Burden Calculation Tables

2253t05.xlsx

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

Burden Calculation Tables

OMB: 2060-0668

Document [xlsx]
Download: xlsx | pdf

Overview

Table 1 Summary
Table 2
Base Data
SmlSolid
LrgSolid
SmlLiquid
LrgLiquid
Capital vs. O&M


Sheet 1: Table 1 Summary

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











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 2,120 3,071 101,229 26,196 127,424 $15,072,452 $6,912,728 $21,985,180


Large Liquid 3,115 1,639 38,143 176,405 214,548 $25,377,953 $5,889,778 $31,267,731


Small Solid 5,806 3,001 66,203 15,023 81,226 $9,607,914 $6,468,070 $16,075,984


Small Liquid 53,304 26,652 582,344 137,924 720,267 $85,197,299 $59,380,414 $144,577,713


Total 64,344 34,363 787,918 355,548 1,143,466 $135,255,618 $78,650,989 $213,906,607


Grand Total (rounded) a



1,140,000 $135,000,000 $78,700,000 $214,000,000
33 hrs/response




Total Private Sector (49% of Respondents) 31,529 16,838 386,080 174,218 560,000 66,300,000 38,500,000 104,800,000


Total Public Sector (51% of Respondents) 32,815 17,525 401,838 181,329 583,000 69,000,000 40,100,000 109,100,000


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



Sheet 2: Table 2

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 Requirements b 40 0 0 0 0 0 $0
2. Enter and Update Information into Agency Recordkeeping System c 2 59.2 118 118 5.92 11.8 $4,296.06
3. Required Activities






a) Observe Initial Stack/Performance Test d 40 0.37 15 15 1 1 $537.31
b) Observe Repeat Performance Test e 40 0.04 2 2 0.1 0.2 $58.09
c) Review Operating Parameters f 2 2 4 4 0.2 0.4 $132.87
d) Review Continuous Parameter Monitoring g 2 3,421 6,843 6,843 342 684 $248,420.59
4. Excess Emissions Enforcement Activities and Inspections h 24 0.2 4.3 4.3 0.22 0.43 $157.01
5. Notification Requirements






a) Review Initial Notification that Sources are Subject to the Standard c 2 59.2 118 118 5.92 11.8 $4,296.06
b) Review Notification of Initial Performance Tests and Review Test Plan f 20 2 37 37 2 4 $1,328.76
c) Review Notification of Compliance Status c 2 59.2 118 118 5.92 11.8 $4,296.06
6. Reporting Requirements




0
a) Review Annual Compliance Report 4 2,211 8,843 8,843 442 884 $321,057.18
b) Review Biennial Compliance Report 2 32,034 64,068 64,068 3,203 6,407 $2,325,988.74
c) Review Initial Report on Energy Audit Results i 2 0 0 0 0 0 $0
7. Travel Expenses for Performance Tests Observed j





$634.68
TOTAL (rounded) k


92,200 $2,910,000
Assumptions






a This ICR uses the following labor rates: $51.23 for technical, $69.04 for managerial, and $27.73 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2021 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 a 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 ($220 hotel + $96 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

Existing Boiler Data for Years 2022, 2023, and 2024












































Number of Existing Boilers Represented by Model and EIA AEO 2021 Data
Number of Existing Facilities Represented by Model and EIA AEO 2021 Data







Fuel Category Size Category [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Updated these base data to show growth or decrease since previous ICR. Total Existing in Year 2022 Projected New Sources: Growth or Decrease Per Year Total Existing in Year 2023 Total Existing in Year 2024 3-Year Average Source
Classification
3-Year Average Total
Fuel Category Size Category 3-Year Average Total Source
Classification
3-Year Average Total

Calculating Decrease in Respondents and Boilers since 2253.02 (2012) for Liquid-Fired Units.
Biomass <10 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Updated these base data to show growth for solid units since previous ICR. 7,912 46.7 7,959 8,005 7,959 Existing Small Solid 11,612
Biomass <10 3,979.3 Existing Small Solid 5,806

Facilities




>= 10 to 100 3,451 3.7 3,455 3,458 3,455 Existing Large Solid 4,239
>= 10 to 100 1,727.3 Existing Large Solid 2,120

