Burden Calculation Tables

2253t04.xlsx

NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR part 63, subpart JJJJJJ) (Reinstatementl)

Burden Calculation Tables

OMB: 2060-0668

Document [xlsx]
Download: xlsx | pdf

Overview

Table 1 (Respondent Summary)
Table 2 (Agency)
Base Data
LrgSolid
LrgLiquid
SmlSolid
SmlLiquid
Respondents&Responses
Capital vs. O&M


Sheet 1: Table 1 (Respondent Summary)

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












TOTAL LABOR BURDEN AND COSTS





Fuel Category Average No. Respondents Average No. Responses Reporting Burden (hrs) Recordkeeping Burden (hrs) Total Labor Burden (hrs) Total Labor Cost ($) Total Capital and O&M Cost ($) Total Costs ($)


Large Solid 2,100 3,026 98,006 25,480 123,485 $14,065,745 $6,060,260 $20,126,005


Large Liquid 5,264 3,119 88,275 298,130 386,405 $44,013,866 $22,453,728 $66,467,594


Small Solid 5,708 2,952 65,129 14,769 79,898 $9,100,847 $6,358,523 $15,459,370


Small Liquid 87,303 45,631 1,009,544 225,897 1,235,440 $140,724,151 $97,255,542 $237,979,693


Total 100,374 54,728 1,260,953 564,276 1,825,228 $207,904,609 $132,128,053 $340,032,662


Grand Total (rounded)1



1,830,000 $208,000,000 $132,000,000 $340,000,000
33 hrs/response





Rounded by Sector1


Total Private Sector (49% of Respondents) 49,183 26,817 617,867 276,495 894,000 101,900,000 64,700,000 166,600,000


Total Public Sector (51% of Respondents) 51,191 27,911 643,086 287,781 931,000 106,000,000 67,400,000 173,400,000


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











Sheet 2: Table 2 (Agency)

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














Burden Item A B C D E F G
Technical Person-Hours per Occurrence Occurrences per Year Technical Person-Hours per Respondent per Year (C=AxB) Technical Hours per Year (D=C) Management Hours per Year (E=Dx0.05) Clerical Hours per Year (F=Dx0.10) Total Cost per Year ($) a
1. Read and Understand Rule Requirementsb 40 0 0 0 0 0 $0
2. Enter and Update Information into Agency Recordkeeping Systemc 2 1,129.84 2,259.68 2,259.68 112.98 225.97 $123,544.40
3. Required Activities






a) Observe Initial Stack/Performance Testd 40 17 664 664 33 66 $36,303.20
b) Observe Repeat Performance Teste 40 1.7 66 66 3.3 6.6 $3,630.32
c) Review Operating Parametersf 2 83 166 166 8.3 16.6 $9,075.80
d) Review Continuous Parameter Monitoringg 2 5,560 11,119 11,119 556.0 1,111.9 $607,914.65
4. Excess Emissions Enforcement Activities and Inspectionsh 24 8.3 199.2 199.2 9.96 19.92 $10,890.96
5. Notification Requirements






a) Review Initial Notification that Sources are Subject to the Standardc 2 1,129.84 2,259.68 2,259.68 112.98 225.97 $123,544.40
b) Review Notification of Initial Performance Tests and Review Test Planf 20 83 1,660 1,660 83 166 $90,758.01
c) Review Notification of Compliance Statusc 2 1,129.84 2,259.68 2,259.68 112.98 225.97 $123,544.40
6. Reporting Requirements




0
a) Review Annual Compliance Report 4 2,424.17 9,696.69 9,696.69 484.83 969.67 $530,151.71
b) Review Biennial Compliance Report 2 50,043.83 100,087.66 100,087.66 5,004.38 10,008.77 $5,472,142.59
c) Review Initial Report on Energy Audit Resultsi 2 0 0 0 0 0 $0
7. Travel Expenses for Performance Tests Observedj





$20,159.0
TOTAL ANNUAL BURDEN AND COST (ROUNDED)k


150,000 $7,150,000








a. This ICR uses the following labor rates: $48.75 for technical, $65.71 for managerial, and $26.38 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2018 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.
b. No burden will be incurred over the three-year ICR period, as this was a one-time requirement during the previous ICR period.






c. All new sources must submit initial notifications and notifications of compliance status, regardless of subcategory.
d. It is assumed that EPA will observe 20% of initial performance tests.
e. It is assumed that 10% of initial performance tests will be repeated, which will be observed by EPA.






f. The number of occurrences is based on the number of new facilities that will test and set/submit operating limits. All new sources must submit operating limits, regardless of subcategory.






g. The number of occurrences is based on the number of facilities maintaining records of control device parameters.






h. It is assumed that 10% of new facilities will have exceedances, requiring EPA enforcement.






i. All existing sources at the time of promulgation of the standard were required to complete the energy audit by the conclusion of the previous ICR period; therefore, no new or existing sources will incur this burden over the next three years.
j. The total cost is based on the number of performance tests observed by EPA multiplied by the cost of each trip. Based on EPA experience with other rulemakings, each trip is estimated to be 3 days x ($110 hotel + $58 meals/incidentals) + ($600 round trip) = $1,104 per trip.
k. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.







