Burden Tables

2028t10.xlsx

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

Burden Tables

OMB: 2060-0551

Document [xlsx]
Download: xlsx | pdf

Overview

TBL1-YR1
TBL2-YR2
TBL3-YR3
TBL4-YR1
TBL5-YR2
TBL6-YR3
TBL7-SUMMARY
TBL8-YR1
TBL9-YR2
TBL10-YR3
TBL11-SUMMARY
Capital vs. O&M
2019 Changes


Sheet 1: TBL1-YR1

Table 1: Annual Respondent Burden and Cost for Existing Large Solid Fuel Units – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 1






























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 a
(H)
Technical Hours per Year
(F X G)
(I)
Clerical Hours per Year
(H X 0.1)
(J)
Management Hours per Year
(H X .05)
(K)
Total Labor Costs Per Year b
(L)
Total Non-Labor Costs Per Year
[(B+C+D)xExG]



1. Applications NA











Labor Rates:
2. Surveys and Studies NA











Management $141.06
3. Reporting Requirements












Technical $120.27
A. Familiarization with Regulatory Requirements c 10 $0 $0 $0 1 10 25 250 25 13 $33,298 $0
Clerical $58.67
B. Required Activities














1) Conduct Energy Audit














a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0


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


2) Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0


3) Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


4) Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


5) Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0


6) Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0


7) Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


8) Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


9) Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0


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


11) Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0


12) Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0


13) Annual Tune-up 12 $0 $2,875 $0 1 12 0 0 0 0 $0 $0


14) Continuous Parameter Monitoring














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


Opacity














a) initial 10 $0 $0 $25,812 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $9,855 1 10 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


b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0


O2














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0


Scrubber System Monitoring and Operation(for units with wet scrubbers)














a) initial 10 $0 $0 $25,054 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $5,774 1 10 0 0 0 0 $0 $0


Bag Leak Detection System Operation (sources that have fabric filters)














a) initial 10 $0 $0 $26,300 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $10,000 1 10 0 0 0 0 $0 $0


DIFF Monitor














a) initial 10 $0 $0 $44,858 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $31,500 1 10 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


b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0


CO CEMS














a) initial 10 $0 $0 $153,700 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $42,600 1 10 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


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


3) Initial Report on results of Energy Audit 5 $0 $0 $0 1 5 0 0 0 0 $0 $0


4) Semi-annual Compliance Report 20 $0 $0 $0 2 40 0 0 0 0 $0 $0


Subtotal for Reporting Requirements






288 $33,298 $0


4. Recordkeeping Requirements














A. Familiarization with Regulatory 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


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


3) Records of Stack Tests 2 $0 $0 $0 1 2 0 0 0 0 $0 $0


4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 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


6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 0 0 0 0 $0 $0


E. Personnel Training 40 $0 $0 $0 1 40 0 0 0 0 $0 $0


F. Time for Audits NA













Subtotal for Recordkeeping Requirements






0 $0 $0


Total Labor Burden and Cost (rounded) d






288 $33,300



Total Capital and O&M Cost (rounded) d










$0


Grand Total (rounded) d










$33,300


















Assumptions:














a This table shows only the additional burden to sources affected by the proposed amendments. All other new and recurring costs for these types of boilers are shown in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551). Since the EPA is proposing a 3-year compliance timeframe no burden is estimated in year 1 or 2.


b This ICR uses the following labor rates: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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 We assume that respondents impacted by the proposal will familiarize themselves with the rule in year one and implement the rule in year three. Based on compliance data, we estimate that 25 facilities with existing solid fuel units will be impacted by the proposal.


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















Sheet 2: TBL2-YR2

Table 2: Annual Respondent Burden and Cost for Existing Large Solid Fuel Units – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 2






























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 a
(H)
Technical Hours per Year
(F X G)
(I)
Clerical Hours per Year
(H X 0.1)
(J)
Management Hours per Year
(H X .05)
(K)
Total Labor Costs Per Year b
(L)
Total Non-Labor Costs Per Year
[(B+C+D)xExG]



1. Applications NA











Labor Rates:
2. Surveys and Studies NA











Management $141.06
3. Reporting Requirements












Technical $120.27
A. Familiarization with Regulatory Requirements 10 $0 $0 $0 1 10 0 0 0 0 $0 $0
Clerical $58.67
B. Required Activities














1) Conduct Energy Audit














a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0


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


2) Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0


3) Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


4) Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


5) Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0


6) Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0


7) Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


8) Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


9) Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0


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


11) Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0


12) Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0


13) Annual Tune-up 12 $0 $2,875 $0 1 12 0 0 0 0 $0 $0


14) Continuous Parameter Monitoring














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


Opacity














a) initial 10 $0 $0 $25,812 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $9,855 1 10 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


b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0


O2














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0


Scrubber System Monitoring and Operation(for units with wet scrubbers)














a) initial 10 $0 $0 $25,054 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $5,774 1 10 0 0 0 0 $0 $0


Bag Leak Detection System Operation (sources that have fabric filters)














a) initial 10 $0 $0 $26,300 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $10,000 1 10 0 0 0 0 $0 $0


