Burden Calculation Tables

2028t11.xlsx

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

Burden Calculation Tables

OMB: 2060-0551

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Overview

T1
T2
T3
BurdenSum
Respondent Data
Labor Rates
ELS
NLS
ESS
NSS
ELL
NLL
ESL
NSL
ELG
NLG
ESG
NSG
Capital vs. O&M


Sheet 1: T1

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


































Boiler Type Number of Units (Average) Number of Respondents per Year (Average) Number of Responses Per Year (Average) Reporting Recordkeeping Total Labor Hours Total Labor Cost Total Annual O&M and Annualized Capital Costs per year Total Costs
No. Response per Respondent Total Annual Response
Existing Large Solid Units 453 282 563 71,582 32,013 103,595 $12,253,764.68 $32,097,783 $44,351,547.68
2.00 563
New Large Solid Units 5 5 20 1,311 512 1,823 $215,605.17 $345,590.00 $561,195.17
4.00 20
Existing Small and Limited Use Solid Units 45 6 4 367 158 526 $62,187.70 $101,002.67 $163,190.36
0.63 4
New Small Solid Units 1 0.33 1 27 16 43 $5,089.73 $2,228.00 $7,317.73
0.00 0
Existing Large Liquid Units 37 21 42 5,729 2,568 8,297 $981,445.63 $786,707 $1,768,152.63
2.00 42
New Large Liquid Units 0 0 0 0 0 0 $0 $0 $0.00
0.00 0
Existing Small and Limited Use Liquid Units 25 3 2 198 78 276 $32,594.13 $55,700 $88,294.13
0.68 2
New Small Liquid Units 0 0 0 0 0 0 $0 $0 $0.00
0.00 0
Existing Large Gaseous Units 6,439 760 1,736 149,265 21,079 170,344 $20,149,244.23 $19,537,883 $39,687,127.57
2.28 1736
New Large Gaseous Units 261 33 100 6,285 3,563 9,848 $1,164,846.05 $750,375 $1,915,221.05
3.00 100
Existing Small and Limited Use Gaseous Units 9,789 1,150 575 77,463 30,587 108,050 $12,780,727.75 $15,466,620.00 $28,247,347.75
0.50 575
New Small Gaseous Units 326 41 103 4,725 2,027 6,752 $798,623.32 $726,328.00 $1,524,951.32
2.50 103
Subtotals (all types) 17,382 2,302 3,146 316,952 92,600 409,552 48,444,128 $69,870,217 $118,314,345
1.37 3146
GRAND TOTAL (rounded) a




410,000 $48,400,000 $69,900,000 $118,000,000
130 hours per response













Total Private Sector
2,164 2,957 297,935 87,044 385,000 $45,500,000 $65,700,000 $111,000,000


Total Public Sector
138 189 19,017 5,556 24,600 $2,910,000 $4,190,000 $7,100,000






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



Sheet 2: T2

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









Burden Item EPA hours per occurrence (A) Number of occurrences per year (B) EPA hours per occurrence per year (C=AxB) Technical hours per year (D=C) Management hours per year (E=Dx0.05) Clerical hours per year (F=Dx0.1) (H)
Costs, $ k
Footnotes
1. Familiarization with rule requirements 10 0 0 0 0 0 $0.00 a
2. Enter and update information into agency recordkeeping system 2 159 319 319 15.9 31.9 $11,569.19 b
3. Required activities







A. Review and approve monitoring plan 20 5 100 100 5 10 $3,630.50 n
B. Review and approve fuel monitoring plan 20 420 8,400 8,400 420 840 $304,962.00 o
C. Observe initial stack/performance test 40 4 160 160 8 16 $5,808.80 c
D. Observe repeat performance test 40 48 1,920 1,920 96 192 $69,705.60 d
E. Review operating parameters 2 20 40 40 2.0 4.0 $1,452.20 e
F. Review continuous parameter monitoring 2 495 990 990 49.5 99.0 $35,941.95 f
4. Excess Emissions Enforcement Activities and Inspections 24 2 0 0 0 0 $0 g
5. Notification requirements







A. Review initial notification that sources are subject to the standard 2 80 159 159 8.0 15.9 $5,784.60 b
B. Review notification of initial performance tests and review test plan 20 20 400 400 20 40 $14,522.00 e
C. Review notification of compliance status 2 80 159 159 8.0 15.9 $5,784.60 b
6. Reporting requirements

0 0 0 0 $0.00
A. Review semiannual compliance report 4 615 2,461 2,461 123.1 246.1 $89,358.71 h
B. Review annual compliance report 2 760 1,520 1,520 76.0 152.0 $55,183.60 i
C. Review biennial compliance report 1 600 600 600 30 60 $21,793.74 j
D. Review initial report on results of energy audit 2 0 0 0 0 0 $0 l
7. Travel Expenses for Tests Attended 3 days * ($220 hotel + $96 meals/incidentals) + ($600 round trip) = $1,548 per trip

$80,496 m
TOTAL (rounded)
19,800 $706,000 p









Assumptions
a Number of hours for agency staff to refamiliarize themselves with the rule requirements.
b Number of occurrences is based on the total number of affected facilities that are required to submit initial notifications (all new boilers in the large and small solid, liquid, and gaseous subcategories).
c Number of occurrences is based on the assumption that EPA personnel will observe 20% of the initial performance tests that occur.
d Number of occurrences is based on the assumption that of the units that test, 10% will have to retest and EPA personnel will observe all these retests. In addition solid fuel units are expected to re-test to obtain worst-case conditions for both Hg and HCl emissions.
e Number of occurrences is based on the number of units that will test and set/submit operating limits.
f Number of occurrences is based on the number of units maintaining records of control device parameters.
g Number of occurrences is based on the assumption that of the units that test, 10% of them will have exceedances and need enforcement.
h Number of occurrences is the number of units that will submit these semi-annual compliance reports, 2 reports per year per respondent.
i Number of occurrences is the number of units that will submit these annual compliance reports.
j Number of occurrences is the number units that will submit these biennial compliance reports.
k 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. These rates can be obtained from the OPM web site, http//www.opm.gov/oca/payrates/index/htm.
l Energy audits only occur at existing facilities.
m Total cost is based on the number of trips taken by EPA to observe performance tests in year 1 (4.A. & 4.B.) multiplied by $1,548 per trip. The source for hotel and meals/incidental costs is based on FY21 per diem rates, averaged across all locations in the United States. Airfares are estimated based on experience from other rulemakings. See: https://www.perdiem101.com/conus/2021
n Number of occurrences is based number of affected facilities which submit monitoring plan, all new large units are required to submit this.
o Number of occurrences is based off facilities which have emission limits plus gas units which must perform Hg spec analysis.
p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 3: T3

Table 3: Respondents and Units by Subcategory – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters












Year 1 Year 2 Year 3
Boiler Type Respondents per Year (Current) Units per Year (Current) New Respondents per Year New Units Per Year Total Respondents Total Units Total Respondents Total Units Total Respondents Total Units
Large Solid Units 277 448 5 5 282 453 287 458 292 463
Small and Limited Use Solid Units 6 44 0.33 1.33 6 45 7 47 7 48
Large Liquid Units 21 37 0 0 21 37 21 37 21 37
Small and Limited Use Liquid Units 3 25 0 0 3 25 3 25 3 25
Large Gaseous Units 727 6,178 33 261 760 6,439 794 6,701 827 6,962
Small and Limited Use Gaseous Units 1,109 9,463 41 326 1,150 9,789 1,191 10,115 1,232 10,441
Subtotals 2,143 16,195 80 594 2,223 16,789 2,302 17,382 2,382 17,976

