Burden Calculation Tables

1967t08.xlsx

NESHAP for Stationary Combustion Turbines (40 CFR part 63, subpart YYYY) (Renewal)

Burden Calculation Tables

OMB: 2060-0540

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Overview

No of Respondents
No of Responses
Capital O&M
IndustryBurden
AgencyBurden


Sheet 1: No of Respondents

Old Table
1967.08 Table




Number of Respondents
Number of Respondents














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

(A) (B) (C) (D) (E)
Year Number of New Respondents a Number of Existing Respondents Number of Existing Respondents that keep records but do not submit reports b Number of Existing Respondents That Are Also New Respondents Number of Respondents
Year Number of New Respondents a Number of Existing Respondents Number of Existing Respondents that keep records but do not submit reports b Number of Existing Respondents That Are Also New Respondents Number of Respondents





(E=A+B+C-D)





(E=A+B+C-D)
Gas-Fired Stationary Combustion Turbine Subcategories





Gas-Fired Stationary Combustion Turbine Subcategories




1 6 0 78.2 0 84.2
1 8 0 101 0 109
2 6 0 84.2 0 90.2
2 8 0 109 0 117
3 6 0 90.2 0 96.2
3 8 0 117 0 125
Average 6 0 84.2 0 90.2
Average 8 0 109 0 117
Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory





Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory




1 0.3 3.5 0 0 3.8
1 0 3 0 0 3
2 0.3 3.8 0 0 4.1
2 0 3 0 0 3
3 0.3 4.1 0 0 4.4
3 0 3 0 0 3
Average 0.3 3.8 0 0 4.1
Average 0 3 0 0 3
Oil-Fired Stationary Combustion Turbine Subcategories





Oil-Fired Stationary Combustion Turbine Subcategories




1 2.4 31.7 0 0 34.1
1 0 2 0 0 2
2 2.4 34.1 0 0 36.5
2 0 2 0 0 2
3 2.4 36.5 0 0 38.9
3 0 2 0 0 2
Average 2.4 34.1 0 0 36.5
Average 0 2 0 0 2
TOTAL 8.7 37.9 84.2 0 130.8
TOTAL 8 5 109 0 122
a New respondents include sources with affected facilities constructed or reconstructed after January 14, 2003.





a New respondents include sources with affected facilities constructed or reconstructed after January 14, 2003.




b Due to the ongoing stay of the NESHAP, existing gas-fired sources that have previously submitted initial notifications are not subject to any additional monitoring or reporting requirements. For this reason, we have accounted for them in Column C.





b Due to the ongoing stay of the NESHAP, existing gas-fired sources that have previously submitted initial notifications are not subject to any additional monitoring or reporting requirements. For this reason, we have accounted for them in Column C.

























RTR proposal does not change applicability, but lifts stay on gas-fired units, and assumes the majority of new units are existing units that would be counted as new units; only 8 gas-fired units are completely new units. So revised to ---> Over the next three years, approximately 114 respondents per year will be subject to these standards, including 109 facilities with gas-fired turbines, 3 facilities with landfill/digester gas-fired turbines, and 2 facilities with oil-fired stationary combustion turbines. In addition, approximately 8 facilities per year will become subject to these same standards, including 8 facilities with gas-fired turbines, 0 facilities with landfill/digester gas-fired turbines, and 0 facilities with oil-fired turbines. 

Sheet 2: No of Responses

Old Table
1967.08 Table


Total Annual Responses
Total Annual Responses











(A) (B) (C) (D) (E)
(A) (B) (C) (D) (E)
Information Collection Activity Number of Respondentsa Number of Responses Number of Existing Respondents That Keep Records But Do Not Submit Reports Total Annual Responses
Information Collection Activity Number of Respondentsa Number of Responses Number of Existing Respondents That Keep Records But Do Not Submit Reports Total Annual Responses




E=(BxC)+D




E=(BxC)+D
Gas-Fired Stationary Combustion Turbine Subcategories
Gas-Fired Stationary Combustion Turbine Subcategories
Initial notification 6 1 0 6
Initial notification 8 1 0 8
Subtotal


6
Subtotal


8
Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory
Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory
Initial notification 0.3 1 0 0.3
Initial notification 0 1 0 0
Annual compliance reportb 3.8 1 0 3.8
Annual compliance reportb 3 1 0 3
Subtotal