Adjustment since 2253.02 Existing in 2012 a Growth per year a Existing in 2013 b Decrease to 2022 (-33%) c
>100 195 16.3 211 228 211 Existing Small Liquid 106,608
>100 105.7 Existing Small Liquid 53,304

Coal <10 3,602 51.7 3,654 3,705 3,654 Existing Large Liquid 6,229
Coal <10 1,826.8 Existing Large Liquid 3,115

Liquid <10 79387 989 80376 53,852
>= 10 to 100 573 0 573 573 573 Grand Total 128,688
>= 10 to 100 286.5 Grand Total* 64,344

>= 10 to 100 4545 80 4625 3,099
>100 0 0 0 0 0


>100 0.0



>100 70 1 71 48
Liquid <10 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Updated these existing data for liquid units to show decrease in #2 fuel oil since 2013. 107,684 -1,076.8 106,608 105,531 106,608


Liquid <10 53,303.8









>= 10 to 100 6,199 -62.0 6,137 6,075 6,137


>= 10 to 100 3,068.5



Boilers




>100 93 -0.9 92 91 92


>100 46.1



Adjustment since 2253.02 Existing in 2012 a Growth per year a Existing in 2013 b Decrease to 2022 (-33%) c
Grand Total 129,710 -1,021 128,688 127,667 128,688


Grand Total 64,344.1






#REF!












Liquid <10 158744 1979 160723 107,684
Boilers per Facility 2














>= 10 to 100 9090 162 9252 6,199

















>100 139 0 139 93
Assume units with bag leak detection will have a bag leak detection monitor












a The counts for existing facilities (respondents) and existing boilers and the values for growth per year are taken directly from the "Base Data' tab of "AreaBoiler_2253.02.xlsx".
b The values for 'Existing in 2013' are the values from 2012, incremented by 1 year's growth.
c U.S. Energy Information Administration data (AEO 2006, AEO 2021, available at https://www.eia.gov/outlooks/aeo/) indicates the consumption of distilate fuel oil in the commercial sector has decreased by 33 percent in the past 9 years and is anticipated to decrease by 1% per year for the next three years. In this ICR renewal, we assume this decrease in consumption corresponds to an equivalent decrease in the number of small and large boilers firing liquid fuels. We adjust the number of small liquid-fired and large liquid-fired boilers and respondents existing in 2013 by 33% to determine the number of small liquid-fired and large liquid-fired boilers existing in the first year of this ICR renewal (2022).
BLD Monitors















Size Category Total














Coal >10 80































Otherwise, all units will have an opacity monitor












Opacity monitors















Size Category Total














< 10 0














>= 10 to 100 0














>100 0














Grand Total 0































New Boiler Data






































Number of New Boilers Represented by Model


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





Growth in New Large Liquid-fired Units in Period June 2010 through June 2013
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
Category Years Growth a

Biomass <10 140 0 New Small Solid 295


Biomass <10 70.0 New Small Solid 148 49.2
Facilities 3 244

>= 10 to 100 11 0 New Large Solid 60


>= 10 to 100 5.5 New Large Solid 30 10.0
Boilers 3 487

>100 49 49 New Small Liquid -3,231


>100 24.5 New Small Liquid -1,615 -538.4
a The growth in number of facilites in the period June 2010 through June 2013 is used to calculate the number of new large liquid-fired boilers constructed since promulgation of the rule and thus subject to standards under this rule. Due to the decrease in fuel oil consumption indicated by the EIA data, we assume that no new oil-fired units were constructed after June 2013.
Coal <10 155 0 New Large Liquid -189


Coal <10 77.5 New Large Liquid -94.4 -31.5
>= 10 to 100 0 0 Grand Total -3,064


>= 10 to 100 0.0 Grand Total -1,532 -510.7
>100 0 0 New units/yr -1,021


>100 0.0



Liquid <10 -3231 0





Liquid <10 -1,615.3



>= 10 to 100 -186 0





>= 10 to 100 -93.0



>100 -3 0





>100 -1.4









Grand Total -3064 49





Grand Total -1,532
































BLD Monitors





Opacity monitors














Size Category Total




Size Category Total













new oil >10 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: revised to zero 0




new biomass >10 60




















new oil >10 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: revised to zero 0




