DIFF Monitor














a) initial 10 $0 $0 $44,858 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $31,500 1 10 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


b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0


CO CEMS














a) initial 10 $0 $0 $153,700 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $42,600 1 10 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


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


3) Initial Report on results of Energy Audit 5 $0 $0 $0 1 5 0 0 0 0 $0 $0


4) Semi-annual Compliance Report 20 $0 $0 $0 2 40 0 0 0 0 $0 $0


Subtotal for Reporting Requirements






0 $0 $0


4. Recordkeeping Requirements














A. Familiarization with Regulatory 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


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


3) Records of Stack Tests 2 $0 $0 $0 1 2 0 0 0 0 $0 $0


4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 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


6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 0 0 0 0 $0 $0


E. Personnel Training 40 $0 $0 $0 1 40 0 0 0 0 $0 $0


F. Time for Audits NA













Subtotal for Recordkeeping Requirements






0 $0 $0


Total Labor Burden and Cost (rounded)






0 $0



Total Capital and O&M Cost (rounded)










$0


Grand Total (rounded)










$0


















Assumptions:














a This table shows only the additional burden to sources affected by the proposed amendments. All other new and recurring costs for these types of boilers are shown in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551). Since the EPA is proposing a 3-year compliance timeframe no burden is estimated in year 1 or 2.


b This ICR uses the following labor rates: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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.



Sheet 3: TBL3-YR3

Table 3: Annual Respondent Burden and Cost for Existing Large Solid Fuel Units – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 3






























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
(F X G)
(I)
Clerical Hours per Year
(H X 0.1)
(J)
Management Hours per Year
(H X .05)
(K)
Total Labor Costs Per Year a
(L)
Total Non-Labor Costs Per Year
[(B+C+D)xExG]



1. Applications NA











Labor Rates:
2. Surveys and Studies NA











Management $141.06
3. Reporting Requirements












Technical $120.27
A. Familiarization with Regulatory Requirements 10 $0 $0 $0 1 10 0 0 0 0 $0 $0
Clerical $58.67
B. Required Activities














1) Conduct Energy Audit b














a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0


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


2) Initial Stack Test and Report (for PM) b 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0


3) Initial Stack Test and Report (for Hg) b 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


4) Initial Stack Test and Report (for HCl) b 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


5) Initial Stack Test and Report (for CO) b 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0


6) Annual Stack Test and Report (for PM) b 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0


7) Annual Stack Test and Report (for Hg) b 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


8) Annual Stack Test and Report (for HCl) b 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


9) Annual Stack Test and Report (for CO) b 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0


10) Repeat Stack Test and Report if Switch Fuels (for Hg and HCl) b 24 $0 $16,000 $0 1 24 0 0 0 0 $0 $0


11) Initial Fuel Analysis for Mercury and HCL Content b 5 $0 $400 $0 1 5 0 0 0 0 $0 $0


12) Monthly Fuel Analysis for Mercury and HCL Content b 5 $0 $400 $0 12 60 0 0 0 0 $0 $0


13) Annual Tune-up b 12 $0 $2,875 $0 1 12 0 0 0 0 $0 $0


14) Continuous Parameter Monitoring














Update Site-specific monitoring plan (all) c 40 $0
$0 1 40 25 1,000 100 50 $133,190 $0


Opacity d














a) initial 10 $0 $0 $25,812 1 10 6 60 6 3 $7,991 $154,872


b) annual 10 $0 $0 $9,855 1 10 6 60 6 3 $7,991 $59,130


PM (only sources greater than 250 mmBtu/hr) b














a) initial 10 $0 $0 $158,000 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0


O2 b














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0


Scrubber System Monitoring and Operation(for units with wet scrubbers) d














a) initial 10 $0 $0 $25,054 1 10 3 30 3 2 $3,996 $75,162


b) annual 10 $0 $0 $5,774 1 10 3 30 3 2 $3,996 $17,322


Bag Leak Detection System Operation (sources that have fabric filters) d














a) initial 10 $0 $0 $26,300 1 10 8 80 8 4 $10,655 $210,400


b) annual 10 $0 $0 $10,000 1 10 8 80 8 4.0 $10,655 $80,000


DIFF Monitor d














a) initial 10 $0 $0 $44,858 1 10 1 10 1 1 $1,332 $44,858


b) annual 10 $0 $0 $31,500 1 10 1 10 1 0.5 $1,332 $31,500


Carbon Injection Monitoring System (all sources that use ACI to control Hg) b














a) initial 10 $0 $0 $115,000 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0