Sheet 3: Base Data

Boilers per Facility 2























Existing Boiler Data
























Number of Boilers Represented by Model (Over 3-Yr ICR Period)





Number of Facilities Represented by Model (Over 3-Yr ICR Period)




Fuel Category Size Category Tracy Curtis: Updated the base data unit totals to reflect growth from 3 year period of prior ICR. Total
Source
Classification
Total
Fuel Category Size Category Total
Source
Classification
Total
Biomass <10 7,772 7,632 Existing Small Solid 11,219
Biomass <10 3,886.0 3,816.0 Existing Small Solid 5,610
>= 10 to 100 3,440 3,429 Existing Large Solid 4,159
>= 10 to 100 1,720.0 1,714.5 Existing Large Solid 2,080
>100 146 97 Existing Small Liquid 170,648
>100 73.0 48.5 Existing Small Liquid 85,324
Coal <10 3,447 3,292 Existing Large Liquid 10,203
Coal <10 1,723.5 1,646.0 Existing Large Liquid 5,102
>= 10 to 100 573 573 Grand Total 196,229
>= 10 to 100 286.5 286.5 Grand Total* 98,115
>100 0 0


>100 0 0 *Roundup/down functions used above to reconcile # facilities with # sources (i.e., 196,229 sources / (2 sources/facility) must equal 98,115 facilities)
Liquid <10 170,648 164,711


Liquid <10 85,324.0 82,355.5
>= 10 to 100 10,064 9,577


>= 10 to 100 5,032.0 4,788.5
>100 139 139


>100 69.5 69.5
Grand Total 196,229 189,450


Grand Total 98,115 94,725



6,779





3,390

Assume units with bag leak detection will have a bag leak detection monitor Otherwise, all units will have an opacity monitor 2015 Existing Facilities End of Yr Units End of Yr









189450 191710 94725 95855
BLD Monitors


Opacity monitors




193970
96985
Size Category Total

Size Category Total



196230
98115
Coal >10 80

< 10 0










>= 10 to 100 0










>100 0










Grand Total 0
































New Boiler Data
























Number of Boilers Represented by Model (Over 3-Yr ICR Period)




Number of Facility Represented by Model (Over 3-Yr ICR Period)





Fuel Category Size Category 3-Yr Total Sources w/ Size Category >30 MMBtu/hr that will have PM costs covered by NSPS (Part 60, Subparts Db or Dc) Source
Classification
3-Yr Total Fuel Category Size Category 3-Yr Total Source
Classification
Facilities
(3-Yr Total)
Facilities/Yr
Biomass <10 140 0 New Small Solid 295 Biomass <10 70.0 New Small Solid 147.5 49.17
>= 10 to 100 11 0 New Large Solid 60 >= 10 to 100 5.5 New Large Solid 30.0 10.00
>100 49 49 New Small Liquid 5,937 >100 24.5 New Small Liquid 2,968.5 989.50
Coal <10 155 0 New Large Liquid 487 Coal <10 77.5 New Large Liquid 243.5 81.17
>= 10 to 100 0 0 Grand Total 6,779 >= 10 to 100 0 Grand Total 3,390 1,130
>100 0 0 New units/yr 2,260 >100 0



Liquid <10 5,937 0

Liquid <10 2,968.5



>= 10 to 100 487 0

>= 10 to 100 243.5



>100 0 0

>100 0



Grand Total 6,779 49

Grand Total 3,390
















BLD Monitors


Opacity monitors







Size Category Total

Size Category Total






new oil >10 45

new biomass >10 60










new oil >10 442



















*All new coal and residual liquid units will have Fabric filter installed and will be assumed to use bag leak detection monitors.











*All new units >100 will install a CO monitor











*All biomass and distillate liquid units will install an opacity monitor since they are not expected to install a FF to meet PM limits.


















































Respondent Labor Rates


Agency Labor Rates & Per Diem Info




















Category Rate

Category Rate






Technical $117.92

Managerial $65.71






Clerical $57.02

Clerical $26.38






Managerial $147.40

Technical $48.75






General Contractor $80.00

Hotel $110






Certfied Energy Audit Contractor $56.78

Meals $58










Airfare $600










Trip Length 3






Other Data
























Percent of Stack Tests Observed 20%








Estimated Percent Retesting 10%








Estimated Percent Emission Exceedences 10%


































Affirmative Defense











No. of units claiming affirmative defense
0









Hours per unit
30









Cost in labor
0










Sheet 4: LrgSolid

Table 1A: Annual Respondent Burden and Cost – Existing and New Large Solid Fuel Boilers, NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal)


