*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 $122.20 March 2021 Labor Rates



Managerial $69.04 Updated Labor rates to 2021 General Schedule












Clerical $61.51 March 2021 Labor Rates



Clerical $51.23 Updated Labor rates to 2021 General Schedule












Managerial $153.55 March 2021 Labor Rates



Technical $27.73 Updated Labor rates to 2021 General Schedule












General Contractor $80.00




Hotel $220 average 2021 rates, https://www.perdiem101.com/conus/2021












Certfied Energy Audit Contractor $56.78




Meals $96 average 2021 rates, https://www.perdiem101.com/conus/2022



















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: 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 1,967 197 98 $267,522.82 $0 0



Familiarization with Rule Requirements (existing sources) 1 $0 $0 1 1 5,757 5,757 576 288 $783,116.07 $0 0



B. Required Activities















Biennial Tune-Up 12 $2,228 $0 0.5 6 5,806 34,837 3,484 1,742 $4,738,824.85 $6,468,070 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 98 10 4.9 $13,376.04 $0 49



2) Notification of Compliance Status 8 $0 $0 1 8 49 393 39 20 $53,504.44 $0 49



3) Biennial Compliance Report 5 $0 $0 0.5 2.5 5,806 14,515 1,452 726 $1,974,510.53 $0 2,903



Subtotal for Reporting Requirements





66,203 $7,830,855 $6,468,070 3,001



4. Recordkeeping Requirements















A. Familiarization with Rule Requirements See 3A














B. Implement Activities N/A














C. Develop Record System d N/A














D. Record Information















1) Records of All Compliance Reports Submitted 2 $0 $0 1 2 5,806 11,612 1,161 581 $1,579,608.18 $0 0



2) Records of Biennial Tune-Up 0.5 $0 $0 0.5 0.25 5,806 1,452 145 73 $197,451.02 $0 0



E. Personnel Training N/A














F. Time for Audits N/A














Subtotal for Recordkeeping Requirements





15,023 $1,777,059 $0 0



Total Labor Burden and Costs (rounded) e






$9,607,914





Total Capital and O&M Cost (rounded) e







$6,468,070




GRAND TOTAL (rounded) e





81,226 $16,075,984
3,001



Assumptions











Notes


a On average, over the 3-year period of this ICR, we estimate 11,711 existing small solid boilers (i.e., units <10 MMBtu/hr) at 5,855 facilities will be subject to the rule. We also estimate 98 new boilers at 49 facilities per year, for a total of 11,809 boilers at 5,905 facilities. 11514 5757 11612 5806
b This ICR uses the following labor rates: $122.20 for technical, $153.55 for managerial, and $61.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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.















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
















Sheet 5: 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 $54,411 $0 0
Notes

Familiarization with Rule Requirements (existing sources) 1 $0 $0 $0 1 1 Stephen Treimel: Three year average of existing respondents. 2,110 2,110 211 105 $286,953 $0 0
New = constructed after June 4, 2010. Existing = constructed on or before June 4, 2010.

B. Required Activities













63.11205: Demonstrate compliance by stack testing, fuel analysis, or stack testing and subsequent CMS

1) Conduct Energy Audit













63.11220: For boilers >10 MMBtu, conduct stack tests on triennial basis.

a) Industrial d, e 20 $18,292 $0 $0 1 20 0 0 0 0 $0 $0 0
COAL: 573 existing coal boilers test for Hg and CO. No new coal boilers. New coal boilers test for Hg, CO, and PM.

b) Commercial d, e 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0
BIOMASS: 3466 existing biomass boilers using oxygen trim have no testing but must tune up biennially.

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
Notes:

4) Initial Stack Test (PM) f, h 12 $0 $8,000 $0 1 12 1.83 22.0 2.2 1.1 $2,987.74 $14,640 0
1.83 = 11 new biomass boilers in this ICR period / 2 boilers per respondent x 1/3 of respondents each year. 11/2/3 = 1.83

5) Triennial Stack Test (Hg) f 12 $0 $5,000 $0 1 12 95.5 1,146 114.6 57.3 $155,888.66 $477,500 0
95.5 = 573 existing large coal boilers x 1/3 test each year / 2 boilers per respondent. 573/3/2 = 95.5