4.1
Subtotal


3
Oil-Fired Stationary Combustion Turbine Subcategories
Oil-Fired Stationary Combustion Turbine Subcategories
Initial notification 2.4 1 0 2.4
Initial notification 0 1 0 0
Notification of construction/reconstruction 2.4 1 0 2.4
Notification of construction/reconstruction 0 1 0 0
Notification of actual startup 2.4 1 0 2.4
Notification of actual startup 0 1 0 0
Notification of performance test 2.4 1 0 2.4
Notification of performance test 0 1 0 0
Notification of CMS performance evaluation 2.4 1 0 2.4
Notification of CMS performance evaluation 0 1 0 0
Notification of compliance status 2.4 1 0 2.4
Notification of compliance status 0 1 0 0
Semiannual compliance reportc 34.1 2 0 68.2
Semiannual compliance reportc 2 2 0 4
Subtotal


82.6
Subtotal


4
TOTAL


92.7
TOTAL


15
a Due to the ongoing stay, existing gas-fired sources that have previously submitted initial notifications are not subject to any additional monitoring or reporting requirements.









b This activity applies to new and existing landfill/digester gas-fired sources.









c This activity applies to new and existing oil-fired sources.










Sheet 3: Capital 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 a Number of New Respondents b Total Capital/Startup Cost, (B X C) Annual O&M Costs for One Respondent c Number of Respondents with O&M Total O&M,






(E X F)








Catalyst inlet temperature Tracy Curtis: Updated labor costs. $4,496 0 $0 0 2 $0 <-- No new oil fired subcategories, updated to 2 new oil-fired respondents








a We estimate a total capital startup cost of $4,496 per respondent, which comprises a purchase cost of $500 and an installation cost of $3,996. The installation cost assumes 30 technical, 1.5 managerial, and 3 clerical hours at a labor rate of $120.27, $141.06, and $58.67, respectively. As described previously, these rates are based on figures from the United States Department of Labor and have been increased by 110 percent to account for private industry benefit packages.






b At present, only oil-fired subcategories are required to install, operate, and maintain continuous monitoring devices.






c No annual O&M costs are shown because we expect the catalyst inlet temperature monitor to be maintenance-free.







Sheet 4: IndustryBurden






120.27 141.06 58.67



Burden item (A) Person hours per occurrence (B) No. of occurrences per respondent per year (C) Person hours per respondent per year (AxB) (D) Respondents per year a (E) Technical person- hours per year (CxD) (F) Management person hours per year (Ex0.05) (G) Clerical person hours per year (Ex0.1) (H) Total Cost Per year b


1. Applications N/A









2. Survey and Studies N/A









3. Reporting Requirements










A. Familiarization with the regulatory requirements c 4 1 4 122 488 24.4 48.8 $64,996.72


B. Required Activities










Initial CMS performance evaluation d 12 1 12 0 0 0 0 $0


Performance test e 12 1 12 0 0 0 0 $0


C. Create Information See 3B









D. Gather Existing Information See 3B









E. Write Report










Initial notification f 2 1 2 8 16 0.8 1.6 $2,131.04


Notification of construction/reconstruction g 2 1 2 0 0 0 0 $0


Notification of actual startup g 2 1 2 0 0 0 0 $0


Notification of performance test g 2 1 2 0 0 0 0 $0


Notification of CMS performance evaluation g 2 1 2 0 0 0 0 $0


Notification of compliance status g 2 1 2 0 0 0 0 $0


Annual compliance report h 8 1 8 3 24 1.2 2.4 $3,196.56


Semiannual compliance reports i 8 2 16 2 32 1.6 3.2 $4,262.08


Subtotal for Reporting Requirements



644 $74,586.40


4. Recordkeeping Requirements










A. Familiarization with the regulatory requirements See 3A









B. Plan Activities See 3B









C. Implement Activities See 3B









D. Time to Enter Information










Records of operating parameters j 0.5 12 6 114 684 34.2 68.4 $91,101.96


F. Train Personnel N/A









G. Audits N/A









Subtotal for Recordkeeping Requirements



787 $91,102


TOTAN ANNUAL BURDEN AND COST (rounded) k



1,430 $166,000
15 hr per resp
Capital and O&M Cost (see Section 6(b)(iii)): k






$0


TOTAL COST: k






$166,000


























Assumptions:










a. We estimate 8 new sources, comprising 8 gas-fired, and 0 landfill/digester gas-fired or oil-fired stationary combustion turbines, will become subject to the rule over the three-year period of this ICR. We also estimate 114 existing sources are subject, comprising 109 facilities with gas-fired turbines, 3 facilities with landfill/digester gas-fired turbines, and 2 facilities with oil-fired stationary combustion turbines. Note that due to the ongoing stay, existing gas-fired sources that have previously submitted initial notifications are not subject to any additional monitoring or reporting requirements.