Sheet 4: BurdenSum

Number of Respondents - All

Respondents That Submit Reports Respondents That Do Not Submit Any Reports
Year (A)
Number of New Respondents a
(B)
Number of Existing Respondents
(C)
Number of Existing Respondents that keep records but do not submit reports
(D)
Number of Existing Respondents That Are Also New Respondents
(E)
Number of Respondents
(E=A+B+C-D)
1 79 2,143 0 0 2,222
2 79 2,222 0 0 2,302
3 79 2,301 0 0 2,381
Average 79 2,222 0 0 2,302






Number of Respondents - By Subcategory

Respondents That Submit Reports Respondents That Do Not Submit Any Reports
Year (A)
Number of New Respondents
(B)
Number of Existing Respondents
(C)
Number of Existing Respondents that keep records but do not submit reports
(D)
Number of Existing Respondents That Are Also New Respondents
(E)
Number of Respondents
(E=A+B+C-D)
Large Solid Units 5 282 0 0 286
Small Solid Units 0 6 0 0 7
Large Liquid Units 0 21 0 0 21
Small Liquid Units 0 3 0 0 3
Large Gaseous Units 33 760 0 0 794
Small Gaseous Units 41 1,150 0 0 1,191
Total 79 2,222 0 0 2,302


















Total Annual Responses
(A)
Boiler Type
(B)
Number of Respondents (facilities)
(C)
Number of Responses (Average)
(D)
Number of Existing Respondents That Keep Records But Do Not Submit Reports
(E)
Total Annual Responses

Existing Large Solid Units 282 2 0 563
New Large Solid Units 5 4 0 20
Existing Small Solid Units 6 0.6 0 4
New Small Solid Units 0 3 0 1
Existing Large Liquid Units 21 2 0 42
New Large Liquid Units 0 0 0 0
Existing Small Liquid Units 3 0.7 0 2
New Small Liquid Units 0 0.0 0 0
Existing Large Gaseous Units 760 2.3 0 1,736
New Large Gaseous Units 33 3 0 100
Existing Small Gaseous Units 1150 0.5 0 575
New Small Gaseous Units 41 2.5 0 103
TOTAL 2,302 21 0 3,146







207.18









ICRAS SUMMARY REPORTING RECORDKEEPING
Annual Burden Hours Number of Respondents (Facilities) Number of Responses Annualized Capital/Start-up and O&M Annual Burden Hours
Year 0 (2013) #REF! #REF! #REF! #REF! #REF!
Annual Burden 316,952 2,302 3,146 $69,870,217 92,600
Cost per Response


$37,610
Burden Hours per Response


130






INDUSTRY 3- year period Average per year Public Sector Private Sector
Reporting Hours
316,952 19,017 297,935
Recordkeeping Hours
92,600 5,556 87,044
Total HOURS 409,552 136,517 8,191 128,326
TOTAL COSTS (non-labor) $69,870,217 $23,290,072 $1,397,404 $21,892,668
Total LABOR COSTS $48,444,128 $16,148,043 $968,883 $15,179,160
TOTAL LABOR AND NON-Labor COSTS $118,314,345 $39,438,115 $2,366,287 $37,071,828
Total Responses
3,146 189 2,957
Tracy Curtis: Previous small entity assumption is based on 151 of 1701 facilities being small entities (or 9%). Adjusted to 9% of 2020 facilities or 207. Small Entity Respondents per year (9% of respondents)

12 195
Total Respondents per year

138 2,164












AGENCY Average per year Average per year (rounded)


Hours 19,800 19,800


Costs (labor + travel) $706,000 $706,000



Sheet 5: Respondent Data


NEW ASSUMPTIONS for 2028.11 ICR Renewal:



















Number of existing large biomass, large coal, large liquid and large Gas 2 units and facilities are taken from December 2020 CEDRI data.



















Number of new large biomass units and facilities are taken from CEDRI data.



















Assume no growth in small coal, large coal, small liquid, large liquid, Gas 1 Other, or Gas 2 units or facilities.



















Update existing unit and facility counts for limited and small biomass, large Gas 1 NG only, and limited and small Gas 1 NG only based on previous trends in 2028.09.



















Number of new small biomass and new Gas 1 NG only units and facilities are based on previous trends in 2028.09.



















Updated labor rates for industry and agency to 2021 values.



















Additional assumptions updated in following spreadsheets (see comments)








































Boiler Data




















Data source is 2028.09
Assume growth is zero

















Data source is CEDRI 12/2020

















Summary of Unit Count and Facility Count




Existing Respondents/Year
Count of Limited Use Units from 2028.09


Mact Floor Fuel Category Size Category Total Existing Units Total Existing Facilities Total New Units Total New Facilities Total New Boilers over 3-Year Period Total New Facilities over 3-Year Period



Yr1 Yr 2 Yr 3 Avg
Mact Floor Fuel Category Size Category Total

Biomass Limited Use 4 1 0 0




Large Solid 277 282 287 282
Biomass <10 0

<10 25 3 4 1 0 0


Large Liquid 21 21 21 21
>=10 to 100 1

>=10 to 100 104 60 5 4 5 4


Large Gas 727 760 793 760
100 to 250 3

100 to 250 49 43 1 1 1 1


Small Solid 6 6 6 6
>250 0

>250 162 106 9 9 9 9


Small Liquid 3 3 3 3




Coal Limited Use 15 2 0 0




Small Gas 1109 1150 1191 1150
Coal <10 0

<10 0 0 0 0 0 0


Total Existing 2143 2222 2301 2222
>=10 to 100 7

>=10 to 100 8 4 0 0 0 0








100 to 250 7

100 to 250 57 32 0 0 0 0


New Respondents/Year



>250 1

>250 68 32 0 0 0 0


Small Biomass 0







Gas 1 (NG Only) Limited Use 333 39 0 0




Large Biomass 5



Gas 1 (NG Only) <10 7

<10 9,079 1,065 978 123 978 123


Small Coal 0



>=10 to 100 215

>=10 to 100 4,285 504 553 70 553 70


Large Coal 0



100 to 250 89

100 to 250 1,284 151 165 21 165 21


Small Gas 1 41



>250 22

>250 609 72 66 9 66 9


Large Gas 1 33







Gas 1 (Other Gases) Limited Use 0 0 0 0




Small Gas 2 0



Gas 1 (Other Gases) <10

<10 0 0 0 0




Large Gas 2 0



>=10 to 100

>=10 to 100 0 0 0 0




Small Liquid 0



100 to 250

100 to 250 0 0 0 0




Large Liquid 0



>250

>250 0 0 0 0




Total New 79







[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: since no CEDRI gas 2 and these units must report emission test results assume no gas 2 units. Gas 2 Limited Use 4 0 0 0










Gas 2 <10 0

<10 47 5 0 0 0 0








>=10 to 100 0

>=10 to 100 0 0 0 0 0 0








100 to 250 4

100 to 250 0 0 0 0 0 0








>250 0

>250 0 0 0 0 0 0












Liquid Limited Use 8 1 0 0










Liquid <10 13

<10 17 2 0 0 0 0








>=10 to 100 57

>=10 to 100 18 11 0 0 0 0








100 to 250 40

100 to 250 15 6 0 0 0 0








>250 15

>250 4 4 0 0 0 0








Grand Total
481

Grand Total
16,195 2,143 1,781 238 1777 222

































Mercury Fuel Spec Analysis (for other Gas 1 units) - Number estimated to test


413 =2.7% of all gas units > 10 MMBtu














Number which will repeat stack test due to switching fuels


448 (applicable to all large solid units)














Notification of Alternative fuel use (15.8% reported the use of liquid, large gas 1 units)


976















Fuel Monitoring Plan - For facilities which have emission limits or for Gas facilities which perform the Hg gas spec 830















CEDRI data indicates the number of existing large liquid units have decreased by 533, or 93.5% since 2028.09. The number of existing limited use liquid units and small liquid units has also been decreased proportionally.



















