Table 1a: Annual Respondent Burden and Cost for Private Facilities – NESHAP for Coal- and Oil-Fired Electric Utility Steam Generating Units (40 CFR Part 63, Subpart UUUUU) (Renewal) |
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Cells highlighted in blue denote values updated by ERG. All other cells use values EPA provided from calculations for the previous ICR. |
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Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
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Technical person-hours per occurrence |
No. of occurrences per respondent per year |
Technical person-hours per respondent per year (AxB) |
Respondents per year a |
Technical hours per year (CxD) |
Management hours per year (Ex0.05) |
Clerical hours per year (Ex0.10) |
Total cost per year ($) b |
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1. Applications |
N/A |
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2. Surveys and studies |
N/A |
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3. Acquisition, installation, and utilization of technology and systems |
160.6 |
1 |
160.6 |
0 |
0 |
0 |
0 |
0 |
Removed/revised all fields that applied only to new respondents |
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4. Report requirements |
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A. Familiarization with regulatory requirements |
1 |
1 |
1 |
268 |
268 |
13.4 |
26.8 |
$33,748.86 |
Updated # of respondents to # of footprints. Included familiarization burden since actual report submittals are due less often than quarterly |
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B. Required activities |
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Existing sources |
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Initial Annual performance test (PM, Methods 5 and 202) c |
27.8 |
1 |
27.8 |
407 |
11,313 |
566 |
1,131 |
1,424,577 |
Updated to # of units conducting testing by pollutant |
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Initial Annual performance test (HCl, Method 320) c |
26.4 |
1 |
26.4 |
100 |
2,647 |
132 |
265 |
333,367 |
Updated to # of units conducting testing by pollutant |
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Initial Annual performance test (Hg, Method 30B) c |
27.8 |
1 |
27.8 |
143 |
3,985 |
199 |
398 |
501,801 |
Updated to # of units conducting testing by pollutant |
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CEMS quarterly inspections d |
2.5 |
4 |
10 |
Tracy Curtis:
Updated to # of HCl/SO2 CEMS, assumes that hourly estimates apply on a unit basis. Note that data provided by OAQPS broke down CEMS for HCl/SO2, CPMS for Hg and PM
505 |
5,048 |
252 |
505 |
$635,694.46 |
Updated to # of units using HCl/SO2 CEMS. Updated to revised # of respondents |
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CEMS daily calibration drift tests d |
0.4 |
365 |
146 |
505 |
73,702 |
3,685.1 |
7,370.2 |
$9,281,139.06 |
Updated to # of units using HCl/SO2 CEMS. Updated to revised # of respondents |
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CEMS daily monitoring d |
0.25 |
365 |
91.25 |
505 |
46,063 |
2,303.17 |
4,606.3 |
$5,800,711.91 |
Updated to # of units using HCl/SO2 CEMS. Updated to revised # of respondents |
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All CEMS must follow appropriate performance specifications d |
14 |
1 |
14 |
505 |
7,067 |
353.4 |
706.7 |
$889,972.24 |
Updated to # of units using HCl/SO2 CEMS. Updated to revised # of respondents |
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New sources |
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Initial performance test (PM, Methods 5 and 202) |
27.8 |
1 |
27.8 |
0 |
0 |
0 |
0 |
0 |
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Initial performance test (HCl, Method 320) |
26.4 |
1 |
26.4 |
0 |
0 |
0 |
0 |
0 |
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Initial performance test (Hg, Method 30B) |
27.8 |
1 |
27.8 |
0 |
0 |
0 |
0 |
0 |
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CEMS quarterly inspections |
2.46 |
4 |
9.84 |
0 |
0 |
0 |
0 |
0 |
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CEMS daily calibration drift tests |
0.12 |
365 |
43.8 |
0 |
0 |
0 |
0 |
0 |
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CEMS daily monitoring |