Burden Item A


B C D E F G H





Technical Person-Hours per Occurrence Certified Energy Audit Cost per Occurrence Stack Testing and Fuel Analysis Cost per Occurrence Other Non-Labor Costs per Occurrence Occurrences per Respondent per Year Technical Person-Hours per Respondent per Year (C=AxB) Respondents per Year a Technical Hours per Year (E=CxD) Clerical Hours per Year (F=Ex0.10) Management Hours per Year (G=Ex0.05) Total Cost per Year ($) b Total Non-Labor Annual Costs Total Number of Responses per Year



1. Applications N/A















2. Surveys and Studies N/A















3. Reporting Requirements
















A. Read and Understand Rule Requirements (new sources)c 40 $0 $0 $0 1 40 10 400 40 20 $52,397 $0 0



Familiarization with Rule Requirements (existing sources) 1 $0 $0 $0 1 1 2,089.5 2,090 209 104 $273,709 $0 0



B. Required Activities
















1) Conduct Energy Audit
















a) Industriald, e 20 $18,292 $0 $0 1 20 0 0 0 0 $0 $0 0



b) Commerciald, e 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0



2) Initial Stack Test (Hg)f, g 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0 0



3) Initial Stack Test (CO)f 12 $0 $6,000 $0 1 12 0 0 0 0 $0 $0 0



4) Initial Stack Test (PM)f, h 12 $0 $8,000 $0 1 12 1.83 21.96 2.2 1.1 $2,877.11 $14,640 0



5) Triennial Stack Test (Hg)f 12 $0 $5,000 $0 0.33 3.96 Tracy Curtis: includes 1/3 of existing coal boilers 95.5 378.2 37.8 18.9 $49,538.82 $157,575 0



6) Triennial Stack Test (CO)f 12 $0 $6,000 $0 0.33 3.96 95.5 378.2 37.8 18.9 $49,538.82 $189,090 0



7) Triennial Stack Test (PM)f, h 12 $0 $8,000 $0 0.33 3.96 ERG: =1.83 x 2 + 1/3*(5.5 x 2) (includes 2/3 new biomass facilities >10 + 1/3 of all new biomass facilities >10 from prior 2 ICRs assuming constant 5.5 growth rate 7.33 29.01 2.90 1.45 $3,799.95 $19,342 0



8) Initial Fuel Analysis for Hg Contentg 5 $0 $200 $0 1 5 0 0 0 0.00 $0 $0 0



9) Monthly Fuel Analysis for Hg Contentg 5 $0 $200 $0 12 60 0 0 0 0 $0 $0 0



10) Continuous Parameter Monitoring
















a) Establish Site-Specific Monitoring Plan (Hg, CO, and PM)f, i 40 $0 $0 $0 1 40 10 400 40 20 $52,396.80 $0 0



b) Opacity (All Sources with ESPs)
















i) Initialj 10 $0 $0 $43,100 1 10 1.83 $18.3 $1.83 $0.92 $2,398 $78,873 0



ii) Annualj 10 $0 $0 $14,700 1 10 Tracy Curtis: 1.83x2 + 11 facilities (5.5 x 2) from last two ICRs that will continue annual activities 14.66 $146.6 $14.66 $7.33 $19,203.43 $215,502 0



c) BLD System Operation (All Sources with Fabric Filters)
















i) Initialk 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0



ii) Annualk 10 $0 $0 $9,700 1 10 Tracy Curtis: All facilities w/ existing coal units (no new units) 286.5 2,865 287 143 $375,292.08 $2,779,050 0



11) Biennial Tune-Upl 12 $0 $2,875 $0 0.5 6 1,813 10,878 1,088 544 $1,424,930.98 $2,606,187.5 0



C. Create Information N/A















D. Gather Information N/A















E. Report Preparation
















1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 10 20 2 1 $2,619.84 $0 10



2) Notification of Compliance Status 8 $0 $0 $0 1 8 10 80 8 4 $10,479.36 $0 10



3) Initial Report on Results of Energy Auditd 5 $0 $0 $0 1 5 0 0 0 0 $0 $0 0



4) Annual Compliance Report 30 $0 $0 $0 1 30 2,099.5 62,985 6,299 3,149 $8,250,531.12 $0 2,100



5) Biennial Compliance Reportl 5 $0 $0 $0 0.5 2.5 1,813 4,532.5 453.3 226.6 $593,721.98 $0 907



Subtotal for Reporting Requirements






98,006 $11,163,434 $6,060,260 3,026



4. Recordkeeping Requirements
















A. Familiarization with Rule Requirements See 3A















B. Implement Activities N/A















C. Develop Record Systemm N/A















D. Record Information
















1) Records of Operating Parameter Valuesf 20 $0 $0 $0 1 20 295.7 5,913 591 295.7 $774,608.09 $0 0



