $0 $5,600 1 10 0 0 0 0 $0 $0 0
Bag Leak Detection System Operation
(sources that have fabric filters)














a) initial 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0
b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0 0
Carbon Injection Monitoring System
(all sources that use ACI to control Hg)














a) initial 10 $0 $0 $115,000 1 10 0 0 0 0 $0 $0 0
b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0 0
C. Create Information na












D. Gather Information na












E. Report Preparation













1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0
2) Notification of Compliance Status 8 $0 $0 $0 1 8 0 0 0 0 $0 $0 0
3) Semi-annual Compliance Report 20 $0 $0 $0 2 40 0 0 0 0 $0 $0 0
Reporting Subtotal






0 $0 $0 0
4. Recordkeeping Requirements













A. Read and Understand Rule Requirements Included in 3a












B. Implement Activities na












C. Develop Record System na












D. Record Information













1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 0 0 0 0 $0 $0 0
2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 0 0 0 0 $0 $0 0
3) Records of Stack Tests 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0
4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0
5) Records of All Compliance Reports Submitted 2 $0 $0 $0 2 4 0 0 0 0 $0 $0 0
6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 0 0 0 0 $0 $0 0
E. Personnel Training 40 $0 $0 $0 1 40 0 0 0 0 $0 $0 0
F. Time for Audits na












Recordkeeping Subtotal






0 $0 $0 0
Totals






0 $0 $0 0















a There are no new large liquid units expected to be constructed/reconstructed over the next 5 years


Sheet 12: Fac-NewLrgGas-Avg

Table 6.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)
New Large Gas Fuel Units
Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Stack Testing and Fuel Analysis Cost Per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes
1. Applications na












2. Surveys and Studies na












3. Reporting Requirements













A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 33 1,320 132 66 $166,226 $0 0 a
B. Required Activities













1. Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0 0 e
2. Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 e
3. Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 e
4. Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0 0 e
6. Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0 0 a
7. Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 a
8. Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0 0 a
9. Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0 0 a
11. Repeat Stack Test and Report if Switch Fuels
(for Hg and HCl)
24 $0 $16,000 $0 1 24 0 0 0 0 $0 $0 0 a,e
12. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 a,f
13. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0 0 a,f
14. Continuous Parameter Monitoring












j
Establish Site-specific monitoring plan (all) 40 $0
$0 1 40 0 0 0 0 $0 $0 0 a
Opacity













a) initial 10 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0 a
b) annual 10 $0 $0 $14,700 1 10 0 0 0 0 $0 $0 0 a
PM (only sources greater than 250 mmBtu/hr)













a) initial 10 $0 $0 $158,000 1 10 0 0 0 0 $0 $0 0 a
b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0 0 a
O2













a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0 0 a
b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0 0 a
Scrubber System Monitoring and Operation
(for units with wet scrubbers)














a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0 a
b) annual 10 $0 $0 $5,600 1 10 0 0 0 0 $0 $0 0 a
Bag Leak Detection System Operation
(sources that have fabric filters)














a) initial 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0 a
b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0 0 a
15. Annual Tune-up 12 $0 $2,875 $0 1 12 261 3,132 313 157 $394,408 $750,375 0 c
16. Mercury Fuel Spec Analysis 5 $0 $200 $0 12 60 0 0 0 0 $0 $0 0 h
C. Create Information na












D. Gather Information na












E. Report Preparation













1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 33 66 6.6 3.3 $8,311 $0 33 a
2) Notification of Compliance Status 8 $0 $0 $0 1 8 33 264 26.4 13.2 $33,245 $0 33 a
3) Annual Compliance Report 20 $0 $0 $0 1 20 33 660 66 33 $83,113 $0 33 a, e
4) Semi-annual Compliance Report 20 $0 $0 $0 2 40 0 0 0 0 $0 $0 0 a, e
5) Notification of Alternative Fuel Use 5 $0 $0 $0 1 5 0 0 0 0 $0 $0 0 i
Reporting Subtotal