0 |
365 |
0 |
0 |
0 |
0 |
0 |
0 |
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All CEMS must follow appropriate performance specifications |
7.3 |
365 |
2664.5 |
0 |
0 |
0 |
0 |
0 |
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C. Create information |
See 4B |
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D. Gather existing information |
See 4E |
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E. Write Report |
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Existing sources |
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Notification of CEMS demonstration |
5 |
1 |
5 |
0 |
0 |
0 |
0 |
0 |
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Notification of initial performance test |
3 |
1 |
3 |
0 |
0 |
0 |
0 |
0 |
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Performance test report |
See 4B |
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Notification of compliance status |
16.5 |
1 |
16.5 |
0 |
0 |
0 |
0 |
0 |
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Quality assurance program certification |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
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Startup, shutdown, and malfunction report (10% of respondents) |
10 |
1 |
10 |
26.8 |
268 |
13.4 |
26.8 |
$33,748.86 |
Updated to based on 10% of footprints. Updated to revised # of respondents |
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Semiannual compliance report |
75 |
2 |
150 |
268 |
40,200 |
2,010 |
4,020 |
$5,062,329.72 |
Updated to based on # of footprints. Updated to revised # of respondents |
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Site-specific performance evaluation test plan |
20 |
1 |
20 |
220 |
4,397 |
220 |
440 |
553,698 |
Updated to based on # of units estimated to conduct testing, assumes 20 hrs/plan/per unit. |
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Request to use alternative monitoring procedure (10% of respondents) |
5 |
1 |
5 |
22 |
110 |
5 |
11 |
13,842 |
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New sources |
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Initial notification |
3 |
1 |
3 |
0 |
0 |
0 |
0 |
0 |
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Notification of CEMS demonstration |
5 |
1 |
5 |
0 |
0 |
0 |
0 |
0 |
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Notification of initial performance test |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
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Performance test report |
See 4B |
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Notification of compliance status |
16.5 |
1 |
16.5 |
0 |
0 |
0 |
0 |
0 |
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Quality assurance program certification |
3 |
1 |
3 |
0 |
0 |
0 |
0 |
0 |
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Startup, shutdown, and malfunction report (10% of respondents) |
10 |
1 |
10 |
0 |
0 |
0 |
0 |
0 |
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Semiannual compliance report |
75 |
2 |
150 |
0 |
0 |
0 |
0 |
0 |
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Site-specific performance evaluation test plan |
20 |
1 |
20 |
0 |
0 |
0 |
0 |
0 |
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Request to use alternative monitoring procedure (10% of respondents) |
5 |
1 |
5 |
0 |
0 |
0 |
0 |
0 |
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Subtotal for Reporting Requirements |
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224,328 |
$24,564,630 |
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5. Recordkeeping requirements |
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A. Familiarization with regulatory requirements |
See 4A |
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B. Plan activities |
See 4B |
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C. Implement activities |
See 4B |
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D. Record data |
N/A |
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E. Time to transmit or disclose information |
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Existing sources |
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Tracy Curtis:
We are only assuming 10% of respondents will be reporting SSM in line 37, have adjusted the records of CEMS malfunctions accordingly.