PM CEMS required for all units >250 that are firing liquid or solid fuels



















Tune-ups required for all units <10 and all gas 1 units, regardless of size



















Existing large Gas 2 units: since there are no Gas 2 units in CEDRI and these units must report emission test results, assume no gas 2 units.


















































































These public vs private sector calculations are from 2028.09



















5_AffectedSector 8_Small Entity Count % of Total
















Not-for-Profit False 22

















Not-for-Profit True 6 0.94 Private %















Not-for-Profit Unknown 3 0.06 Public %















Private Enterprise False 1276

















Private Enterprise True 131

















Private Enterprise Unknown 80

















Public Sector False 82
% Small Entity















Public Sector True 14 Private Sector 0.1















Public Sector Unknown 6 Public Sector 0.15















Did not use these unknowns:



















Unknown False 3

















Unknown Unknown 78






































5_AffectedSector 8_Small Entity Count

















Not-for-Profit False 22

















Not-for-Profit True 6 151 7%




































Private Enterprise False 1276

















Private Enterprise True 131






































Public Sector False 82

















Public Sector True 14






































Did not use these unknowns:



















Unknown False 3

















Unknown Unknown 78

















Not-for-Profit Unknown 3

















Private Enterprise Unknown 80

















Public Sector Unknown 6

















Sheet 6: Labor Rates

Labor Rates - Industry




Labor Rates - Agency












Category Rate Note


Managerial $69.04 Updated Labor rates to 2021 General Schedule
Technical $122.20 March 2021 Labor Rates


Clerical $51.23

Clerical $61.51 March 2021 Labor Rates


Technical $27.73

Managerial $153.55 March 2021 Labor Rates






General Contractor $80.00



Per Diem Info


Certfied Energy Audit Contractor $56.78



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






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






Airfare $600







Trip Length 3







Total (3 days) $1,548

















Other Data








Percent of Stack Tests Observed 20%






Estimated Percent Retesting 10%






Estimated Percent Emission Exceedences 10%

Sheet 7: ELS

Table 1.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)


Existing Large Solid Fuel Units


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 (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA















2. Surveys and Studies NA















3. Reporting Requirements
















A. Familiarization with Rule Requirements 10 $0 $0 $0 1 10 282 2,817 282 141 $383,147 $0 282 a


B. Required Activities
















1. Conduct Energy Audit
















a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d


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


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


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


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


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


6. Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 453 5,436 544 272 $739,451 $2,265,000 0 c,h,i


7. Annual Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 453 5,436 544 272 $739,451 $3,624,000 0 c, i


8. Annual Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 453 5,436 544 272 $739,451 $3,624,000 0 c, i


9. Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 453 5,436 544 272 $739,451 $3,171,000 0 c, i


10. Repeat Stack Test and Report if Switch Fuels
(for Hg and HCl)
24 $0 $16,000 $0 1 24 453 10,872 1,087 544 $1,478,902 $7,248,000 0 c,j


11. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 c,g


12. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0 0 c,g


13. Annual Tune-up 12 $0 $2,875 $0 1 12 453 5,436 544 272 $739,451 $1,302,375 0 c,k


14. Continuous Parameter Monitoring












m


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


Opacity
















a) initial 10 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0 c,m


b) annual 10 $0 $0 $14,700 1 10 217 2,170 217 109 $295,182 $3,189,900 0 c,m


PM (only sources greater than 250 mmBtu/hr)
















a) initial 10 $0 $0 $158,000 1 10 0 0 0 0 $0 $0 0 c,L,m


b) annual 10 $0 $0 $56,100 1 10 66 660 66 33 $89,779 $3,702,600 0 c,L,m


O2
















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


b) annual 10 $0 $0 $1,436 1 10 453 4,530 453 227 $616,209 $650,508 0 c,m


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

















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0 c,m


b) annual 10 $0 $0 $5,600 1 10 103 1,030 103 52 $140,109 $576,800 0 c,m


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

















a) initial 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0 c,m


b) annual 10 $0 $0 $9,700 1 10 85 850 85 42.5 $115,624 $824,500 0 c,m


DIFF Monitor
















a) initial 10 $0 $0 $43,500 1 10 0 0 0 0 $0 $0 0 c,m


b) annual 10 $0 $0 $26,500 1 10 64 640 64 32 $87,058 $1,696,000 0 c,m


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 0 c,m


b) annual 10 $0 $0 $9,700 1 10 23 230 23 11.5 $31,287 $223,100 0 c,m


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 0 a


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


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


4) Semi-annual Compliance Report 20 $0 $0 $0 2 40 282 11,267 1,127 563 $1,532,588 $0 563 a










62,245 6,225 3,112



$32,097,783 $0
Reporting Subtotal






71,582 $8,467,139 $32,097,783 563



4. Recordkeeping Requirements
















A. Familiarization with Rule Requirements Included in 3a















B. Implement Activities NA















C. Develop Record System NA











e


D. Record Information
















1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 453 9,060 906 453 $1,232,418 $0 0 c


2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 453 6,795 680 340 $924,314 $0 0 c,n


3) Records of Stack Tests 2 $0 $0 $0 1 2 453 906 91 45 $123,242 $0 0 c


4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 453 906 91 45 $123,242 $0 0 c


5) Records of All Compliance Reports Submitted 2 $0 $0 $0 2 4 453 1,812 181 91 $246,484 $0 0 c


6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 453 2,718 272 136 $369,725 $0 0 c


E. Personnel Training 40 $0 $0 $0 1 40 141 5,640 564 282 $767,201 $0 0 f


F. Time for Audits NA























27,837 2,784 1,392



$0

Recordkeeping Subtotal






32,013 $3,786,625 $0 0











90,082 9,008 4,504






Totals






103,595 $12,253,765 $32,097,783 563





















Assumptions
















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 10 hours.




b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 88% of facilities are in the industrial sector while the remaining 12% of facilities are in the commercial sector.
c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting semi-annual reports and conducting the required recordkeeping.




d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.




e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.
















f For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.
















g Existing large solid units are expected to determine compliance through stack testing and not fuel analysis
















h Units not equipped with PM CPMS wil perform stack testing for PM.
















i Annual testing is based on the average number of existing units.




j Only applies to large solid fuel boilers, because solid fuel boilers may fire a mix of non-homogeneous fuels. Assumed all solid fuel units would perform a repeat stack test.
















k Tune-ups are required as work practice standards in lieu of dioxin/furan testing. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.


l PM CPMS is only required for coal boilers, biomass boilers which are not 100% biomass, and residual oil boilers which are >= 250 mmBtu/hr that were construction prior to June 4, 2010.
















m The number of units expected to require each type of parameter monitoring are taken from the CEDRI data, December 2020, and represent the reported data on units utilizing each type of monitoring.



n Includes enhanced recordkeeping provisions for demonstration of compliance with the alternative definition of "startup" (paragraph (2) of the definition) that document when useful thermal energy is provided, what fuels are used during startup, parametric monitoring data to verify relevant controls are engaged, and the time when PM controls are engaged. It is assumed that no one is using the compliance alternatives at this time.