6) Triennial Stack Test (CO) f 12 $0 $6,000 $0 1 12 95.5 1,146 114.6 57.3 $155,888.66 $573,000 0
95.5 = 573 existing large coal boilers x 1/3 test each year / 2 boilers per respondent. 573/3/2 = 95.6

7) Triennial Stack Test (PM) f, h 12 $0 $8,000 $0 1 12 5.5 66.0 6.60 3.30 $8,977.88 $44,000 0
5.5 respondents per year = 1/3 of all new biomass boilers > 10 MMBtu constructed since June 2010. 3 ICR periods x 11 new biomass boilers per ICR (growth rate) / 2 boilers per respondent x 1/3 of respondents test each year. ((3 x 11) / 2 / 3 = 5.5 . Note: new boilers constructed during this ICR period do not perform repeat testing during this ICR period.

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



9) Monthly Fuel Analysis for Hg Content g 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 $54,411.40 $0 0



b) Opacity (All Sources with ESPs)













Notes

i) Initial j 10 $0 $0 $43,100 1 10 1.83 $18.3 $1.83 $0.92 $2,490 $78,873 0
1.83 = 11 new biomass boilers in this ICR period / 2 boilers per respondent x 1/3 of respondents each year. 11/2/3 = 1.83

ii) Annual j 10 $0 $0 $14,700 1 10 20.2 $202 $20.2 $10.08 $27,423.35 $296,352 0
20.2 respondents per year = 1/3 of all new biomass boilers > 10 MMBtu constructed since June 2010. 3 ICR periods x 11 new biomass boilers per ICR (growth rate) + 2/3's of new biomass boilers constructed during this ICR period, / 2 boilers per respondent x all respondents test each year. ((3 x 11) + (2/3 x 11))/2 = 20.16

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
















i) Initial k 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0



ii) Annual k 10 $0 $0 $9,700 1 10 287 2,865 287 143 $389,721.65 $2,779,050 0
286.5 = all facilities w/ existing coal units (no new units). 573 coal boilers/2 boilers per facility = 286.5

11) Biennial Tune-Up l 12 $0 $2,875 $0 0.5 6 1,843 11,058 1,106 553 $1,504,203.15 $2,649,313 0
1,843 = existing large biomass boilers + 2/3's of new large biomass boilers

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 $2,720.57 $0 10



2) Notification of Compliance Status 8 $0 $0 $0 1 8 10 80 8 4 $10,882.28 $0 10



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

4) Annual Compliance Report 30 $0 $0 $0 1 30 2,130 63,885 6,389 3,194 $8,690,180.72 $0 2,130
2,130 = existing large coal + existing large biomass + 2/3's of new biomass

5) Biennial Compliance Report l 5 $0 $0 $0 0.5 2.5 1,843 4,607.5 460.8 230.4 $626,752.08 $0 922
1,843 = existing large biomass boilers + 2/3's of new large biomass boilers

Subtotal for Reporting Requirements






101,229 $11,973,893 $6,912,728 3,071



4. Recordkeeping Requirements
















A. Familiarization with Rule Requirements See 3A















B. Implement Activities N/A















C. Develop Record System m N/A















D. Record Information













Notes:

1) Records of Operating Parameter Values f 20 $0 $0 $0 1 20 307 6,133 613 307 $834,308.03 $0 0
307 = existing and new large coal boilers + new large biomass boilers constructed since June 2010 with PM limits and not subject to NSPS limits + 2/3's of large biomass boilers projected to be constructed during this three-year ICR period with PM limits and not subject to NSPS limits. (573/2 (existing coal) + ((11/2)*3) biomass boilers constructed since June 2010 + 2/3*(11/2) (2/3's of new biomass boilers)

2) Records of Deviations f 15 $0 $0 $0 1 15 307 4,600 460 230 $625,731.10 $0 0



3) Records of Stack Tests f 2 $0 $0 $0 1 2 307 613 61.3 30.7 $83,430.71 $0 0



4) Records of Monitoring Device Calibrations f 2 $0 $0 $0 1 2 307 613 61.3 30.7 $83,430.71 $0 0



5) Records of All Compliance Reports Submitted f 2 $0 $0 $0 2 4 2,130 8,518 852 426 $1,158,690.76 $0 0