CO CEMS d, e














a) initial 10 $0 $0 $153,700 1 10 8 80 8 4 $10,655 $1,229,600


b) annual 10 $0 $0 $42,600 1 10 8 80 8 4 $10,655 $340,800


C. Create Information NA













D. Gather Information NA













E. Report Preparation














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


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


3) Initial Report on results of Energy Audit b 5 $0 $0 $0 1 5 0 0 0 0 $0 $0


4) Semi-annual Compliance Report b 20 $0 $0 $0 2 40 0 0 0 0 $0 $0


Subtotal for Reporting Requirements






1,748 $202,449 $528,752


4. Recordkeeping Requirements














A. Familiarization with Regulatory Requirements Included in 3a













B. Implement Activities NA













C. Develop Record System NA













D. Record Information














1) Records of Operating Parameter Values f 20 $0 $0 $0 1 20 36 720 72 36 $95,897 $0


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


3) Records of Stack Tests b 2 $0 $0 $0 1 2 0 0 0 0 $0 $0


4) Records of Monitoring Device Calibrations f 2 $0 $0 $0 1 2 36 72 7 4 $9,590 $0


5) Records of All Compliance Reports Submitted b 2 $0 $0 $0 2 4 0 0 0 0 $0 $0


6) Records of Monthly Fuel Use b 0.5 $0 $0 $0 12 6 0 0 0 0 $0 $0


E. Personnel Training b 40 $0 $0 $0 1 40 0 0 0 0 $0 $0


F. Time for Audits NA













Subtotal for Recordkeeping Requirements






911 $105,486 $0


Total Labor Burden and Cost (rounded) g






2,660 $308,000



Total Annualized Capital and O&M Cost (rounded) g










$529,000


Grand Total (rounded) g










$837,000


















Assumptions:














a This cost is based on the following labor rates: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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.


b This line item is not changed by proposed amendments and is accounted for in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551).


c Based on compliance data, we estimate that 25 facilities with existing solid fuel units will be impacted by the proposal and may be required to modify monitoring plans. This burden was assigned to year 3 of the compliance period given that sources have 3 years to demonstrate compliance.


d Based on compliance data, we estimate that 26 additional monitors to be installed, operated, calibrated, and maintained at existing large solid fuel units as a result of additional controls installed to meet the revised emission limits. This includes 6 opacity monitors, 1 monitor for the dry injection rate and bag leak detection (DIFF), 8 bag leak detection monitors, 3 wet scrubber monitors, 8 CO CEMS monitors. The initial costs (capital costs of equipment) and annual costs (annualized capital cost + annual O&M costs) for each monitor are consistent with the costs updated in the impacts analysis for the proposed amendments.


e As as a results of some of the CO emission limit changes, EPA anticipates 8 sources will opt to comply with the CO CEMS-based emission limit instead of the stack test limit and as a result these units will need to intall and operate CO CEMS. The ICR renewals have assumed that units would comply with stack test CO limits to date since they have the option of either. This was not previously costed out.


f We estimate that 36 existing large solid fuel units will have to change the records associated with operating parameter values. This includes the 26 units that install new monitors as well as 10 additional units that may need to make minor changes to the record system to reflect the new emission limits.


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



Sheet 4: TBL4-YR1

Table 4: Annual Respondent Burden and Cost for New Large Solid Fuel Units – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 1






























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 a
(H)
Technical Hours per Year
(F X G)
(I)
Clerical Hours per Year
(H X 0.1)
(J)
Management Hours per Year
(H X .05)
(K)
Total Labor Costs Per Year b
(L)
Total Non-Labor Costs Per Year
[(B+C+D)xExG]



1. Applications NA











Labor Rates:
2. Surveys and Studies NA











Management $141.06
3. Reporting Requirements












Technical $120.27
A. Familiarization with Regulatory Requirements c 10 $0 $0 $0 1 10 3 30 3 2 $3,996 $0
Clerical $58.67
B. Required Activities














1) Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 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


3) Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 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


5) Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 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


7) Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 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


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


10) Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 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


12) Annual Tune-up 12 $0 $2,875 $0 1 12 0 0 0 0 $0 $0


13) Continuous Parameter Monitoring














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


Opacity














a) initial 10 $0 $0 $25,812 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $9,855 1 10 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


b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0


O2














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0


Scrubber System Monitoring and Operation (for units with wet scrubbers)














a) initial 10 $0 $0 $25,054 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $5,774 1 10 0 0 0 0 $0 $0


Bag Leak Detection System Operation (sources that have fabric filters)














a) initial 10 $0 $0 $26,300 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $10,000 1 10 0 0 0 0 $0 $0


DIFF Monitor














a) initial 10 $0 $0 $44,858 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $31,500 1 10 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


b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0


CO CEMS














a) initial 10 $0 $0 $153,700 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $42,600 1 10 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


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


3) Semi-annual Compliance Report 20 $0 $0 $0 2 40 0 0 0 0 $0 $0


Subtotal for Reporting Requirements






35 $3,996 $0


4. Recordkeeping Requirements














A. Familiarization with Regulatory 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


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


3) Records of Stack Tests 2 $0 $0 $0 1 2 0 0 0 0 $0 $0


4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 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


6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 0 0 0 0 $0 $0


E. Personnel Training 40 $0 $0 $0 1 40 0 0 0 0 $0 $0


F. Time for Audits NA













Subtotal for Recordkeeping Requirements






0 $0 $0


Total Labor Burden and Cost (rounded) d






35 $4,000



Total Capital and O&M Cost (rounded) d










$0


Grand Total (rounded) d










$4,000


















Assumptions:














a This table shows only the additional burden to sources affected by the proposed amendments. All other new and recurring costs for these types of boilers are shown in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551). Since the EPA is proposing a 3-year compliance timeframe no burden is estimated in year 1 or 2.


b This ICR uses the following labor rates: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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 We assume that respondents impacted by the proposal will familiarize themselves with the rule in year one and implement the rule in year three. Based on compliance data, we estimate that 3 facilities with new solid fuel units will be impacted by the proposal.