Sheet 8: NLS

Table 2.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)

New Large Solid Fuel Units

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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA














2. Surveys and Studies NA














3. Reporting Requirements















A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 5 200 20 10 $27,206 $0 0 a

B. Required Activities















1. Initial Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 5 60 6 3 $8,162 $25,000 0 a

2. Initial Stack Test and Report (for Hg) 12 $0 $8,000 $0 1 12 5 60 6 3 $8,162 $40,000 0 a

3. Initial Stack Test and Report (for HCl) 12 $0 $8,000 $0 1 12 5 60 6 3 $8,162 $40,000 0 a

4. Initial Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 5 60 6 3 $8,162 $35,000 0 a

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

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

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

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

9. Repeat Stack Test and Report if Switch Fuels
(for Hg and HCl)
24 $0 $16,000 $0 1 24 5 120 12 6 $16,323 $80,000 0 a,d

10. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 a,e

11. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0 0 a,e

12. Annual Tune-up 12 $0 $2,875 $0 1 12 5 60 6 3 $8,162 $14,375 0 a,g

13. Continuous Parameter Monitoring












i

Establish Site-specific monitoring plan (all) 40 $0
$0 1 40 5 200 20 10 $27,206 $0 0 a

Opacity















a) initial 10 $0 $0 $43,100 1 10 1 10 1 1 $1,360 $43,100 0 a

b) annual 10 $0 $0 $14,700 1 10 0 0 0 0 $0 $0 0 a

PM (only sources greater than 250 mmBtu/hr)















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

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

O2















a) initial 10 $0 $0 $8,523 1 10 5 50 5 3 $6,801 $42,615 0 a

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

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
















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0 a

b) annual 10 $0 $0 $5,600 1 10 0 0 0 0 $0 $0 0 a

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
















a) initial 10 $0 $0 $25,500 1 10 1 10 1 1 $1,360 $25,500 0 a

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

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 0 a

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

C. Create Information NA














D. Gather Information NA














E. Report Preparation















1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 5 10 1 1 $1,360 $0 5 b

2) Notification of Compliance Status 8 $0 $0 $0 1 8 5 40 4 2 $5,441 $0 5 b

3) Semi-annual Compliance Report 20 $0 $0 $0 2 40 5 200 20 10 $27,206 $0 10 b









1,140 114 57





Reporting Subtotal






1,311 $155,072 $345,590 20
$234,375 $111,215
4. Recordkeeping Requirements















A. Read and Understand Rule Requirements Included in 3a














B. Implement Activities NA














C. Develop Record System NA











c

D. Record Information















1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 5 100 10 5 $13,603 $0 0 a

2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 5 75 8 4 $10,202 $0 0 a, j

3) Records of Stack Tests 2 $0 $0 $0 1 2 5 10 1 1 $1,360 $0 0 a

4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 5 10 1 1 $1,360 $0 0 a

5) Records of All Compliance Reports Submitted 2 $0 $0 $0 2 4 5 20 2 1 $2,721 $0 0 a

6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 5 30 3 2 $4,081 $0 0 a,g

E. Personnel Training 40 $0 $0 $0 1 40 5 200 20 10 $27,206 $0 0 f

F. Time for Audits NA






















445 45 22





Recordkeeping Subtotal






512 $60,533 $0 0
$0








1,585 159 79





Totals






1,823 $215,605 $345,590 20



















Assumptions















a In order to calculate a per year estimate of the number of boilers and facilities required to meet these rule requirements, the number of projected boilers and facilities is each divided by 3.



b Assumed reporting activities would start the first year a boiler is applicable to rule.



c Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.



d Only applies to large solid fuel boilers, because solid fuel boilers may fire a mix of non-homogeneous fuels. Assumed all solid fuel units would perform a repeat stack test.

e Existing large solid units are expected to determine compliance through stack testing and not fuel analysis















f For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes all new respondents will conduct training.


g Tune-ups are required as work practice standards in lieu of dioxin/furan testing. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.

h PM CPMS is required for coal boilers, biomass boilers which are not 100% biomass, and residual oil boilers which are >= 250 mmBtu/hr. It was assumed all new solid fuel boilers are firing 100% biomass.




i The number of units expected to require each type of parameter monitoring are taken from the CEDRI data, December 2020, and represent the reported data on units utilizing each type of monitoring.

j Includes enhanced recordkeeping provisions for demonstration of compliance with the alternative definition of "startup" (paragraph (2) of the definition) that document when useful thermal energy is provided, what fuels are used during startup, parametric monitoring data to verify relevant controls are engaged, and the time when PM controls are engaged. It is assumed that no one is using the compliance alternatives at this time.



Sheet 9: ESS

Table 3.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)

Existing Small and Limited Use Solid Fuel Units

Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up 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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA














2. Surveys and Studies NA














3. Reporting Requirements















A. Familiarization with Rule Requirements 5 $0 $0 $0 1 5 6 32 3 2 $4,308 $0 0 a

B. Required Activities















1. Conduct Energy Audit















a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b,c, d

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

2. Biennual Tune-Up 12 $0 $2,228 $0 0.5 6 45 272 27.2 13.6 $37,000 $101,003 0 c,i

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 0 a

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

3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 6 16 1.58 0.79 $2,154 $0 3 f

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









320 32 16





Reporting Subtotal






367 $43,461 $101,003 4
$101,003 0
4. Recordkeeping Requirements















A. Familiarization with Rule Requirements Included in 3a














B. Implement Activities NA














C. Develop Record System NA











e

D. Record Information















1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 6 6 0.63 0.32 $862 $0 0 c

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

3) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 45 11 1.13 0.57 $1,542 $0 0 c

E. Personnel Training 40 $0 $0 $0 1 40 3 120 12 6 $16,323 $0 0 h

F. Time for Audits NA






















138 14 6.88





Recordkeeping Subtotal






158 $18,727 $0 0
$0








457 46 23





Totals






526 $62,188 $101,003 4



















Assumptions















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 5 hours for small units.

b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution facility NAICS codes in the 2008 combustion unit survey database, 12% of facilities are in the commercial sector while the remaining 88% of facilities are in the industrial sector.
c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting reports and conducting the required recordkeeping. Annualized cost of $2228 for a tune-up is calculated considering a biennual schedule.



d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals. It is assumed that all will be industrial facilities since industrial is the vast majority of projected units.

e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.















f Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.















g Small units are not required to maintain records on startup, shutdown and malfunction.















h For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.















i Assumes a biennial tune-up is conducted on half of all units each year. Some very small boilers (<5mmBtu/hr) or limited use boilers which operate less than 100 hours annually qualify for tune-ups every five years, however they would still incur an initial tune-up. For the time period of this ICR, there will not be a difference in burden associated with biennial vs 5-year tune-ups for existing units.