6) Records of Monthly Fuel Use f 0.5 $0 $0 $0 12 6 307 1,840 184 92.0 $250,292.44 $0 0



7) Records of Biennial Tune-Up 0.5 $0 $0 $0 0.5 0.25 1,843 460.8 46.1 23.0 $62,675.82 $0 0



E. Personnel Training N/A















F. Time for Audits N/A















Subtotal for Recordkeeping Requirements






26,196 $3,098,560 $0 0



Total Labor Burden and Costs (rounded) n









$15,072,452





Total Capital and O&M Cost (rounded) n










$6,912,728




GRAND TOTAL (rounded) n






127,424 $21,985,180
3,071



Assumptions












Notes (Units vs. Respondents):


a On average, over the 3-year period of this ICR, we estimate 4,260 existing large solid boilers (i.e., biomass- and coal-fired boilers >10 MMBtu/hr) at 2,130 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 4,280 boilers at 2,140 facilities. 4219 2109.5 4239 2119.5
b This ICR uses the following labor rates: $122.20 for technical, $153.55 for managerial, and $61.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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 a 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. Large biomass boilers constructed since June 2010 and not subject to NSPS limits for PM under 40 CFR Part 60 Subparts Db or Dc are subject to PM limits under this rule.



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 New and existing large biomass boilers are subject to biennial tune-ups. These boilers also submit a biennial compliance report.



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.
















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

















Sheet 6: 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 0 0 0 0 $0 $0 0



Familiarization with Rule Requirements (existing sources) 1 $0 $0 1 1 53,304 53,304 5,330 2,665 $7,250,834 $0 0



B. Required Activities















Biennial Tune-Up 12 $2,228 $0 0.5 6 53,304 319,823 31,982 15,991 $43,505,003 $59,380,414 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 0 0 0 0 $0 $0 0



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



3) Biennial Compliance Report 5 $0 $0 0.5 2.5 53,304 133,259 13,326 6,663 $18,127,084 $0 26,652



Subtotal for Reporting Requirements





582,344 $68,882,921 $59,380,414 26,652



4. Recordkeeping Requirements















A. Familiarization with Rule Requirements See 3A














B. Implement Activities N/A














C. Develop Record System d N/A














D. Record Information















1) Records of All Compliance Reports Submitted 2 $0 $0 1 2 53,304 106,608 10,661 5,330 $14,501,668 $0 0



2) Records of Biennial Tune-Up 0.5 $0 $0 0.5 0.25 53,304 13,326 1,333 666 $1,812,710 $0 0



E. Personnel Training N/A














F. Time for Audits N/A














Subtotal for Recordkeeping Requirements





137,924 $16,314,378 $0 0



Total Labor Burden and Costs (rounded) e






$85,197,299





Total Capital and O&M Cost (rounded) e







$59,380,414




GRAND TOTAL (rounded) e





720,267 $144,577,713
26,652



Assumptions











Notes


a On average, over the 3-year period of this ICR, we estimate 105,532 existing small liquid boilers (i.e., units <10 MMBtu/hr) at 52,776 facilities will be subject to the rule. We also estimate a decrease of 538 small liquid boilers per year, for a total of 104,456 boilers at 52,228 facilities. 107684.41 53842.205 106607.5659 53303.78295
b This ICR uses the following labor rates: $122.20 for technical, $153.55 for managerial, and $61.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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.















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
















Sheet 7: 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 0 0 0 0 $0 $0 0



Familiarization with Rule Requirements (existing sources) 1 $0 $0 $0 $0 1 1 3,115 3,115 311 156 $423,679 $0 0



B. Required Activities

















1) Conduct Energy Audit

















a) Industrial d 20 $18,292
$0 $0 1 20 0 0 0 0 $0 $0 0



b) Commercial d 20 $854
$0 $0 1 20 0 0 0 0 $0 $0 0



2) Initial Stack Test and Report (PM) e 12 $0 $8,000 $0 $0 1 12 0 0 0 0 $0 $0 0
Notes

3) Triennial Stack Test and Report (PM) f 12 $0 $8,000 $0 $0 1 12 27 325 33 16 $44,255 $216,889 0
27 respondents = # respondents that have constructed since June 2010 and not subject to NPSP Subpart Db or Dc (244/3=81). Assume 1/3 test each year (81/3=27).