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















Sheet 5: TBL5-YR2

Table 5: Annual Respondent Burden and Cost for New Large Solid Fuel Units – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 2






























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 a
(H)
Technical Hours per Year
(F X G)
(I)
Clerical Hours per Year
(H X 0.1)
(J)
Management Hours per Year
(H X .05)
(K)
Total Labor Costs Per Year b
(L)
Total Non-Labor Costs Per Year
[(B+C+D)xExG]



1. Applications NA











Labor Rates:
2. Surveys and Studies NA











Management $141.06
3. Reporting Requirements












Technical $120.27
A. Familiarization with Regulatory Requirements 10 $0 $0 $0 1 10 0 0 0 0 $0 $0
Clerical $58.67
B. Required Activities














1) Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 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


3) Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 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


5) Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 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


7) Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 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


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


10) Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 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


12) Annual Tune-up 12 $0 $2,875 $0 1 12 0 0 0 0 $0 $0


13) Continuous Parameter Monitoring














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


Opacity














a) initial 10 $0 $0 $25,812 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $9,855 1 10 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


b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0


O2














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0


Scrubber System Monitoring and Operation (for units with wet scrubbers)














a) initial 10 $0 $0 $25,054 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $5,774 1 10 0 0 0 0 $0 $0


Bag Leak Detection System Operation (sources that have fabric filters)














a) initial 10 $0 $0 $26,300 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $10,000 1 10 0 0 0 0 $0 $0


DIFF Monitor














a) initial 10 $0 $0 $44,858 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $31,500 1 10 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


b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0


CO CEMS














a) initial 10 $0 $0 $153,700 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $42,600 1 10 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


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


3) Semi-annual Compliance Report 20 $0 $0 $0 2 40 0 0 0 0 $0 $0


Subtotal for Reporting Requirements






0 $0 $0


4. Recordkeeping Requirements














A. Familiarization with Regulatory 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


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


3) Records of Stack Tests 2 $0 $0 $0 1 2 0 0 0 0 $0 $0


4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 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


6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 0 0 0 0 $0 $0


E. Personnel Training 40 $0 $0 $0 1 40 0 0 0 0 $0 $0


F. Time for Audits NA













Subtotal for Recordkeeping Requirements






0 $0 $0


Total Labor Burden and Cost (rounded)






0 $0



Total Capital and O&M Cost (rounded)










$0


Grand Total (rounded)










$0


















Assumptions:














a This table shows only the additional burden to sources affected by the proposed amendments. All other new and recurring costs for these types of boilers are shown in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551). Since the EPA is proposing a 3-year compliance timeframe no burden is estimated in year 1 or 2.


b This ICR uses the following labor rates: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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.



Sheet 6: TBL6-YR3

Table 6: Annual Respondent Burden and Cost for New Large Solid Fuel Units – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 3






























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
(F X G)
(I)
Clerical Hours per Year
(H X 0.1)
(J)
Management Hours per Year
(H X .05)
(K)
Total Labor Costs Per Year a
(L)
Total Non-Labor Costs Per Year
[(B+C+D)xExG]



1. Applications NA











Labor Rates:
2. Surveys and Studies NA











Management $141.06
3. Reporting Requirements












Technical $120.27
A. Familiarization with Regulatory Requirements 10 $0 $0 $0 1 10 0 0 0 0 $0 $0
Clerical $58.67
B. Required Activities














1) Initial Stack Test and Report (for PM) b 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0


2) Initial Stack Test and Report (for Hg) b 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


3) Initial Stack Test and Report (for HCl) b 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


4) Initial Stack Test and Report (for CO) b 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0
$188,827.20
5) Annual Stack Test and Report (for PM) b 12 $0 $5,000 $0 1 12 0 0 0 0 $0 $0
$540,000.00
6) Annual Stack Test and Report (for Hg) b 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0
$728,827.20
7) Annual Stack Test and Report (for HCl) b 12 $0 $8,000 $0 1 12 0 0 0 0 $0 $0


8) Annual Stack Test and Report (for CO) b 12 $0 $7,000 $0 1 12 0 0 0 0 $0 $0


9) Repeat Stack Test and Report if Switch Fuels (for Hg and HCl) b 24 $0 $16,000 $0 1 24 0 0 0 0 $0 $0