Sheet 10: NSS

Table 4.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)


New Small Solid Fuel Units


Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up 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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA















2. Surveys and Studies NA















3. Reporting Requirements
















A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 0.33 13 1 1 $1,814 $0 0 a


B. Required Activities
















1. Biennial Tune-Up 12 $0 $2,228 $0 0.5 6 1 6 0.6 0.3 $816 $2,228 0 a


C. Create Information NA















D. Gather Information NA















E. Report Preparation
















1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 0.33 1 0 0 $91 $0 0.33 a


2) Notification of Compliance Status 8 $0 $0 $0 1 8 0.33 3 0 0 $363 $0 0.33 a


3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 0.33 0.8 0.08 0.04 $113 $0 0.17 d










24 2 1






Reporting Subtotal






27 $3,197 $2,228 1
$2,228 0
4. Recordkeeping Requirements
















A. Read and Understand Rule Requirements Included in 3a















B. Implement Activities NA















C. Develop Record System NA











b


D. Record Information
















1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 0.33 0 0.03 0.02 $45 $0 0 a


2) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 1 0 0.03 0.01 $34 $0 0 a, d


E. Personnel Training 40 $0 $0 $0 1 40 0.33 13 1 1 $1,814 $0 0 c


F. Time for Audits NA























13.9 1.4 0.7






Recordkeeping Subtotal






16 $1,893 $0 0
$0









37 4 2






Totals






43 $5,090 $2,228 1





















Assumptions
















a Assumes one respondent with new small solid units per 3-year period, and that a tune-up is conducted on all units.




b Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.




c For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes all new respondents will conduct training.
















d Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.

















Sheet 11: ELL

Table 5.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)


Existing Large Liquid Fuel Units


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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA















2. Surveys and Studies NA















3. Reporting Requirements
















A. Familiarization with Rule Requirements 10 $0 $0 $0 1 10 21 210 21 11 $28,566 $0 21 a


B. Required Activities
















1. Conduct Energy Audit
















a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d


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


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


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


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


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


6. Annual Stack Test and Report (for PM) 12 $0 $5,000 $0 1 12 37 444 44 22 $60,397 $185,000 0 c,h,j


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


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


9. Annual Stack Test and Report (for CO) 12 $0 $7,000 $0 1 12 37 444 44 22 $60,397 $259,000 0 c,j


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 0 c,f


11. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 c,g


12. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 37 2,220 222 111 $301,983 $177,600 0 c,g


13. Annual Tune-up 12 $0 $2,875 $0 1 12 37 444 44 22 $60,397 $106,375 0 c, l


14. Continuous Parameter Monitoring












n


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


Opacity
















a) initial 10 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0 c


b) annual 10 $0 $0 $14,700 1 10 0 0 0 0 $0 $0 0 c


PM (only sources greater than 250 mmBtu/hr)
















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


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


O2
















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


b) annual 10 $0 $0 $1,436 1 10 37 370 37 19 $50,331 $53,132 0 c,n


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

















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0 c,n


b) annual 10 $0 $0 $5,600 1 10 1 10 1 0.5 $1,360 $5,600 0 c,n


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

















a) initial 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0 c,n


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


DIFF Monitor
















a) initial 10 $0 $0 $43,500 1 10 0 0 0 0 $0 $0 0 c,n


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


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 0 c,n


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


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 0 a


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


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


4) Semi-annual Compliance Report 20 $0 $0 $0 2 40 21 840 84 42 $114,264 $0 42 c










4,982 498 249






Reporting Subtotal






5,729 $677,694 $786,707 42
$786,707 $0
4. Recordkeeping Requirements
















A. Familiarization with Rule Requirements Included in 3a















B. Implement Activities NA















C. Develop Record System NA











e


D. Record Information
















1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 37 740 74 37 $100,661 $0 0 c


2) Records of Startup, Shutdown, Malfunction 15 $0 $0 $0 1 15 37 555 56 28 $75,496 $0 0 c,o


3) Records of Stack Tests 2 $0 $0 $0 1 2 37 74 7 4 $10,066 $0 0 c


4) Records of Monitoring Device Calibrations 2 $0 $0 $0 1 2 37 74 7 4 $10,066 $0 0 c


5) Records of All Compliance Reports Submitted 2 $0 $0 $0 2 4 37 148 15 7 $20,132 $0 0 c


6) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 37 222 22 11 $30,198 $0 0 c


E. Personnel Training 40 $0 $0 $0 1 40 11 420 42 21 $57,132 $0 0 k


F. Time for Audits NA























2,233 223 112






Recordkeeping Subtotal






2,568 $303,752 $0 0
$0









7,215 722 361






Totals






8,297 $981,446 $786,707 42





















Assumptions
















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 10 hours.
















b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 88% of facilities are in the industrial sector while the remaining 12% of facilities are in the commercial sector.




c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting semi-annual reports and conducting the required recordkeeping.




d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.


e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.
















f Only applies to large solid fuel boilers, because solid fuel boilers may fire a mix of non-homogeneous fuels. Assumed zero respondents for liquid and gas units.






g Existing large liquid units are expected to determine compliance for Hg and HCl through fuel analysis not stack testing.
















h Units not equipped with PM CPMS wil perform stack testing for PM.
















j Annual testing is based on the number of existing units in the three years following promulgation of the November 20, 2015 final rule.




k For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.
















l Tune-ups are required as work practice standards in lieu of dioxin/furan testing. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.



m PM CPMS is required for coal boilers, biomass boilers which are not 100% biomass, and residual oil boilers which are >= 250 mmBtu/hr
















n The number of units expected to require each type of parameter monitoring are taken from the CEDRI data, December 2020, and represent the reported data on units utilizing each type of monitoring.



o Includes enhanced recordkeeping provisions for demonstration of compliance with the alternative definition of "startup" (paragraph (2) of the definition) that document when useful thermal energy is provided, what fuels are used during startup, parametric monitoring data to verify relevant controls are engaged, and the time when PM controls are engaged. It is assumed that no one is using the compliance alternatives at this time.