2) Records of Deviationsf 15 $0 $0 $0 1 15 295.7 4,435.1 443.5 221.8 $580,955.99 $0 0



3) Records of Stack Testsf 2 $0 $0 $0 1 2 295.7 591 59.1 29.6 $77,461.02 $0 0



4) Records of Monitoring Device Calibrationsf 2 $0 $0 $0 1 2 295.7 591 59.1 29.6 $77,461.02 $0 0



5) Records of All Compliance Reports Submittedf 2 $0 $0 $0 2 4 2,099.5 8,398 839.8 419.9 $1,100,070.82 $0 0



6) Records of Monthly Fuel Usef 0.5 $0 $0 $0 12 6 295.7 1,774 177.4 88.7 $232,382.17 $0 0



7) Records of Biennial Tune-Up 0.5 $0 $0 $0 0.5 0.25 1,813 453.3 45.3 22.7 $59,372.04 $0 0



E. Personnel Training N/A















F. Time for Audits N/A















Subtotal for Recordkeeping Requirements






25,480 $2,902,311 $0 0



TOTAL LABOR BURDEN AND COST









$14,065,745





TOTAL CAPITAL AND O&M COST










$6,060,260




GRAND TOTAL






123,485 $20,126,005
3,026



N/A - Not Applicable












Notes (Units vs. Respondents):


a. On average, over the 3-year period of this ICR, we estimate 4,179 existing large solid boilers (i.e., biomass- and coal-fired boilers >10 MMBtu/hr) at 2,089.5 facilities will be subject to the rule. We also estimate 20 new boilers at 10 facilities per year, all of which are biomass-fired, for a total of 4,199 boilers at 2,099.5 facilities. 4179 2089.5 4199 2099.5
b. This ICR uses the following labor rates: $117.92 for technical, $147.40 for managerial, and $57.02 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2018, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.



c. This burden applies to new sources only. The burden on existing sources to read and understand rule requirements and submit initial notifications was incurred during a previous ICR period. It is assumed that existing sources will take 1 hour to refamiliarize themselves with the rule requirements each year.
















d. This burden applies to existing large solid fuel boilers only. All existing sources were required to complete the energy audit by the conclusion of the previous ICR period; therefore, no new or existing sources will incur this burden over the next three years.



e. Cost per occurrence for certified energy audit professionals includes a phone screening to discuss the facility prior to a visit, a 2- to 4-hour site visit, and an additional 2 to 4 hours to prepare a follow-up report on recommendations and findings. Cost depends on whether the source is industrial or commercial. It is assumed that 10% of sources will be industrial and 90% will be commercial.



f. Only existing and new large coal boilers are subject to numerical mercury (Hg) and carbon monoxide (CO) limits, while new large coal and biomass boilers are subject to particulate matter (PM) limits.



g. All projected large solid fuel boilers are expected to comply through stack testing instead of the fuel testing compliance option.



h. Only boilers <30 MMBtu/hr that are not subject to limits under the NSPS (40 CFR Part 60 Subparts Db, Dc) will incur additional testing, monitoring, recordkeeping and reporting costs under this rule. It is estimated that 11 boilers (5.5 facilities, assuming 2 boilers per facility) will be subject to additional testing.



i. Sources demonstrating compliance with any applicable emission limits through stack testing must develop a site-specific monitoring plan. All new large solid fuel units are expected to develop this plan.



j. All new biomass boilers >10 MMBtu/hr are expected to meet PM limits with an electrostatic precipitator (ESP); therefore, those sources will install opacity monitors.



k. All new coal boilers >10 MMBtu/hr are expected to install fabric filters equipped with bag leak detection (BLD) systems instead of opacity monitors. No new large coal boilers are projected over the three-year ICR period.



l. Only existing large biomass boilers are subject to biennial tune-ups.



m. It is assumed that facilities must already maintain records on boiler insurance and/or maintenance scheduling; therefore, no new record system would be required.

















Sheet 5: LrgLiquid

Table 1B: Annual Respondent Burden and Cost – Existing and New Large Liquid Fuel Boilers, NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal)




































Burden Item A



B C D E F G H





Technical Person-Hours per Occurrence Certified Energy Audit Cost per Occurrence Stack Testing and Fuel Analysis Cost per Occurrence Tune-Up Cost per Occurrence Other Non-Labor Costs per Occurrence Occurrences per Respondent per Year Technical Person-Hours per Respondent per Year (C=AxB) Respondents per Year a Technical Hours per Year (E=CxD) Clerical Hours per Year (F=Ex0.10) Management Hours per Year (G=Ex0.05) Total Cost per Year ($) b Total Non-Labor Annual Costs Total Number of Responses per Year