6,258 $685,303 $750,375 99
4. Recordkeeping Requirements













A. Read and Understand Rule Requirements Included in 3a












B. Implement Activities na












C. Develop Record System na











d
D. Record Information













1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 0 0 0 0 $0 $0 0 a
2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 0 0 0 0 $0 $0 0 a
3) Records of Stack Tests 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0 a
4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0 a
5) Records of All Annual Compliance Reports Submitted 2 $0 $0 $0 2 4 33 132 13.2 6.6 $16,623 $0 0 a, e
6) Records of All Semi-Annual Compliance Reports
Submitted
2 $0 $0 $0 2 4 0 0 0 0 $0 $0 0 a, e
7) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 261 1,566 157 78.3 $197,204 $0 0 a
8) Records of Annual Tune-up 0.25 $0 $0 $0 1 0.25 261 65 6.53 3.26 $8,217 $0 261 c
E. Personnel Training 40 $0 $0 $0 1 40 33 1,320 132 66 $166,226 $0 0 g
F. Time for Audits na












Recordkeeping Subtotal






3,546 $388,269 $0

Totals






9,804 $1,073,572 $750,375 99















a In order to calculate a per year estimate of the number of boilers and facilities required to meet these rule requirements, the number of projected boilers and facilities is each divided by 3.

b A one-time requirement.

c Energy Audits are a requirement for existing units only.
d Assumes facility must already maintain records on boiler insurance and/or maintenance schedule as part of their operations. No new record system would be required.
e Only facilities with process gas (gas 2 units) subject to numerical emission limits are expected to be required to submit semi-annual compliance reports and conduct testing and monitoring (There will not be any new process gas units). Natural gas and refinery gas units are required to submit reports annually and conduct a tune-up. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.
f Process gas units are expected to demonstrate compliance with a stack test instead of a fuel analysis. However no new process gas units were estimated.













g For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes all new respondents will conduct training.













h Assume all units will fire natural gas, so fuel spec analysis not necessary.













i Assumed no units would fire an alternative fuel.













j Estimated number of units expected to require each type of parameter monitoring are consistent with the estimated number of units expected to install controls, as outlined in the memorandum: "Revised (November 2011) Methodology for Estimating Cost and Emissions Impacts for Industrial, Commercial, Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants – Major Source." Small edits to the MACT floor dataset were made after the impacts analysis and ICR burden estimates were prepared. These edits are not reflected in the ICR or impacts analysis, but the changes are incorporated into the burden estimates for the final rule.

Sheet 13: Fac - ExistSmlSolid-Avg

Table 7.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)


Existing Small and Limited Use Solid Fuel Units


Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up Cost per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes


1. Applications na















2. Surveys and Studies na















3. Reporting Requirements
















A. Familiarization with Rule Requirements 5 $0 $0 $0 1 5 5 25 3 1 $3,148 $0 0 a

Should this be 5 existing respondents, see year 1 totals in table 3
B. Required Activities
















1. Conduct Energy Audit
















a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b,c, d


b) Industrial 20 $18,292 $0 $0 1 20 0 0 0 0 $0 $0 0 b,c, d


2. Biennual Tune-Up 12 $0 $2,228 $0 0.5 6 44 264 26.4 13.2 $33,245 $98,032 0 c,i


C. Create Information na















D. Gather Information na















E. Report Preparation
















1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0 a


2) Notification of Compliance Status 8 $0 $0 $0 1 8 0 0 0 0 $0 $0 0 c


3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 5 13 1.25 0.63 $1,574 $0 3 f


4) Initial Report on results of Energy Audit 5 $0 $0 $0 1 5 0 0 0.00 0.00 $0 $0 0 c










302 30 15






Reporting Subtotal






347 $37,967 $98,032 3



4. Recordkeeping Requirements
















A. Familiarization with Rule Requirements Included in 3a















B. Implement Activities na















C. Develop Record System na











e


D. Record Information
















1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 5 5 0.50 0.25 $630 $0 0 c


2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 0 0 0 0 $0 $0 0 g


3) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 44 11 1.10 0.55 $1,385 $0 0 c


E. Personnel Training 40 $0 $0 $0 1 40 3 120 12 6 $15,111 $0 0 h


F. Time for Audits na















Recordkeeping Subtotal






156 $17,126 $0 0



Totals






503 $55,094 $98,032 3





















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 5 hours for small units.


b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution facility NAICS codes in the 2008 combustion unit survey database, 12% of facilities are in the commercial sector while the remaining 88% of facilities are in the industrial sector.




c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting reports and conducting the required recordkeeping. Annualized cost of $2228 for a tune-up is calculated considering a biennual schedule.




d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals. It is assumed that all will be industrial facilities since industrial is the vast majority of projected units.


e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.
















f Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.
















g Small units are not required to maintain records on startup, shutdown and malfunction.
















h For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.
















i Assumes a biennial tune-up is conducted on half of all units each year. Some very small boilers (<5mmBtu/hr) or limited use boilers which operate less than 100 hours annually qualify for tune-ups every five years, however they would still incur an initial tune-up. For the time period of this ICR, there will not be a difference in burden associated with biennial vs 5-year tune-ups for existing units.