Sheet 12: NLL

Table 6.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, subpart DDDDD) (Renewal)

New Large Liquid Fuel Units

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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA














2. Surveys and Studies NA














3. Reporting Requirements















A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 0 0 0 0 $0 $0 0 a

B. Required Activities















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


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


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


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


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


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


13. Continuous Parameter Monitoring















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


Opacity











0


a) initial 10 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0


b) annual 10 $0 $0 $14,700 1 10 0 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 0


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


O2















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


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


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
















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0


b) annual 10 $0 $0 $5,600 1 10 0 0 0 0 $0 $0 0


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
















a) initial 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0


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


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


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


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










0 0 0





Reporting Subtotal






0 $0 $0 0
$0 $0
4. Recordkeeping Requirements















A. Read and Understand Rule 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 0


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


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


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


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


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


F. Time for Audits NA






















0 0 0





Recordkeeping Subtotal






0 $0 $0 0
$0








0 0 0





Totals






0 $0 $0 0



















Assumptions















a There are no new large liquid units expected to be constructed/reconstructed over the next 5 years




Sheet 13: ESL

Table 7.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)

Existing Small and Limited Use Liquid Fuel Units

Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up 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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA














2. Surveys and Studies NA














3. Reporting Requirements















A. Familiarization with Rule Requirements 5 $0 $0 $0 1 5 3 15 1 1 $1,989 $0 0 a

B. Required Activities















1. Conduct Energy Audit















a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d

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

2. Biennual Tune-Up 12 $0 $2,228 $0 0.5 6 25 150 15.0 7.5 $20,404 $55,700 0 c, f, i

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 0 a

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

3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 3 7 0.7 0.4 $995 $0 1 c, f

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

Reporting Subtotal






198 $23,388 $55,700 2
$55,700 0
4. Recordkeeping Requirements















A. Familiarization with Rule Requirements Included in 3a














B. Implement Activities NA














C. Develop Record System NA











e

D. Record Information















1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 3 3 0.3 0.1 $398 $0 0 c

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

3) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 25 6 0.6 0.3 $850 $0 0 c, f

E. Personnel Training 40 $0 $0 $0 1 40 1.5 59 6 3 $7,958 $0 0 h

F. Time for Audits NA














Recordkeeping Subtotal






78 $9,206 $0 0
$0
Totals






276 $32,594 $55,700 2



















Assumptions















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 5 hours for small units.

b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 88% of facilities are in the industrial sector while the remaining 12% of facilities are in the commercial sector.
c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting reports and conducting the required recordkeeping. Annualized cost of $2228 for a tune-up is calculated considering a biennual schedule.



d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.

e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.















f Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.















g Small units are not required to maintain records on startup, shutdown and malfunction.















h For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.















i Assumes a biennial tune-up is conducted on half of all units each year. Some very small boilers (<5mmBtu/hr) or limited use boilers which operate less than 100 hours annually qualify for tune-ups every five years, however they would still incur an initial tune-up. For the time period of this ICR, there will not be a difference in burden associated with biennial vs 5-year tune-ups for existing units.


Sheet 14: NSL

Table 8.B.: Annual Respondent Burden and Cost -- NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal) – Year 2

New Small Liquid Fuel Units

Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up 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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA














2. Surveys and Studies NA














3. Reporting Requirements















A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 0 0 0 0 $0 $0 0 a

B. Required Activities















1. Biennial Tune-Up 12 $0 $2,228 $0 0.5 6 0 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 0


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


3) Biennial Compliance Report 5 $0 $0 $0 0.5 2.5 0 0 0 0 $0 $0 0


Reporting Subtotal






0 0 0 0
$0 0
4. Recordkeeping Requirements















A. Read and Understand Rule Requirements Included in 3a














B. Implement Activities NA














C. Develop Record System NA














D. Record Information















1) Records of All Notifications and Compliance Reports Submitted 2 $0 $0 $0 0.5 1 0 0 0 0 $0 $0 0


2) Biennial Tune-Up Records 0.5 $0 $0 $0 0.5 0.25 0 0 0 0 $0 $0 0


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


F. Time for Audits NA














Recordkeeping Subtotal






0 $0 $0 0
$0
Totals






0 $0 $0 0



















Assumptions















a There are no new small solid units expected to be constructed/reconstructed over the next 3 years.




Sheet 15: ELG

Table 9.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)


Existing Large Gas Fuel Units


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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA















2. Surveys and Studies NA















3. Reporting Requirements
















A. Familiarization with Rule Requirements 10 $0 $0 $0 1 10 760 7,603 760 380 $1,034,270 $0 0 a


B. Required Activities
















1. Conduct Energy Audit
















a) Commerical 20 $854 $0 $0 1 20 0 0 0 0 $0 $0 0 b, c, d


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


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


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


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


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


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


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


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


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


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 0 c,f


11. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 c,g


12. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0 0 c,g


13. Continuous Parameter Monitoring












o


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


Opacity
















a) initial 10 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0 c,h


b) annual 10 $0 $0 $14,700 1 10 0 0 0 0 $0 $0 0 c,h


PM (only sources greater than 250 mmBtu/hr)
















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


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


O2
















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


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


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

















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0 c,o


b) annual 10 $0 $0 $5,600 1 10 6 60 6 3 $8,162 $33,600 0 c,o


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

















a) initial 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0 c,o


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


14. Annual Tune-up 12 $0 $2,875 $0 1 12 6,439 77,272 7,727 3,864 $10,511,194 $18,513,083 0 c,k


15. Mercury Fuel Spec Analysis 5 $0 $200 $0 12 60 413 24,780 2,478 1,239 $3,370,786 $991,200 0 c,i


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 0 a


2) Notification of Compliance Status 8 $0 $0 $0 1 8 0 0 0.0 0.0 $0 $0 0 c


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


4) Annual Compliance Report 20 $0 $0 $0 1 20 760 15,200 1,520 760 $2,067,633 $0 760 c, l


5) Semi-annual Compliance Report 20 $0 $0 $0 2 40 0 0 0 0 $0 $0 0 c, l


6) Notification of Alternative Fuel Use 5 $0 $0 $0 1 5 976 4,880 488 244 $663,819 $0 976 c,m










129,795 12,980 6,490






Reporting Subtotal





149,265 $17,655,865 $19,537,883 1,736
$19,537,883 $0
4. Recordkeeping Requirements
















A. Familiarization with Rule Requirements Included in 3a















B. Implement Activities NA















C. Develop Record System NA











e


D. Record Information
















1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 0 0 0 0 $0 $0 0 c


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


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


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


5) Records of All Annual Compliance Reports Submitted 2 $0 $0 $0 1 2 760 1,520 152 76 $206,763 $0 0 c, l


6) Records of All Semi-Annual Compliance Reports
Submitted
2 $0 $0 $0 2 4 0 0 0 0 $0 $0 0 c, l


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


8) Records of Annual Tune-up 0.25 $0 $0 $0 1 0.25 6,439 1,610 161 80 $218,983 $0 0 c


E. Personnel Training 40 $0 $0 $0 1 40 380 15,200 1,520 760 $2,067,633 $0 0 n


F. Time for Audits NA























18,330 1,833 916






Recordkeeping Subtotal






21,079 $2,493,380 $0












148,125 14,813 7,406






Totals






170,344 $20,149,244 $19,537,883 1,736





















Assumptions
















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 10 hours.
















b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 87.4% of facilities are in the industrial sector while the remaining 12.6% of facilities are in the commercial sector.
c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting semi-annual reports and conducting the required recordkeeping.




d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.


e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.
















f Only applies to large solid fuel boilers, because solid fuel boilers may fire a mix of non-homogeneous fuels. Assumed zero respondents for liquid and gas units.






g Existing large gas 2 units are expected to determine compliance through stack testing.
















h Gas units are exempt from PM CPMS and opacity monitoring.
















i Number based on units which reported firing fuels other than natural or refinery gas.
















j The units firing other process gases other than natural gas, refinery gases or other on-spec gas 1 fuels have limits for PM, HCl, Hg, and CO and are subject to testing and monitoring requirements for each pollutant.


k The recordkeeping and reporting requirements for natural gas fired units is to conduct an annual tune-up and document that the tune-up was completed. The documentation does not need to be submitted as a report unless requested by the Administrator. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.


l Only facilities with process gas (gas 2 units) subject to numerical emission limits are expected to be required to submit semi-annual compliance reports. Natural gas and refinery gas units are required to submit reports annually.
















m Number based on 15.8% of the large gas 1 units using liquid instead of gas at some point.
















n For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.
















o Estimated number of units expected to require each type of parameter monitoring are consistent with the estimated number of units expected to install controls, as outlined in the memorandum: "Revised (November 2011) Methodology for Estimating Cost and Emissions Impacts for Industrial, Commercial, Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants – Major Source."
p Includes enhanced recordkeeping provisions for demonstration of compliance with the alternative definition of "startup" (paragraph (2) of the definition) that document when useful thermal energy is provided, what fuels are used during startup, parametric monitoring data to verify relevant controls are engaged, and the time when PM controls are engaged. It is assumed that no one is using the compliance alternatives at this time.