Records of CEMS malfunctions (10% of respondents) |
1 |
12 |
12 |
26.8 |
322 |
16.1 |
32.2 |
$40,498.64 |
Updated to based on # of footprints. Updated to revised # of respondents |
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Records of startups, shutdowns, malfunctions, etc. |
1 |
12 |
12 |
268 |
3,216 |
160.8 |
321.6 |
$404,986.38 |
Updated to based on # of footprints. Updated to revised # of respondents |
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Records of monthly fuel use |
2 |
12 |
24 |
268 |
6,432 |
321.6 |
643.2 |
$809,972.76 |
Updated to based on # of footprints. Updated to revised # of respondents |
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New sources |
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Records of CEMS malfunctions (10% of respondents) |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
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Records of startups, shutdowns, malfunctions, etc. |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
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Records of monthly fuel use |
2 |
12 |
24 |
0 |
0 |
0 |
0 |
0 |
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F. Time to train personnel |
80 |
1 |
80 |
0 |
0 |
0 |
0 |
0 |
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G. Time for audits |
N/A |
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Subtotal for Recordkeeping Requirements |
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11,465 |
$1,255,458 |
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TOTAL LABOR BURDEN AND COSTS (ROUNDED) e |
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236,000 |
$25,800,000 |
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TOTAL CAPITAL AND O&M COST (ROUNDED) e |
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$86,600,000 |
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GRAND TOTAL (ROUNDED) e |
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$112,000,000 |
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Footnotes: |
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a EPA estimates an average of 727 units at 322 existing facilities and no new units per year will be subject to the NESHAP over the next 3 years. Of these, 268 facilities are owned by private industry. |
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b This ICR uses the following labor rates: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry. |
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c Estimates are based on the number of privately-owned EGUs complying with annual testing requirements for PM, HCl, and Hg, in lieu of CEMS/CPMS monitoring for these pollutants and includes 407 EGUs conducting Method 5 and Method 202 testing, 100 EGUs conducting Method 320 testing, and 143 EGUs conducting Method 30B testing. |
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d Assumes that 505 privately-owned EGUs use HCl or SO2 CEMs. |
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e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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Assumptions and calculation area: |
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Respondent Labor Rates |
Loaded |
Unloaded |
Rate (110%) |
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Technical |
$112.98 |
$53.80 |
2.1 |
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Managerial |
$149.35 |
$71.12 |
2.1 |
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Clerical |
$54.81 |
$26.10 |
2.1 |
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Average Annual Capital Costs for Performance Testing |
From MATS analysis November 2011--Stef Johnson |
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HAP |
Test Method |
Cost per Test |
Number of Tests |
Total Cost |
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PM |
Methods 5 and 202 |
$15,522 |
407 |
$6,316,327 |
updated - # of test is based on # of units testing by pollutant |
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HCl |
Method 320 |
$20,444 |
100 |
$2,050,054 |
updated - # of test is based on # of units testing by pollutant |
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Hg |
Method 30B |
$20,006 |
143 |
$2,867,628 |
updated - # of test is based on # of units testing by pollutant |
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Total |
$55,972 |
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$11,234,009 |
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Average Annual Capital Costs for CEMS Installation (Labor and Other Direct Costs) |
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Equipment |
CEM |
Cost per Installation |
Number of Installations |
Total Cost |
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new beta gauge PM CEMS |
PM |
$65,388 |
0 |
$0 |
updated - no new respondents |
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new FTIR CEMS |
HCl |
$111,045 |
0 |
$0 |
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new Hg CEMS |
Hg |
$174,002 |
0 |
$0 |
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Total |
$350,434 |
0 |
$0 |
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Total Capital Cost: |
$11,234,009 |
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Average Annual Operation and Maintenance (O&M) Costs |
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CEM |
Costs per Monitor |
Tracy Curtis:
Number of monitors has been updated based on the % of EGUs conducting CPMS or CEMS monitoring (see the %CEMSCPMSvs.testing tab)
Number of Monitors |
Total Annual Cost |
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Labor |
Testing |
ODC's |
Total |
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PM |
$11,818 |
$20,779 |
$8,902 |
$41,499 |
198 |
$8,223,086 |
updated to reference annual costs w. recovery from CEMS Cost model as applied to CEMS from existing units; Updated number of monitors based on OAQPS percentage of ERPs using CEMs by pollutant |
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HCl |
$14,789 |
$10,932 |
$15,897 |
$41,618 |
505 |
$21,008,935 |
updated to reference annual costs w. recovery from CEMS Cost model as applied to CEMS from existing units; Updated number of monitors based on OAQPS percentage of ERPs using CEMs by pollutant |
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Hg |
$19,959 |
$40,012 |
$40,035 |
$100,006 |
462 |
$46,177,033 |
updated to reference annual costs w. recovery from CEMS Cost model as applied to CEMS from existing units; Updated number of monitors based on OAQPS percentage of ERPs using CEMs by pollutant |
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Total |
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$75,409,054 |
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