4) Continuous Parameter Monitoring

















a) Establish Site-specific monitoring plan g 40 $0 $0 $0 $0 1 40 0 0 0 0 $0 $0 0



b) Opacity (All Sources with ESPs)

















i) Initial 10 $0 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0



ii) Annual h 10 $0 $0 $0 $14,700 1 10 81 813 81 41 $110,636 $1,195,600 0
81 respondents = # respondents that have constructed since June 2010 and not subject to NPSP Subpart Db or Dc (244/3=81).

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

















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



ii) Annual 10 $0 $0 $0 $9,700 1 10 0 0 0 0 $0 $0 0



5) Biennial Tune-Up 12 $0 $0 $2,875 $0 0.5 6 3,115 18,688 1,868.8 934.39 $2,542,074.6 $4,477,288.82 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 0 0 0 0 $0 $0 0



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



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 81 2,440 244 122 $331,910 $0 81
81 respondents are subject to emission standards and are required to submit annual compliance reports.

5) Biennial Compliance Report 5 $0 $0 $0 $0 0.5 2.5 3,115 7,787 778.7 389.3 $1,059,198.30 $0 1,557



Subtotal for Reporting Requirements







38,143 $4,511,753 $5,889,778 1,639



4. Recordkeeping Requirements

















A. Familiarization with Rule Requirements See 3A
















B. Implement Activities N/A
















C. Develop Record System i N/A
















D. Record Information

















1) Records of Operating Parameter Values 20 $0 $0 $0 $0 1 20 3,115 62,293 6,229.3 3,114.6 $8,473,584.53 $0 0



2) Records of Deviations 15 $0 $0 $0 $0 1 15 3,115 46,720 4,672.0 2,336.0 $6,355,189.16 $0 0



3) Records of Stack Tests 2 $0 $0 $0 $0 1 2 3,115 6,229 622.9 311.5 $847,357.90 $0 0



4) Records of Monitoring Device Calibrations 2 $0 $0 $0 $0 1 2 3,115 6,229 622.9 311.5 $847,357.90 $0 0



5) Records of All Compliance Reports Submitted 2 $0 $0 $0 $0 2 4 3,115 12,459 1,245.9 622.9 $1,694,716.72 $0 0



6) Records of Monthly Fuel Use 0.5 $0 $0 $0 $0 12 6 3,115 18,688 1,868.8 934.4 $2,542,074.62 $0 0



7) Records of Biennial Tune-Up 0.5 $0 $0 $0 $0 0.5 0.25 3,115 779 77.9 38.9 $105,919.74 $0 0



E. Personnel Training N/A





.









F. Time for Audits N/A
















Subtotal for Recordkeeping Requirements







176,405 $20,866,201 $0 0



Total Labor Burden and Costs (rounded) j










$25,377,953





Total Capital and O&M Cost (rounded) j











$5,889,778




GRAND TOTAL (rounded) j







214,548 $31,267,731
1,639



Assumptions













Notes


a On average, over the 3-year period of this ICR, we estimate 6,167 existing large liquid boilers (i.e., units >10 MMBtu/hr) at 3,084 facilities will be subject to the rule. We also estimate a decrease of 31 large liquid boilers per year, for a total of 6,104 boilers at 3,052 facilities. 6292 3146 6229 3115
b This ICR uses the following labor rates: $122.20 for technical, $153.55 for managerial, and $61.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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. 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.



e All new 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.



f We assume one-third of respondents perform stack testing each year over the three-year period of this ICR. Liquid fuel boilers constructed since June 2010 that are > 10 MMBtu and <30 MMBtu/hr are not subject to PM limits under the NSPS (40 CFR Part 60 Subparts Db, Dc). These units will incur additional testing, monitoring, recordkeeping and reporting costs under this rule. The number of respondents required to perform stack testing is the number of respondents that constructed a boiler subject to the PM standard since promulgation of the rule in June 2010. EIA AEO data indicates that growth in this sector ceased in 2013 and began to decrease. This number represents the respondents constructing new boiler units in the three year period June 2010 through June 2013. We assume no new large liquid boilers have been constructed since that time.