Sheet 16: NLG

Table 10.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)

New Large Gas Fuel Units

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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year [(B+C+D)xExG] (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA














2. Surveys and Studies NA














3. Reporting Requirements















A. Read and Understand Rule Requirements 40 $0 $0 $0 1 40 33 1,333 133 67 $181,371 $0 0 a

B. Required Activities















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

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

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

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

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

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

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

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

11. 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 0 a,e

12. Initial Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 1 5 0 0 0 0 $0 $0 0 a,f

13. Monthly Fuel Analysis for Mercury and HCL Content 5 $0 $400 $0 12 60 0 0 0 0 $0 $0 0 a,f

14. Continuous Parameter Monitoring












j

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

Opacity















a) initial 10 $0 $0 $43,100 1 10 0 0 0 0 $0 $0 0 a

b) annual 10 $0 $0 $14,700 1 10 0 0 0 0 $0 $0 0 a

PM (only sources greater than 250 mmBtu/hr)















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

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

O2















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

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

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
















a) initial 10 $0 $0 $24,300 1 10 0 0 0 0 $0 $0 0 a

b) annual 10 $0 $0 $5,600 1 10 0 0 0 0 $0 $0 0 a

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
















a) initial 10 $0 $0 $25,500 1 10 0 0 0 0 $0 $0 0 a

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

15. Annual Tune-up 12 $0 $2,875 $0 1 12 261 3,132 313 157 $426,041 $750,375 0 c

16. Mercury Fuel Spec Analysis 5 $0 $200 $0 12 60 0 0 0 0 $0 $0 0 h

C. Create Information NA














D. Gather Information NA














E. Report Preparation















1) Initial Notification that Source is Subject 2 $0 $0 $0 1 2 33 67 6.7 3.3 $9,069 $0 33 a

2) Notification of Compliance Status 8 $0 $0 $0 1 8 33 267 26.7 13.3 $36,274 $0 33 a

3) Annual Compliance Report 20 $0 $0 $0 1 20 33 667 67 33 $90,686 $0 33 a, e

4) Semi-annual Compliance Report 20 $0 $0 $0 2 40 0 0 0 0 $0 $0 0 a, e $750,375 $0
5) Notification of Alternative Fuel Use 5 $0 $0 $0 1 5 0 0 0 0 $0 $0 0 i









5,465 547 273





Reporting Subtotal






6,285 $743,441 $750,375 100


4. Recordkeeping Requirements















A. Read and Understand Rule Requirements Included in 3a














B. Implement Activities NA














C. Develop Record System NA











d

D. Record Information















1) Records of Operating Parameter Values 20 $0 $0 $0 1 20 0 0 0 0 $0 $0 0 a

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

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

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

5) Records of All Annual Compliance Reports Submitted 2 $0 $0 $0 2 4 33 133 13.3 6.7 $18,137 $0 0 a, e

6) Records of All Semi-Annual Compliance Reports
Submitted
2 $0 $0 $0 2 4 0 0 0 0 $0 $0 0 a, e

7) Records of Monthly Fuel Use 0.5 $0 $0 $0 12 6 261 1,566 157 78.3 $213,021 $0 0 a

8) Records of Annual Tune-up 0.25 $0 $0 $0 1 0.25 261 65 6.53 3.26 $8,876 $0 261 c

E. Personnel Training 40 $0 $0 $0 1 40 33 1,333 133 67 $181,371 $0 0 g

F. Time for Audits NA






















3,098 310 155





Recordkeeping Subtotal






3,563 $421,405 $0











8,563 856 428





Totals






9,848 $1,164,846 $750,375 100



















Assumptions















a In order to calculate a per year estimate of the number of boilers and facilities required to meet these rule requirements, the number of projected boilers and facilities is each divided by 3.



b A one-time requirement.



c Energy Audits are a requirement for existing units only.


d Assumes facility must already maintain records on boiler insurance and/or maintenance schedule as part of their operations. No new record system would be required.


e Only facilities with process gas (gas 2 units) subject to numerical emission limits are expected to be required to submit semi-annual compliance reports and conduct testing and monitoring (There will not be any new process gas units). Natural gas and refinery gas units are required to submit reports annually and conduct a tune-up. While the rule provides flexibility to conduct less frequent tune-ups for large units that have a continuous oxygen trim system that maintains an optimum air to fuel ratio, the number of units with this configuration is unknown and the ICR conservatively assumes all large units will conduct tune-ups annually.

f Process gas units are expected to demonstrate compliance with a stack test instead of a fuel analysis. However no new process gas units were estimated.















g For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes all new respondents will conduct training.















h Assume all units will fire natural gas, so fuel spec analysis not necessary.















i Assumed no units would fire an alternative fuel.















j Estimated number of units expected to require each type of parameter monitoring are consistent with the estimated number of units expected to install controls, as outlined in the memorandum: "Revised (November 2011) Methodology for Estimating Cost and Emissions Impacts for Industrial, Commercial, Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants – Major Source."


Sheet 17: ESG

Table 11.B.: Annual Respondent Burden and Cost – NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal)


Existing Small and Limited Use Gas Fuel Units


Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Emission Test Contractor Hours Per Occurrence (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up 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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA
















2. Surveys and Studies NA
















3. Reporting Requirements

















A. Familiarization with Rule Requirements 5
$0 $0 $0 1 5 1,150 5,750 575 288 $782,164 $0 0 a


B. Required Activities

















1. Conduct Energy Audit

















a) Commerical 20
$854 $0 $0 1 20 0 0 0.00 0.00 $0 $0 0 b,c,d


b) Industrial 20
$18,292 $0 $0 1 20 0 0 0.00 0.00 $0 $0 0 b,c,d


2. Biennial Tune-Up 12
$0 $1,580 $0 0.5 6 9,789 58,734 5,873 2,937 $7,989,498 $15,466,620 0 c,f,i


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 0 a


2) Notification of Compliance Status 8
$0 $0 $0 1 8 0 0 0.00 0.00 $0 $0 0 c


3) Biennial Compliance Report 5
$0 $0 $0 0.5 2.5 1,150 2,875 288 144 $391,082 $0 575 c,f


4) Initial Report on results of Energy Audit 5
$0 $0 $0 1 5 0 0 0.00 0.00 $0 $0 0 c