1. Applications N/A
















2. Surveys and Studies N/A
















3. Reporting Requirements

















A. Read and Understand Rule Requirements (new sources)c 40 $0 $0 $0 $0 1 40 81.17 3,247 325 162 $425,304.83 $0 0



Familiarization with Rule Requirements (existing sources) 1 $0 $0 $0 $0 1 1 5,183 5,183 518 259 $678,887.96 $0 0



B. Required Activities

















1) Conduct Energy Audit

















a) Industriald, e 20 $18,292
$0 $0 1 20 0 0 0 0 $0 $0 0



b) Commerciald, e 20 $854
$0 $0 1 20 0 0 0 0 $0 $0 0



2) Initial Stack Test and Report (PM)f 12 $0 $8,000 $0 $0 1 12 81.17 974.04 97.4 48.7 $127,590.92 $649,360 0



3) Triennial Stack Test and Report (PM)f 12 $0 $8,000 $0 $0 0.33 3.96 ERG: 81.17 x 2 + 1/3*(243.5*2) (includes 2/3 of new facilities >10 + 1/3 of all new facilities from prior 2 ICRs assuming constant growth rate) 324.7 1,285.71 128.57 64.3 $168,418.33 $857,138 0



4) Continuous Parameter Monitoring

















a) Establish Site-specific monitoring plang 40 $0 $0 $0 $0 1 40 81.17 3,246.80 324.68 162.3 $425,304.83 $0 0



b) Opacity (All Sources with ESPs)

















i) Initial 10 $0 $0 $0 $43,100 1 10 81.17 811.70 81.17 40.6 $106,326.94 $3,498,427 0



ii) Annual 10 $0 $0 $0 $14,700 1 10 Tracy Curtis: 81.17 x 2 + 243.5 x 2 (includes 2/3 new facilities and all new facilities from last two ICRs that will continue annual activities 649.3 6,493.40 649.34 324.7 $850,583.45 $9,545,298 0



c) BLD System Operation (All Sources with Fabric Filters)

















i) Initial 10 $0 $0 $0 $25,500 1 10 7.5 75 7.5 3.75 $9,824.40 $191,250 0



ii) Annual 10 $0 $0 $0 $9,700 1 10 15 150 15 7.5 $19,648.80 $145,500 0



5) Biennial Tune-Up 12 $0 $0 $2,875 $0 0.5 6 5,264 31,583 3,158.3 1,579.15 $4,137,118.0 $7,566,755.63 0



C. Create Information N/A
















D. Gather Information N/A
















E. Report Preparation

















1) Initial Notification that Source is Subject 2 $0 $0 $0 $0 1 2 81.17 162.34 16.23 8.12 $21,265.46 $0 81.17



2) Notification of Compliance Status 8 $0 $0 $0 $0 1 8 81.17 649.36 64.94 32.47 $85,061.49 $0 81.17



3) Initial Report on Results of Energy Auditd 5 $0 $0 $0 $0 1 5 0 0 0 0 $0 $0 0



4) Annual Compliance Report 30 $0 $0 $0 $0 1 30 324.7 9,740 974.0 487.0 $1,275,888.28 $0 324.67



5) Biennial Compliance Report 5 $0 $0 $0 $0 0.5 2.5 5,264 13,160 1,316.0 658.0 $1,723,799.96 $0 2,631.92



Subtotal for Reporting Requirements







88,275 $10,055,024 $22,453,728 3,119



4. Recordkeeping Requirements

















A. Familiarization with Rule Requirements See 3A
















B. Implement Activities N/A
















C. Develop Record Systemh N/A
















D. Record Information

















1) Records of Operating Parameter Values 20 $0 $0 $0 $0 1 20 5,264 105,277 10,527.7 5,263.8 $13,790,392.39 $0 0



2) Records of Deviations 15 $0 $0 $0 $0 1 15 5,264 78,957 7,895.8 3,947.9 $10,342,794.21 $0 0



3) Records of Stack Tests 2 $0 $0 $0 $0 1 2 5,264 10,528 1,052.8 526.4 $1,379,039.02 $0 0



4) Records of Monitoring Device Calibrations 2 $0 $0 $0 $0 1 2 5,264 10,528 1,052.8 526.4 $1,379,039.02 $0 0



5) Records of All Compliance Reports Submitted 2 $0 $0 $0 $0 2 4 5,264 21,055 2,105.5 1,052.8 $2,758,078.95 $0 0



6) Records of Monthly Fuel Use 0.5 $0 $0 $0 $0 12 6 5,264 31,583 3,158.3 1,579.2 $4,137,117.98 $0 0



7) Records of Biennial Tune-Up 0.5 $0 $0 $0 $0 0.5 0.25 5,264 1,316 131.6 65.8 $172,380.76 $0 0



E. Personnel Training N/A





.