10) Initial Fuel Analysis for Mercury and HCL Content b 5 $0 $400 $0 1 5 0 0 0 0 $0 $0


11) Monthly Fuel Analysis for Mercury and HCL Content b 5 $0 $400 $0 12 60 0 0 0 0 $0 $0


12) Annual Tune-up b 12 $0 $2,875 $0 1 12 0 0 0 0 $0 $0


13) Continuous Parameter Monitoring














Update Site-specific monitoring plan (all) c 40 $0
$0 1 40 3 120 12 6 $15,983 $0


Opacity b














a) initial 10 $0 $0 $25,812 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $9,855 1 10 0 0 0 0 $0 $0


PM (only sources greater than 250 mmBtu/hr) b














a) initial 10 $0 $0 $158,000 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $56,100 1 10 0 0 0 0 $0 $0


O2 b














a) initial 10 $0 $0 $8,523 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $1,436 1 10 0 0 0 0 $0 $0


Scrubber System Monitoring and Operation (for units with wet scrubbers) d














a) initial 10 $0 $0 $25,054 1 10 2 20 2 1 $2,664 $50,108


b) annual 10 $0 $0 $5,774 1 10 2 20 2 1 $2,664 $11,548


Bag Leak Detection System Operation (sources that have fabric filters) b














a) initial 10 $0 $0 $26,300 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $10,000 1 10 0 0 0 0 $0 $0


DIFF Monitor b














a) initial 10 $0 $0 $44,858 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $31,500 1 10 0 0 0 0 $0 $0


Carbon Injection Monitoring System (all sources that use ACI to control Hg) b














a) initial 10 $0 $0 $115,000 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $9,700 1 10 0 0 0 0 $0 $0


CO CEMS b














a) initial 10 $0 $0 $153,700 1 10 0 0 0 0 $0 $0


b) annual 10 $0 $0 $42,600 1 10 0 0 0 0 $0 $0


C. Create Information NA













D. Gather Information NA













E. Report Preparation














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


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


3) Semi-annual Compliance Report b 20 $0 $0 $0 2 40 0 0 0 0 $0 $0


Subtotal for Reporting Requirements






184 $21,310 $11,548


4. Recordkeeping Requirements














A. Familiarization with Regulatory Requirements Included in 3a













B. Implement Activities NA













C. Develop Record System NA













D. Record Information














1) Records of Operating Parameter Values e 20 $0 $0 $0 1 20 3 60 6 3 $7,991 $0


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


3) Records of Stack Tests b 2 $0 $0 $0 1 2 0 0 0 0 $0 $0


4) Records of Monitoring Device Calibrations e 2 $0 $0 $0 1 2 3 6 0.6 0.3 $799 $0


5) Records of All Compliance Reports Submitted b 2 $0 $0 $0 2 4 0 0 0 0 $0 $0


6) Records of Monthly Fuel Use b 0.5 $0 $0 $0 12 6 0 0 0 0 $0 $0


E. Personnel Training b 40 $0 $0 $0 1 40 0 0 0 0 $0 $0


F. Time for Audits NA













Subtotal for Recordkeeping Requirements






76 $8,791 $0


Total Labor Burden and Cost (rounded) f






260 $30,100



Total Capital and O&M Cost (rounded) f










$11,500


Grand Total (rounded) f










$41,600


















Assumptions:














a This cost is based on the following labor rates: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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.


b This line item is not changed by proposed amendments and is accounted for in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551).














c Based on compliance data, we estimate that 3 facilities with new solid fuel units will be impacted by the proposal and may be required to modify monitoring plans. This burden was assigned to year 3 of the compliance period given that sources have 3 years to demonstrate compliance.


d Based on compliance data, we estimate that 2 additional wet scrubber monitors to be installed, operated, calibrated, and maintained at new large solid fuel units as a result of additional controls installed to meet the revised emission limits. The initial costs (capital costs of equipment) and annual costs (annualized capital cost + annual O&M costs) for each monitor are consistent with the costs updated in the impacts analysis for the proposed amendments.


e We estimate that 3 existing large solid fuel units will have to change the records associated with operating parameter values. This includes the 2 units that install new monitors as well as an additional unit that may need to make minor changes to the record system to reflect the new emission limits.


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



Sheet 7: TBL7-SUMMARY

Table 7: Summary of Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)
Boiler Type &
Year
Technical Hours Clerical Hours Management Hours Total Labor Hours Labor Costs Non-Labor (Annualized Capital/Startup Cost + Annual O&M Cost) Costs Total Costs
Existing Large Solid Fuel Units






Year 1 250 25 13 288 $33,298 $0 $33,298
Year 2 0 0 0 0 $0 $0 $0
Year 3 2,312 231 116 2,659 $307,935 $528,752 $836,687
New Large Solid Fuel Units






Year 1 30 3 2 35 $4,000 $0 $4,000
Year 2 0 0 0 0 $0 $0 $0
Year 3 226 23 11 260 $30,100 $11,548 $41,648
Total 2,818 282 141 3,241 $375,000 $540,000 $920,000
Average 939 94 47 1,080 125,000 $180,000 $307,000