Sheet 14: Fac - ExistSmlLiquid-Avg

Table 8.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)

Existing Small and Limited Use Liquid Fuel Units

Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up Cost per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes

1. Applications na














2. Surveys and Studies na














3. Reporting Requirements















A. Familiarization with Rule Requirements 5 $0 $0 $0 1 5 45 225 23 11 $28,334 $0 0 a

B. Required Activities















1. Conduct Energy Audit















a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d

b) Industrial 20 $18,292 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d

2. Biennual Tune-Up 12 $0 $2,228 $0 0.5 6 385 2,310 231.0 115.5 $290,895 $857,780 0 c, f, i

C. Create Information na














D. Gather Information na














E. Report Preparation















1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0 a

2) Notification of Compliance Status 8 $0 $0 $0 1 8 0 0 0.0 0.0 $0 $0 0 c

3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 45 113 11.3 5.6 $14,167 $0 23 c, f

4) Initial Report on results of Energy Audit 5 $0 $0 $0 1 5 0 0 0 0.0 $0 $0 0 c

Reporting Subtotal






3,045 $333,396 $857,780 23


4. Recordkeeping Requirements















A. Familiarization with Rule Requirements Included in 3a














B. Implement Activities na














C. Develop Record System na











e

D. Record Information















1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 45 45 4.5 2.3 $5,667 $0 0 c

2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 0 0 0 0 $0 $0 0 c, g

3) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 385 96 9.6 4.8 $12,121 $0 0 c, f

E. Personnel Training 40 $0 $0 $0 1 40 23 920 92 46 $115,854 $0 0 h

F. Time for Audits na














Recordkeeping Subtotal






1220 $133,642 $0 0


Totals






4,265 $467,037 $857,780 23



















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 5 hours for small units.

b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 88% of facilities are in the industrial sector while the remaining 12% of facilities are in the commercial sector.



c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting reports and conducting the required recordkeeping. Annualized cost of $2228 for a tune-up is calculated considering a biennual schedule.



d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.

e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.















f Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.















g Small units are not required to maintain records on startup, shutdown and malfunction.















h For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.














edited footnote
i Assumes a biennial tune-up is conducted on half of all units each year. Some very small boilers (<5mmBtu/hr) or limited use boilers which operate less than 100 hours annually qualify for tune-ups every five years, however they would still incur an initial tune-up. For the time period of this ICR, there will not be a difference in burden associated with biennial vs 5-year tune-ups for existing units.


Sheet 15: Fac - ExistSmlGas-Avg

Table 9.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)

Existing Small and Limited Use Gas Fuel Units

Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Emission Test Contractor Hours Per Occurrence (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up Cost per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes

1. Applications na















2. Surveys and Studies na















3. Reporting Requirements
















A. Familiarization with Rule Requirements 5
$0 $0 $0 1 5 1,027 5,135 514 257 $646,643 $0 0 a

B. Required Activities
















1. Conduct Energy Audit
















a) Commerical 20
$854 $0 $0 1 20 0 0 0.00 0.00 $0 $0 0 b,c,d

b) Industrial 20
$18,292 $0 $0 1 20 0 0 0.00 0.00 $0 $0 0 b,c,d

2. Biennial Tune-Up 12
$0 $1,580 $0 0.5 6 8,811 52,866 5,286.6 2,643.3 $6,657,336 $13,921,380 0 c,f,i

C. Create Information na















D. Gather Information na















E. Report Preparation
















1) Initial Notification that Source is Subject 2
$0 $0 $0 1 2 0 0 0 0 $0 $0 0 a

2) Notification of Compliance Status 8
$0 $0 $0 1 8 0 0 0.00 0.00 $0 $0 0 c

3) Biennial Compliance Report 5
$0 $0 $0 0.5 2.5 1,027 2,568 256.75 128.38 $323,321 $0 514 c,f