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 The number of respondents with an annual opacity test represents the number of respondents constructed since promulgation of the rule and are not already subject to NSPS Subpart Db or Dc.. EIA AEO data indicates that growth in this sector ceased in 2013 and began to decrease. This number represents the respondents constructing new boiler units in the three year period June 2010 through June 2013. We assume no new large liquid boilers have been constructed since that time.



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



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




Sheet 8: Capital vs. O&M

Number of Respondents





Respondents That Submit Reports Respondents That Do Not Submit Any Reports





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




Number of New Respondents a 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
Count QA:


1 10 2,100 0 0 2,110
Notes (Units vs. Respondents):


2 10 2,110 0 0 2,120
4219 2,110 4239 2,120
3 10 2,120 0 0 2,130




Average 10 2,110 0 0 2,120




Large Liquid Boilers




1 -31.5 3,178 0 0 3,146




2 -31.5 3,146 0 0 3,115
6292 3,146 6229 3115
3 -31.5 3,115 0 0 3,083




Average -31.5 3,146 0 0 3,115




Small Solid Boilers




1 49 5,708 0 0 5,757




2 49 5,757 0 0 5,806
11514 5,757 11612 5806
3 49 5,806 0 0 5,855




Average 49 5,757 0 0 5,806




Small Liquid Boilers




1 -538 54,381 0 0 53,842




2 -538 53,842 0 0 53,304
107684.41 53,842 106608 53,304
3 -538 53,304 0 0 52,765




Average -538 53,842 0 0 53,304




Total -511 64,855 0 0 64,344
129,710


a New respondents include sources with constructed, reconstructed and modified affected facilities.
b Based on our research for this ICR, we determined that the number of respondents using liquid-fired boilers is decreasing at a rate of 1 percent per year during the three-year period of this ICR.
















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 2,130 1 0 2,130





Biennial Compliance Report 1,843 0.5 0 922





Subtotal


3,071





Large Liquid Boilers





Initial Notification 0 1 0 0





Notification of Compliance Status 0 1 0 0





Annual Compliance Report 81 1 0 81





Biennial Compliance Report 3,115 0.5 0 1,557





Subtotal


1,639





Small Solid Boilers









Initial Notification 49 1 0 49





Notification of Compliance Status 49 1 0 49





Biennial Compliance Report 5,806 0.5 0 2,903





Subtotal


3,001





Small Liquid Boilers





Initial Notification 0 1 0 0





Notification of Compliance Status 0 1 0 0





Biennial Compliance Report 53,304 0.5 0 26,652





Subtotal


26,652





Total (rounded)
34,363
































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) a $0 0 $0 $5,000 96 $477,500



Initial Stack Test and Report (CO) $6,000 0 $0 $0 0 $0



Triennial Stack Test and Report (CO) a $0 0 $0 $6,000 96 $573,000



Initial Stack Test and Report (PM) $8,000 1.8 $14,640 $0 0 $0



Triennial Stack Test and Report (PM) a $0 0 $0 $8,000 5.5 $44,000



Electrostatic Precipitator System $43,100 1.8 $78,873 $14,700 20.2 $296,352



Bag Leak Detection System $25,500 0 $0 $9,700 286.5 $2,779,050



Biennial Tune-Up $0 0 $0 $1,437.5 1,843 $2,649,313



Subtotal

$93,513

$6,819,215



Large Liquid Boilers









Initial Stack Test and Report (PM) $8,000 0 $0 $0 0 $0



Triennial Stack Test and Report (PM) a $0 0 $0 $8,000 27 $216,889



Electrostatic Precipitator System $43,100 0 $0 $14,700 81 $1,195,600



Bag Leak Detection System $25,500 0 $0 $9,700 0 $0



Biennial Tune-Up $0 0 $0 $1,438 3,115 $4,477,289



Subtotal

$0

$5,889,778



Small Solid Boilers









Biennial Tune-Up $0 0 $0 $1,114 5,806 $6,468,070



Subtotal

$0

$6,468,070



Small Liquid Boilers









Biennial Tune-Up $0 0 $0 $1,114 53,304 $59,380,414



Subtotal

$0

$59,380,414



Totals (rounded)

$93,500

$78,600,000
$78,700,000

a We assume that one-third of the respondents required to perform these tests will test each year during the three-year period of this ICR.



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