F. Time for Audits N/A
















Subtotal for Recordkeeping Requirements







298,130 $33,958,842 $0 0



TOTAL LABOR BURDEN AND COST










$44,013,866





TOTAL CAPITAL AND O&M COST











$22,453,728




GRAND TOTAL







386,405 $66,467,594
3,119



N/A - Not Applicable













Notes


a. On average, over the 3-year period of this ICR, we estimate 10,365 existing large liquid boilers (i.e., units >10 MMBtu/hr) at 5,183 facilities will be subject to the rule. We also estimate 162 new boilers at 81 facilities per year, for a total of 10,528 boilers at 5,264 facilities. 10365 5183 10528 5264
b. This ICR uses the following labor rates: $117.92 for technical, $147.40 for managerial, and $57.02 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2018, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.



c. This burden applies to new sources only. The burden on existing sources to read and understand rule requirements and submit initial notifications was incurred during a previous ICR period. It is assumed that existing sources will take 1 hour to refamiliarize themselves with the rule requirements each year.

















d. This burden applies to existing large liquid fuel boilers only. All existing sources were required to complete the energy audit by the conclusion of the previous ICR period; therefore, no new or existing sources will incur this burden over the next three years.



e. Cost per occurrence for certified energy audit professionals includes a phone screening to discuss the facility prior to a visit, a 2- to 4-hour site visit, and an additional 2 to 4 hours to prepare a follow-up report on recommendations and findings. Cost depends on whether the source is industrial or commercial. It is assumed that 10% of sources will be industrial and 90% will be commercial.



f. All projected large liquid fuel boilers are expected to comply through stack testing instead of the fuel testing compliance option. Only units <30 MMBtu/hr that are not subject to PM limits under the NSPS (40 CFR Part 60 Subparts Db, Dc) will incur additional testing, monitoring, recordkeeping and reporting costs under this rule. This is a conservatively high estimate for burden as we expect some of the units will comply with the PM standard by combusting ultra-low sulfur diesel (ULSD), but the number of units with ULSD is unknown.



g. Sources demonstrating compliance with any applicable emission limits through stack testing must develop a site-specific monitoring plan. All new large liquid fuel units are expected to develop this plan.



h. It is assumed that facilities must already maintain records on boiler insurance and/or maintenance scheduling; therefore, no new record system would be required.


















Sheet 6: SmlSolid

Table 1C: Annual Respondent Burden and Cost – Existing and New Small Solid Fuel Boilers, NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal)
































Burden Item A

B C D E F G H





Technical Person-Hours per Occurrence Tune-Up Cost per Occurrence Other Non-Labor Costs per Occurrence Occurrences per Respondent per Year Technical Person-Hours per Respondent per Year (C=AxB) Respondents per Year a Technical Hours per Year (E=CxD) Clerical Hours per Year (F=Ex0.10) Management Hours per Year (G=Ex0.05) Total Cost per Year ($) b Total Non-Labor Annual Costs Total Number of Responses per Year



1. Applications N/A














2. Surveys and Studies N/A














3. Reporting Requirements















A. Read and Understand Rule Requirements (new sources)c 40 $0 $0 1 40 49.17 1,966.8 196.68 98.34 $257,635.07 $0 0



Familiarization with Rule Requirements (existing sources) 1 $0 $0 1 1 5,659 5,658.7 565.87 282.93 $741,240.16 $0 0



B. Required Activities















Biennial Tune-Up 12 $2,228 $0 0.5 6 5,708 34,246.98 3,424.70 1,712.4 $4,486,080.67 $6,358,522.62 0



C. Create Information N/A














D. Gather Information N/A














E. Report Preparation















1) Initial Notification that Source is Subject 2 $0 $0 1 2 49.17 98.34 9.83 4.92 $12,881.97 $0 49.17



2) Notification of Compliance Status 8 $0 $0 1 8 49.17 393.36 39.34 19.67 $51,527.54 $0 49.17



3) Biennial Compliance Report 5 $0 $0 0.5 2.5 5,708 14,269.58 1,426.96 713.48 $1,869,201.08 $0 2,853.915



Subtotal for Reporting Requirements





65,129 $7,418,566 $6,358,523 2,952



4. Recordkeeping Requirements















A. Familiarization with Rule Requirements See 3A














B. Implement Activities N/A














C. Develop Record Systemd N/A














D. Record Information















1) Records of All Compliance Reports Submitted 2 $0 $0 1 2 5,708 11,415.66 1,141.57 570.78 $1,495,359.92 $0 0



2) Records of Biennial Tune-Up 0.5 $0 $0 0.5 0.25 5,708 1,426.96 142.70 71.4 $186,920.87 $0 0