4) Initial Report on results of Energy Audit 5
$0 $0 $0 1 5 0 0 0.00 0.00 $0 $0 0 c

Reporting Subtotal







69,654 $7,627,300 $13,921,380 514


4. Recordkeeping Requirements
















A. Familiarization with Rule Requirements Included in 3a















B. Implement Activities na















C. Develop Record System na












e

D. Record Information
















1) Records of All Notifications and Compliance Reports Submitted 2 0 $0 $0 $0 0.5 1 1,027 1,027 102.70 51.35 $129,329 $0 0 c

2) Records of Startup, Shutdown, Malfunction 15 0 $0 $0 $0 1 15 0 0 0 0 $0 $0 0 c,g

3) Biennial Tune-Up Records 0.5
$0 $0 $0 0.5 0.25 8,811 2,203 220.28 110.14 $277,389 $0 0 c,f

E. Personnel Training 40
$0 $0 $0 1 40 514 20,560 2,056 1,028 $2,589,090 $0 0 h

F. Time for Audits na















Recordkeeping Subtotal







27358 $2,995,808 $0 0


Totals







97,012 $10,623,108 $13,921,380 514




















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 5 hours for small units.

b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 88% of facilities are in the industrial sector while the remaining 12% of facilities are in the commercial sector.



c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting reports and conducting the required recordkeeping. Annualized cost of $2228 for a tune-up is calculated considering a biennual schedule.



d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.

e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.
















f Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.
















g Small units are not required to maintain records on startup, shutdown and malfunction.
















h For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.















edited footnote
i Assumes a biennial tune-up is conducted on half of all units each year. Some very small boilers (<5mmBtu/hr) or limited use boilers which operate less than 100 hours annually qualify for tune-ups every five years, however they would still incur an initial tune-up. For the time period of this ICR, there will not be a difference in burden associated with biennial vs 5-year tune-ups for existing units.


Sheet 16: Fac-NewSmlSolid-Avg

Table 10.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)
New Small Solid Fuel Units
Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up Cost per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes
1. Applications na













2. Surveys and Studies na













3. Reporting Requirements














A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 1 40 4 2 $5,037 $0 0 a
B. Required Activities














1. Biennial Tune-Up 12 $0 $2,228 $0 0.5 6 2 12 1.2 0.6 $1,511 $4,456 0 a
C. Create Information na













D. Gather Information na













E. Report Preparation














1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 1 2 0 0 $252 $0 1 a
2) Notification of Compliance Status 8 $0 $0 $0 1 8 1 8 1 0 $1,007 $0 1 a
3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 1 2.5 0.25 0.13 $315 $0 1 d
Reporting Subtotal






74.2 $8,122 $4,456 3

4. Recordkeeping Requirements














A. Read and Understand Rule Requirements Included in 3a













B. Implement Activities na













C. Develop Record System na











b
D. Record Information














1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 1 1 0.10 0.05 $126 $0 0 a
2) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 2 1 0.05 0.03 $63 $0 0 a, d
E. Personnel Training 40 $0 $0 $0 1 40 1 40 4 2 $5,037 $0 0 c
F. Time for Audits na













Recordkeeping Subtotal






47.7 $5,226 $0 0

Totals






122 $13,348 $4,456 3

















a Assumes one respondent with new small solid units per 3-year period, and that a tune-up is conducted on all units.


b Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.


c For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes all new respondents will conduct training.














d Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.















Sheet 17: Fac-NewSmlLiquid-Avg

Table 11.B.: Annual Respondent Burden and Cost -- NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal) – Year 2
New Small Liquid Fuel Units
Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up Cost per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes
1. Applications na












2. Surveys and Studies na












3. Reporting Requirements













A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 0 0 0 0 $0 $0 0 a
B. Required Activities













1. Biennial Tune-Up 12 $0 $2,228 $0 0.5 6 0 0 0 0 $0 $0 0
C. Create Information na












D. Gather Information na












E. Report Preparation













1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 0 0 0 0 $0 $0 0
2) Notification of Compliance Status 8 $0 $0 $0 1 8 0 0 0 0 $0 $0 0
3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 0 0 0 0 $0 $0 0
Reporting Subtotal






0 0 0 0
4. Recordkeeping Requirements













A. Read and Understand Rule Requirements Included in 3a












B. Implement Activities na












C. Develop Record System na












D. Record Information













1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 0 0 0 0 $0 $0 0
2) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 0 0 0 0 $0 $0 0
E. Personnel Training 40 $0 $0 $0 1 40 0 0 0 0 $0 $0 0
F. Time for Audits na












Recordkeeping Subtotal






0 $0 $0 0
Totals






0 $0 $0 0















a There are no new small solid units expected to be constructed/reconstructed over the next 3 years.