Boiler Type &
Year
Number of Respondents Number of Responses Reporting Hours Recordkeeping Hours Total Hours Hours per Response Hours Per Respondent
Existing Large Solid Fuel Units






Year 1 0 0 288 0 288 - -
Year 2 0 0 0 0 0 - -
Year 3 25 51 1,748 911 2,659 52 106
New Large Solid Fuel Units






Year 1 0 0 35 0 35 - -
Year 2 0 0 0 0 0 - -
Year 3 3 5 184 76 260 52 87
Total 28 56 2,254 987 3,241 - -
Average 9 19 751 329 1,080 57.9 115.7
Average annual additional costs per respondent:
$33,000




Average annual additional hours per respondent:
115.7




Average annual additional hours per response:
58





Sheet 8: TBL8-YR1

Table 8: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 1









Burden Item (A) (B) (C) (E) (F) (G) (H)


EPA hours per occurrence Number of occurrences per year EPA hours per occurrence per year (C=AxB) Technical hours per year Manage-ment hours per year (F=Ex0.05) Clerical hours per year (G=Ex0.1) Costs per year, $ a


1. Familiarization with regulatory requirements b 10 0 0 0 0 0 $0
Labor Rates:
2. Enter and update information into agency recordkeeping system b 2 0 0 0 0 0 $0
Management $66.62
3. Required activities





$0
Technical $49.44
A. Review and approve monitoring plan c 20 0 0 0 0 0 $0
Clerical $26.75
B. Review and approve fuel monitoring plan b 20 0 0 0 0 0 $0


C. Observe initial stack/performance test b 40 0 0 0 0 0 $0


D. Observe repeat performance test b 40 0 0 0 0 0 $0


E. Review operating parameters d 2 0 0 0 0 0 $0


F. Review continuous parameter monitoring d 2 0 0 0 0 0 $0


4. Excess Emissions Enforcement Activities and Inspections b 24 0 0 0 0 0 $0


5. Notification requirements





$0


A. Review initial notification that sources are subject to the standard b 2 0 0 0 0 0 $0


B. Review notification of initial performance tests and review test plan b 20 0 0 0 0 0 $0


C. Review notification of compliance status b 2 0 0 0 0 0 $0


6. Reporting requirements





$0


A. Review semiannual compliance report b 4 0 0 0 0 0 $0


B. Review annual compliance report b 2 0 0 0 0 0 $0


C. Review biennial compliance report b 1 0 0 0 0 0 $0


D. Review initial report on results of energy audit b 2 0 0 0 0 0 $0


7. Travel Expenses for Tests Attended b 3 days * ($201 hotel + $93 meals/incidentals) + ($600 round trip) = $1482 per trip 0 0 0 $0


TOTAL (rounded) e


0 $0













Assumptions:









a This cost is based on the following labor rates: $66.62 for managerial, $49.44 for technical, 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.


b This line item is not changed by proposed amendments and is accounted for in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551).


c Based on compliance data, we estimate that 25 facilities with existing solid fuel units and 3 facilities with new solid fuel units will be impacted by the proposal and may be required to modify monitoring plans. This burden was assigned to year 3 of the compliance period given that sources have 3 years to demonstrate compliance.


d Based on compliance data, we estimate that 26 existing solid fuel units and 3 new solid fuel units will have additional operating parameters and continuous parameter monitoring results to be reviewed based on the changes to the emission limits. This burden was assigned to year 3 of the compliance period given that sources have 3 years to demonstrate compliance.


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



Sheet 9: TBL9-YR2

Table 9: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 2









Burden Item (A) (B) (C) (E) (F) (G) (H)


EPA hours per occurrence Number of occurrences per year EPA hours per occurrence per year (C=AxB) Technical hours per year Manage-ment hours per year (F=Ex0.05) Clerical hours per year (G=Ex0.1) Costs per year, $ a


1. Familiarization with regulatory requirements b 10 0 0 0 0 0 $0
Labor Rates:
2. Enter and update information into agency recordkeeping system b 2 0 0 0 0 0 $0
Management $66.62
3. Required activities





$0
Technical $49.44
A. Review and approve monitoring plan c 20 0 0 0 0 0 $0
Clerical $26.75
B. Review and approve fuel monitoring plan b 20 0 0 0 0 0 $0


C. Observe initial stack/performance test b 40 0 0 0 0 0 $0


D. Observe repeat performance test b 40 0 0 0 0 0 $0


E. Review operating parameters d 2 0 0 0 0 0 $0


F. Review continuous parameter monitoring d 2 0 0 0 0 0 $0


4. Excess Emissions Enforcement Activities and Inspections b 24 0 0 0 0 0 $0


5. Notification requirements





$0


A. Review initial notification that sources are subject to the standard b 2 0 0 0 0 0 $0


B. Review notification of initial performance tests and review test plan b 20 0 0 0 0 0 $0


C. Review notification of compliance status b 2 0 0 0 0 0 $0


6. Reporting requirements





$0


A. Review semiannual compliance report b 4 0 0 0 0 0 $0


B. Review annual compliance report b 2 0 0 0 0 0 $0


C. Review biennial compliance report b 1 0 0 0 0 0 $0


D. Review initial report on results of energy audit b 2 0 0 0 0 0 $0


7. Travel Expenses for Tests Attended b 3 days * ($201 hotel + $93 meals/incidentals) + ($600 round trip) = $1482 per trip 0 0 0 $0