b. This ICR uses the following labor rates: $120.27 for technical, $141.06 for managerial, and $58.67 for clerical labor from the United States Department of Labor, Bureau of Labor Statistics.










c. We assume four hours are required to read instructions. This activity applies to existing and new sources in all subcategories.










d. We assume 12 hours are required to complete the CMS performance evaluation. This activity only applies to new sources in the oil-fired turbine subcategories.










e. We assume 12 hours are required to complete the performance test. This activity only applies to new sources in the oil-fired turbine subcategories.










f. We assume two hours are required to prepare each notification. This activity applies to new sources in all subcategories.










g. We assume two hours are required to prepare each notification. These activities only apply to new sources in the oil-fired turbine subcategories.










h. We assume eight hours are required to prepare annual compliance reports. This activity only applies to existing sources in the landfill/digester gas-fired turbine subcategory. (3 existing sources)










i. We assume eight hours are required to prepare semiannual compliance reports. This activity only applies to existing sources in the oil-fired turbine subcategories. (2 existing sources)










j. We assume one half-hour is required to record operating parameters. This activity applies to existing sources in all subcategories.










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











Sheet 5: AgencyBurden






49.44 66.62 26.75
Activity (A) EPA Hours per occurrence (B) Number of occurrences per Year (C) EPA Hours per Year (AxB) (D) Plants per Year a (E) Technical Hours per Year (CxD) (F) Managerial Hours per Year (Ex0.05) (G) Clerical Hours per Year (Ex0.10) (H) Total cost per year, $ b
Initial notification c 2 1 2 8 16 0.8 1.6 $887.14
Notification of construction/reconstruction d 2 1 2 0 0 0 0 $0
Notification of actual startup d 2 1 2 0 0 0 0 $0
Notification of performance test d 2 1 2 0 0 0 0 $0
Notification of CMS performance evaluation d 2 1 2 0 0 0 0 $0
Notification of compliance status e 18 1 18 0 0 0 0 $0
Annual compliance report f 8 1 8 3 24 1.2 2.4 $1,330.70
Semiannual compliance reports g 8 2 16 2 32 1.6 3.2 $1,774.27
TOTAL ANNUAL BURDEN AND COST (rounded) h



83 $3,990









Assumptions:







a. We estimate 8 new sources, comprising 8 gas-fired, and 0 landfill/digester gas-fired or oil-fired stationary combustion turbines, will become subject to the rule over the three-year period of this ICR. We also estimate 114 existing sources are subject, comprising 109 facilities with gas-fired turbines, 3 facilities with landfill/digester gas-fired turbines, and 2 facilities with oil-fired stationary combustion turbines. Note that due to the ongoing stay, existing gas-fired sources that have previously submitted initial notifications are not subject to any additional monitoring or reporting requirements.







b. This ICR uses the following labor rates: $49.44 for technical, $66.62 for managerial, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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.







c. We assume two hours are required to review each initial notification. This activity applies to new sources in all subcategories (i.e., 8 new sources comprising 8 gas-fired, 0 oil-fired, and 0 landfill/digester gas-fired turbines).







d. We assume two hours are required to review each notification. This activity only applies to new sources in the oil-fired turbine subcategories (i.e., 0 oil-fired turbines).







e. We assume that performance test and CMS performance evaluation reports will be submitted for review concurrently with the notification of compliance status, and that a total of 16 hours will be required to review each compliance notification (2 hours), performance test report (8 hours), and performance evaluation report (8 hours).







f. We assume eight hours are required to review each annual compliance report. This activity only applies to existing sources in the landfill/digester gas-fired turbine subcategory (3 existing sources).







g. We assume eight hours are required to review each semiannual compliance report. This activity only applies to existing sources in the oil-fired turbine subcategories (2 existing sources).







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







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