Sheet 18: Fac-NewSmlGas-avg

Table 12.B.: Annual Respondent Burden and Cost -- NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal) – Year 2

New Small Gas Fuel Units

Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up Cost per Occurrence (D) Other Non-Labor Costs Per Occurrence (E) Number of Occurrences Per Respondent Per Year (F) Technical Hours per Respondent Per Year
(A X E)
(G) Number of Respondents Per Year (H) Technical Hours per Year @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes

1. Applications na














2. Surveys and Studies na














3. Reporting Requirements















A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 41 1,640 164 82 $206,523 $0 0 a

B. Required Activities















1. Biennial Tune-Up 12 $0 $2,228 $0 0.5 6 326 1,956 195.6 97.8 $246,316 $726,328 0 a,e,f

C. Create Information na














D. Gather Information na














E. Report Preparation















1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 41 82 8.2 4.1 $10,326 $0 41 a

2) Notification of Compliance Status 8 $0 $0 $0 1 8 41 328 32.8 16.4 $41,305 $0 41 a

3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 41 103 10.3 5.1 $12,908 $0 21 d,e

Reporting Subtotal






4,725 517,377 726,328 103


4. Recordkeeping Requirements















A. Read and Understand Rule Requirements Included in 3a














B. Implement Activities na














C. Develop Record System na











b

D. Record Information















1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 41 41 4.1 2.1 $5,163 $0 0 a

2) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 326 82 8.2 4.1 $10,263 $0 0 a,e,f

E. Personnel Training 40 $0 $0 $0 1 40 41 1,640 164 82 $206,523 $0 0 c

F. Time for Audits na














Recordkeeping Subtotal






2027 $221,949 $0 0


Totals






6,752 $739,326 $726,328 103



















a In order to calculate a per year estimate of the number of boilers and facilities required to meet these rule requirements, the number of projected boilers and facilities is each divided by 3.



b Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.



c For on-going training activities to keep personnel updated in order to implement compliance activities.















d Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.















e Assumes for boilers which performed a tune-up in year 1, the biennial tune-up would also occur in year 3.



f Very small boilers qualify for tune-ups every five years, however they would still incur an initial tune-up when they come online. For those boilers in year 1 which were performing their initial five-year tune-up, a tune-up in year 3 is not necessary. Four boilers would qualify for 5-year tune-ups and are thus not applicable to tune-ups in year 3.




Sheet 19: Capital vs. O&M

Annual Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)
Boiler Type
(B)
Number of Respondents (facilities)
(C)
Annual Capital/Startup Cost
(D)
Annual O&M
(E)
Annual O&M and Annualized Capital Costs

Existing Large Solid Units 121 $0 $74,866,304 $74,866,304
New Large Solid Units 3 $2,005,198 $1,218,750 $3,223,948
Existing Small and Limited Use Solid Units 5 $0 $98,032 $98,032
New Small Solid Units 1 $0 $4,456 $4,456
Existing Large Liquid Units 66 $0 $17,695,826 $17,695,826
New Large Liquid Units 0 $0 $0 $0
Existing Small and Limited Use Liquid Units 45 $0 $857,780 $857,780
New Small Liquid Units 0 $0 $0 $0
Existing Large Gaseous Units 669 $0 $18,867,183 $18,867,183
New Large Gaseous Units 33 $0 $750,375 $750,375
Existing Small and Limited Use Gaseous Units 1027 $0 $13,921,380 $13,921,380
New Small Gaseous Units 41 $0 $726,328 $726,328
Total 2,012 $2,005,198 $129,006,414 $131,011,612
Total (Rounded) 2,010 $2,000,000 $129,000,000 $131,000,000
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