TOTAL (rounded) e


0 $0













Assumptions:









a This cost is based on the following labor rates: $66.62 for managerial, $49.44 for technical, 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.


b This line item is not changed by proposed amendments and is accounted for in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551).


c Based on compliance data, we estimate that 25 facilities with existing solid fuel units and 3 facilities with new solid fuel units will be impacted by the proposal and may be required to modify monitoring plans. This burden was assigned to year 3 of the compliance period given that sources have 3 years to demonstrate compliance.


d Based on compliance data, we estimate that 26 existing solid fuel units and 3 new solid fuel units will have additional operating parameters and continuous parameter monitoring results to be reviewed based on the changes to the emission limits. This burden was assigned to year 3 of the compliance period given that sources have 3 years to demonstrate compliance.


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



Sheet 10: TBL10-YR3

Table 10: Average Annual EPA Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)


Year 3









Burden Item (A) (B) (C) (E) (F) (G) (H)


EPA hours per occurrence Number of occurrences per year EPA hours per occurrence per year (C=AxB) Technical hours per year Manage-ment hours per year (F=Ex0.05) Clerical hours per year (G=Ex0.1) Costs per year, $ a


1. Familiarization with regulatory requirements b 10 1 10 10 1 1 $554.46
Labor Rates:
2. Enter and update information into agency recordkeeping system b 2 0 0 0 0 0 $0
Management $66.62
3. Required activities





$0
Technical $49.44
A. Review and approve monitoring plan c 20 28 560 560 28 56 $31,049.76
Clerical $26.75
B. Review and approve fuel monitoring plan b 20 0 0 0 0 0 $0


C. Observe initial stack/performance test b 40 0 0 0 0 0 $0


D. Observe repeat performance test b 40 0 0 0 0 0 $0


E. Review operating parameters d 2 28 56 56 2.8 5.6 $3,104.98


F. Review continuous parameter monitoring d 2 28 56 56 2.8 5.6 $3,104.98


4. Excess Emissions Enforcement Activities and Inspections b 24 0 0 0 0 0 $0


5. Notification requirements









A. Review initial notification that sources are subject to the standard b 2 0 0 0 0 0 $0


B. Review notification of initial performance tests and review test plan b 20 0 0 0 0 0 $0


C. Review notification of compliance status b 2 0 0 0 0 0 $0


6. Reporting requirements





$0


A. Review semiannual compliance report b 4 0 0 0 0 0 $0


B. Review annual compliance report b 2 0 0 0 0 0 $0


C. Review biennial compliance report b 1 0 0 0 0 0 $0


D. Review initial report on results of energy audit b 2 0 0 0 0 0 $0


7. Travel Expenses for Tests Attended b 3 days * ($201 hotel + $93 meals/incidentals) + ($600 round trip) = $1482 per trip 0 0 0 $0


TOTAL (rounded) e


784 $37,800













Assumptions:









a This cost is based on the following labor rates: $66.62 for managerial, $49.44 for technical, 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.


b This line item is not changed by proposed amendments and is accounted for in the previous ICR Renewal (EPA ICR Number 2028.09, OMB Control Number 2060-0551).


c Based on compliance data, we estimate that 25 facilities with existing solid fuel units and 3 facilities with new solid fuel units will be impacted by the proposal and may be required to modify monitoring plans. This burden was assigned to year 3 of the compliance period given that sources have 3 years to demonstrate compliance.


d Based on compliance data, we estimate that 26 existing solid fuel units and 3 new solid fuel units will have additional operating parameters and continuous parameter monitoring results to be reviewed based on the changes to the emission limits. This burden was assigned to year 3 of the compliance period given that sources have 3 years to demonstrate compliance.


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



Sheet 11: TBL11-SUMMARY

Table 11 - Summary of Annual Agency Burden and Cost - NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Amendments)
Year Technical Hours Management Hours Clerical Hours Total Hours Labor Costs Non-Labor Costs Total Costs
1 0 0 0 0 $0 $0 $0
2 0 0 0 0 $0 $0 $0
3 682 34 68 784 $37,800 $0 $37,800
Total 682 34 68 784 $37,800 $0 $37,800
Average 227 11.4 23 261 $12,600 $0 $12,600








Year Number of Responses Total Hours




1 0 0




2 0 0




3 85 784




Total 85 784




Average 28 261





Sheet 12: Capital vs. O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) (B) (C) (D) (E) (F) (G)
Boiler Type &
CPMS
Capital/Startup Cost Number of Units Total Capital/ Startup Cost
(B x C)
Annualized Capital Cost + Annual O&M Costs for One Unit a Number of Units Total Annualized Capital Cost + Annual O&M Costs
(E x F)