E. Personnel Training N/A














F. Time for Audits N/A














Subtotal for Recordkeeping Requirements





14,769 $1,682,281 $0 0



TOTAL LABOR BURDEN AND COST






$9,100,847





TOTAL CAPITAL AND O&M COST







$6,358,523




GRAND TOTAL





79,898 $15,459,370
2,952



N/A - Not Applicable











Notes


a. On average, over the 3-year period of this ICR, we estimate 11,317 existing small solid boilers (i.e., units <10 MMBtu/hr) at 5,659 facilities will be subject to the rule. We also estimate 98 new boilers at 49 facilities per year, for a total of 11,416 boilers at 5,708 facilities. 11317 5659 11416 5708
b. This ICR uses the following labor rates: $117.92 for technical, $147.40 for managerial, and $57.02 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2018, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.



c. This burden applies to new sources only. The burden on existing sources to read and understand rule requirements and submit initial notifications was incurred during a previous ICR period. It is assumed that existing sources will take 1 hour to refamiliarize themselves with the rule requirements each year.















d. It is assumed that facilities must already maintain records on boiler insurance and/or maintenance scheduling; therefore, no new record system would be required.
















Sheet 7: SmlLiquid

Table 1D: Annual Respondent Burden and Cost – Existing and New Small Liquid Fuel Boilers, NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) (Renewal)
































Burden Item A

B C D E F G H





Technical Person-Hours per Occurrence Tune-Up Cost per Occurrence Other Non-Labor Costs per Occurrence Occurrences per Respondent per Year Technical Person-Hours per Respondent per Year (C=AxB) Respondents per Year a Technical Hours per Year (E=CxD) Clerical Hours per Year (F=Ex0.10) Management Hours per Year (G=Ex0.05) Total Cost per Year ($) b Total Non-Labor Annual Costs Total Number of Responses per Year



1. Applications N/A














2. Surveys and Studies N/A














3. Reporting Requirements















A. Read and Understand Rule Requirements (new sources)c 40 $0 $0 1 40 989.5 39,580 3,958 1,979 $5,184,663 $0 0



Familiarization with Rule Requirements (existing sources) 1 $0 $0 1 1 86,314 86,314 8,631 4,316 $11,306,379 $0 0



B. Required Activities















Biennial Tune-Up 12 $2,228 $0 0.5 6 87,303 523,818 52,381.8 26,190.90 $68,615,967 $97,255,542 0



C. Create Information N/A














D. Gather Information N/A














E. Report Preparation















1) Initial Notification that Source is Subject 2 $0 $0 1 2 989.5 1,979 197.9 98.95 $259,233 $0 989.5



2) Notification of Compliance Status 8 $0 $0 1 8 989.5 7,916 791.6 395.8 $1,036,933 $0 989.5



3) Biennial Compliance Report 5 $0 $0 0.5 2.5 87,303 218,257.50 21,825.75 10,912.88 $28,589,987 $0 43,651.50



Subtotal for Reporting Requirements





1,009,544 $114,993,163 $97,255,542 45,631



4. Recordkeeping Requirements















A. Familiarization with Rule Requirements See 3A














B. Implement Activities N/A














C. Develop Record Systemd N/A














D. Record Information















1) Records of All Compliance Reports Submitted 2 $0 $0 1 2 87,303 174,606 17,460.6 8,730.30 $22,871,989 $0 0



2) Records of Biennial Tune-Up 0.5 $0 $0 0.5 0.25 87,303 21,825.75 2,182.58 1,091.29 $2,858,999 $0 0



E. Personnel Training N/A














F. Time for Audits N/A














Subtotal for Recordkeeping Requirements





225,897 $25,730,988 $0 0



TOTAL LABOR BURDEN AND COST






$140,724,151





TOTAL CAPITAL AND O&M COST







$97,255,542




GRAND TOTAL





1,235,440 $237,979,693
45,631



N/A - Not Applicable











Notes


a. On average, over the 3-year period of this ICR, we estimate 172,627 existing small liquid boilers (i.e., units <10 MMBtu/hr) at 86,314 facilities will be subject to the rule. We also estimate 1,979 new boilers at 989.5 facilities per year, for a total of 174,606 boilers at 87,303 facilities. 172627 86313.5 174606 87303
b. This ICR uses the following labor rates: $117.92 for technical, $147.40 for managerial, and $57.02 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2018, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.



c. This burden applies to new sources only. The burden on existing sources to read and understand rule requirements and submit initial notifications was incurred during a previous ICR period. It is assumed that existing sources will take 1 hour to refamiliarize themselves with the rule requirements each year.















d. It is assumed that facilities must already maintain records on boiler insurance and/or maintenance scheduling; therefore, no new record system would be required.
