67,359 6,736 3,368






Reporting Subtotal







77,463 $9,162,744 $15,466,620 575
$15,466,620 0
4. Recordkeeping Requirements

















A. Familiarization with Rule Requirements Included in 3a
















B. Implement Activities NA
















C. Develop Record System NA












e


D. Record Information

















1) Records of All Notifications and Compliance Reports Submitted 2 0 $0 $0 $0 0.5 1 1,150 1,150 115.00 58 $156,433 $0 0 c


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


3) Biennial Tune-Up Records 0.5
$0 $0 $0 0.5 0.25 9,789 2,447 245 122 $332,896 $0 0 c,f


E. Personnel Training 40
$0 $0 $0 1 40 575 23,000 2,300 1,150 $3,128,656 $0 0 h


F. Time for Audits NA

























26,597 2,660 1,330






Recordkeeping Subtotal







30,587 $3,617,984 $0 0
$0










93,956 9,396 4,698






Totals







108,050 $12,780,728 $15,466,620 575






















Assumptions

















a The burden on existing sources to refamiliarize themselves with the rule requirements is assumed at 5 hours for small units.


b Cost includes taking an inventory of facility equipment including age, operating schedules, square feet of the facility and other details necessary for preparing for the audit pre-screening, attending the energy audit, and reviewing audit report from the audit professional. Based on the distribution of facilities with affected boilers or process heaters, 88% of facilities are in the industrial sector while the remaining 12% of facilities are in the commercial sector.




c It is assumed that the affected existing units have conducted an audit, developed an initial site-specific testing and monitoring plan, and submitted initial notifications following the compliance date of January 31, 2016. It is assumed that all existing units are submitting reports and conducting the required recordkeeping. Annualized cost of $2228 for a tune-up is calculated considering a biennual schedule.




d Cost per occurrence for energy audit professionals including an phone screening to discuss the facility prior to a visit, a 2 to 4 hour site visit, and an additional 2-4 hours to prepare a follow-up report on recommendations and findings. These site visits are assumed to be conducted by certified energy professionals.


e Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.

















f Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.

















g Small units are not required to maintain records on startup, shutdown and malfunction.

















h For on-going training activities to keep personnel updated in order to implement compliance activities. Assumes half of respondents will conduct training each year.

















i Assumes a biennial tune-up is conducted on half of all units each year. Some very small boilers (<5mmBtu/hr) or limited use boilers which operate less than 100 hours annually qualify for tune-ups every five years, however they would still incur an initial tune-up. For the time period of this ICR, there will not be a difference in burden associated with biennial vs 5-year tune-ups for existing units.



Sheet 18: NSG

Table 12.B.: Annual Respondent Burden and Cost -- NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD) (Renewal) – Year 2

New Small Gas Fuel Units

Burden Item (A) Respondent Hours per Occurrence (Technical hours) (B) Emission Test Contractor Hours Per Occurrence (B) Certified Energy Audit Cost per Occurrence (C) Annual Tune-Up 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 @ $99.16 (F X G) (I) Clerical Hours per Year @ $50.88 (H X 0.1) (J) Management Hours per Year @ $127.43 (H X .05) (J) Emission Testing Contractor Hours per Year @ $80 (BxDxF) (K) Total Labor Costs Per Year (L) Total Non-Labor Capital Costs Per Year ((B+C+D)xExG) (M) Total Number of Responses per Year (E X G) Footnotes Annualized Capital/start-up O&M Total Capital (Monitor Purchase)
1. Applications NA
















2. Surveys and Studies NA
















3. Reporting Requirements

















A. Read and Understand Rule Requirements 40
$0 $0 $0 1 40 41 1,640 164 82 0 $223,087 $0 0 a

B. Required Activities

















1. Biennial Tune-Up 12
$0 $2,228 $0 0.5 6 326 1,956 195.6 97.8
$266,072 $726,328 0 a,e,f

C. Create Information NA
















D. Gather Information NA
















E. Report Preparation

















1) Initial Notification that Source is Subject 2
$0 $0 $0 1 2 41 82 8.2 4.1 0 $11,154 $0 41 a

2) Notification of Compliance Status 8
$0 $0 $0 1 8 41 328 32.8 16.4 0 $44,617 $0 41 a

3) Biennial Compliance Report 5
$0 $0 $0 0.5 2.5 41 103 10.3 5.1 0 $13,943 $0 21 d,e










4,109 411 205






Reporting Subtotal







4,725 0 558,873 726,328 103
$726,328 0
4. Recordkeeping Requirements

















A. Read and Understand Rule Requirements Included in 3a
















B. Implement Activities NA
















C. Develop Record System NA













b

D. Record Information

















1) Records of All Notifications and Compliance Reports Submitted 2 0 $0 $0 $0 0.5 1 41 41 4.1 2.1 0 $5,577 $0 0 a

2) Biennial Tune-Up Records 0.5
$0 $0 $0 0.5 0.25 326 82 8.2 4.1 0 $11,086 $0 0 a,e,f

E. Personnel Training 40
$0 $0 $0 1 40 41 1,640 164 82
$223,087 $0 0 c

F. Time for Audits NA

























1,763 176 88






Recordkeeping Subtotal







2,027 0 $239,750 $0 0
$0









5,871 587 294






Totals







6,752 0 $798,623 $726,328 103





















Assumptions

















a In order to calculate a per year estimate of the number of boilers and facilities required to meet these rule requirements, the number of projected boilers and facilities is each divided by 3.



b Assumes facility must already maintain records on boiler insurance and/or maintenance schedule. No new record system would be required.



c For on-going training activities to keep personnel updated in order to implement compliance activities.

















d Since a tune-up is required biennially, every two years, the compliance reports for small units are also due every two years. Records of the tune-ups will be submitted to the Administrator upon request.

















e Assumes for boilers which performed a tune-up in year 1, the biennial tune-up would also occur in year 3.



f Very small boilers qualify for tune-ups every five years, however they would still incur an initial tune-up when they come online. For those boilers in year 1 which were performing their initial five-year tune-up, a tune-up in year 3 is not necessary. Four boilers would qualify for 5-year tune-ups and are thus not applicable to tune-ups in year 3.




Sheet 19: Capital vs. O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)
Boiler Type
(B)
Number of Respondents (facilities)
(C)
Annual Capital/Startup Cost
(D)
Annual O&M
(E)
Annual O&M and Annualized Capital Costs

Existing Large Solid Units 282 $0 $32,097,783 $32,097,783
New Large Solid Units 5 $111,215 $234,375 $345,590
Existing Small and Limited Use Solid Units 6 $0 $101,003 $101,003
New Small Solid Units 0 $0 $2,228 $2,228
Existing Large Liquid Units 21 $0 $786,707 $786,707
New Large Liquid Units 0 $0 $0 $0
Existing Small and Limited Use Liquid Units 3 $0 $55,700 $55,700
New Small Liquid Units 0 $0 $0 $0
Existing Large Gaseous Units 760 $0 $19,537,883 $19,537,883
New Large Gaseous Units 33 $0 $750,375 $750,375
Existing Small and Limited Use Gaseous Units 1,150 $0 $15,466,620 $15,466,620
New Small Gaseous Units 41 $0 $726,328 $726,328
Total 2,302 $111,215 $69,759,002 $69,870,217
Total (Rounded) 2,300 $111,000 $69,800,000 $69,900,000
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