YEAR 1
Existing Large Solid Units






Opacity $25,812 0 $0 $9,855 0 $0
Scrubber System $25,054 0 $0 $5,774 0 $0
Bag Leak Detection System $26,300 0 $0 $10,000 0 $0
DIFF Monitor $44,858 0 $0 $31,500 0 $0
CO CEMS $153,700 0 $0 $42,600 0 $0
New Large Solid Units






Scrubber System $25,054 0 $0 $5,774 0 $0
YEAR 2
Existing Large Solid Units






Opacity $25,812 0 $0 $9,855 0 $0
Scrubber System $25,054 0 $0 $5,774 0 $0
Bag Leak Detection System $26,300 0 $0 $10,000 0 $0
DIFF Monitor $44,858 0 $0 $31,500 0 $0
CO CEMS $153,700 0 $0 $42,600 0 $0
New Large Solid Units






Scrubber System $25,054 0 $0 $5,774 0 $0
YEAR 3
Existing Large Solid Units






Opacity $25,812 6 $154,872 $9,855 6 $59,130
Scrubber System $25,054 3 $75,162 $5,774 3 $17,322
Bag Leak Detection System $26,300 8 $210,400 $10,000 8 $80,000
DIFF Monitor $44,858 1 $44,858 $31,500 1 $31,500
CO CEMS $153,700 8 $1,229,600 $42,600 8 $340,800
New Large Solid Units






Scrubber System $25,054 2 $50,108 $5,774 2 $11,548








Total (Rounded) b

$1,770,000

$540,000
a This figure represents the annualized capital cost of the new equipment plus the annual O&M costs of the new equipment. For a detailed explanation of the annualized cost, see: " XXXXXX" in EPA Docket ID Number EPA-HQ-OAR-2002-0058.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.














































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

Existing Sources New Sources Existing Sources New Sources
Total Annual Responses, In Year One
Reporting: Update Site-specific monitoring plan 0 0 0 0 0 0
Reporting: CPMS: Opacity: Annual 0 0 0 0 0 0
Reporting: CPMS: Scrubber: Annual 0 0 0 0 0 0
Reporting: CPMS: Bag Leak Detection: Annual 0 0 0 0 0 0
Reporting: CPMS: DIFF Monitor: Annual 0 0 0 0 0 0
Reporting: CPMS: CO CEMS: Annual 0 0 0 0 0 0





Total 0


Total Annual Responses, In Year Two
Reporting: Update Site-specific monitoring plan 0 0 0 0 0 0
Reporting: CPMS: Opacity: Annual 0 0 0 0 0 0
Reporting: CPMS: Scrubber: Annual 0 0 0 0 0 0
Reporting: CPMS: Bag Leak Detection: Annual 0 0 0 0 0 0
Reporting: CPMS: DIFF Monitor: Annual 0 0 0 0 0 0
Reporting: CPMS: CO CEMS: Annual 0 0 0 0 0 0





Total 0


Total Annual Responses, In Year Three
Reporting: Update Site-specific monitoring plan 25 3 1 1 0 28
Reporting: CPMS: Opacity: Annual 6 0 1 0 0 6
Reporting: CPMS: Scrubber: Annual 3 2 1 1 0 5
Reporting: CPMS: Bag Leak Detection: Annual 8 0 1 0 0 8
Reporting: CPMS: DIFF Monitor: Annual 1 0 1 0 0 1
Reporting: CPMS: CO CEMS: Annual 8 0 1 0 0 8





Total 56
a EPA estimates that, as a result of the proposed amendments, 26 continuous parameter monitoring systems (CPMS) on existing pollution control devices will be required to be installed. EPA also estimates that, as a result of the proposed amendments, 2 new sources will be required to install CPMS on scrubbers. Additionally, EPA estimates that 25 existing sources and 3 new sources will update site-specific monitoring plans as a result of the proposed changes to the emission limits.
b Facilities have three years to come into compliance after the proposed amendments are promulgated. EPA assumes that all facilities will comply in year three. Therefore, all additional responses as a result of these amendments are assumed to occur in year three.

Sheet 13: 2019 Changes

# of facilities with units in one of the impacted subcategories in the first 3 years of compliance

Existing Large Solid New Large Solid

25 3






# of units with additional monitoring, includes the list from complaince data plus model boilers to account for units where we do not have data for existing sources. For new sources includes an extra unit with scrubber, recognizing potential growth in new units. The 3rd new unit is estimated to only require an increase in sorbent injection rate to meet the HCl limit.
Monitors Existing Large Solid New Large Solid
Opacity 6
Wet Scrubber 3 2
BLD 8
DIFF 1
CO CEMS 8
Total 26 2
Units that don't require new monitors but may need to adjust monitoring plan to account for new limits 10 1
Total for monitoring changes 36 3
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