Sheet 8: Respondents&Responses

Number of Respondents





Respondents That Submit Reports Respondents That Do Not Submit Any Reports





Year (A) (B) (C) (D) (E)





Number of New Respondents Number of Existing Respondents Number of Existing Respondents that keep records but do not submit reports Number of Existing Respondents That Are Also New Respondents Number of Respondents (E=A+B+C-D)




Large Solid Boilers




1 10 2,079.5 0 0 2,089.5
Notes (Units vs. Respondents):


2 10 2,089.5 0 0 2,099.5
4179 2,089.5 4199 2,099.5
3 10 2,099.5 0 0 2,109.5




Average 10 2,090 0 0 2,100




Large Liquid Boilers




1 81.17 5,101.50 0 0 5,182.67




2 81.17 5,182.67 0 0 5,263.84
10365 5,183 10528 5264
3 81.17 5,263.84 0 0 5,345.01




Average 81 5,183 0 0 5,264




Small Solid Boilers




1 49.17 5,610 0 0 5,658.67




2 49.17 5,658.67 0 0 5,707.84
11317 5,659 11416 5708
3 49.17 5,707.84 0 0 5,757.01




Average 49 5,659 0 0 5,708




Small Liquid Boilers




1 989.5 85,324.0 0 0 86,314




2 989.5 86,314 0 0 87,303.0
172627 86,313.5 174606 87,303
3 989.5 87,303.0 0 0 88,293




Average 990 86,314 0 0 87,303




Total 1,130 99,244 0 0 100,374
198,489
























Total Annual Responses





(A) (B) (C) (D) (E)





Information Collection Activity Number of Respondents Number of Responses Number of Existing Respondents That Keep Records But Do Not Submit Reports Total Annual Responses
E=(BxC)+D






Large Solid Boilers





Initial Notification 10 1 0 10





Notification of Compliance Status 10 1 0 10





Annual Compliance Report 2,099.5 1 0 2,099.5





Biennial Compliance Report 1,813 0.5 0 906.5





Subtotal


3,026





Large Liquid Boilers





Initial Notification 81.17 1 0 81.17





Notification of Compliance Status 81.17 1 0 81.17





Annual Compliance Report 324.7 1 0 324.67





Biennial Compliance Report 5,263.83 0.5 0 2,631.92





Subtotal


3,118.93





Small Solid Boilers









Initial Notification 49.17 1 0 49.17





Notification of Compliance Status 49.17 1 0 49.17





Biennial Compliance Report 5,707.83 0.5 0 2,853.92





Subtotal


2,952.26





Small Liquid Boilers





Initial Notification 989.5 1 0 989.5





Notification of Compliance Status 989.5 1 0 989.5





Biennial Compliance Report 87,303.0 0.5 0 43,651.50





Subtotal


45,630.50





Total (rounded)
54,700






Sheet 9: Capital vs. O&M

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







(A) (B) (C) (D) (E) (F) (G)
Continuous Monitoring Device Capital/Startup Cost for One Respondent Number of New Respondents Total Capital/Startup Cost, (B X C) Annual O&M Costs for One Respondent Number of Respondents with O&M Total O&M,
(E X F)
Large Solid Boilers





Initial Stack Test and Report (Hg) $5,000 0 $0 $0 0 $0
Triennial Stack Test and Report (Hg) $0 0 $0 $1,650 96 $157,575.00
Initial Stack Test and Report (CO) $6,000 0 $0 $0 0 $0
Triennial Stack Test and Report (CO) $0 0 $0 $1,980 96 $189,090.00
Initial Stack Test and Report (PM) $8,000 2 $14,640.000 $0 2 $0
Triennial Stack Test and Report (PM) $0 0 $0 $2,640 7 $19,342.40
Electrostatic Precipitator System $43,100 2 $78,873.000 $14,700 15 $215,502.00
Bag Leak Detection System $25,500 0 $0 $9,700 286.5 $2,779,050.00
Biennial Tune-Up $0 0 $0 $1,437.5 1,813 $2,606,187.50
Subtotal

$93,513

$5,966,747
Large Liquid Boilers





Initial Stack Test and Report (PM) $8,000 81.17 $649,360 $0 81.17 $0
Triennial Stack Test and Report (PM) $0 0 $0 $2,640 325 $857,137.60
Electrostatic Precipitator System $43,100 81.17 $3,498,427 $14,700 649 $9,545,298.00
Bag Leak Detection System $25,500 7.50 $191,250 $9,700 15 $145,500.00
Biennial Tune-Up $0 0 $0 $1,438 5,264 $7,566,755.63
Subtotal

$4,339,037

$18,114,691
Small Solid Boilers





Biennial Tune-Up $0 0 $0 $1,114 5,708 $6,358,522.62
Subtotal

$0

$6,358,523
Small Liquid Boilers





Biennial Tune-Up $0 0 $0 $1,114 87,303 $97,255,542
Subtotal

$0

$97,255,542
Total

$4,430,000

$128,000,000
File Typeapplication/vnd.openxmlformats-officedocument.spreadsheetml.sheet
File Modified0000-00-00
File Created0000-00-00

© 2024 OMB.report | Privacy Policy