Burden Calculations Table

1967t09.xlsx

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

Burden Calculations Table

OMB: 2060-0540

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Overview

Summary
Table 1
Table 2
Responses
Respondents
Capital O&M


Sheet 1: Summary

ICR Summary Information
Hours per Response 15
Number of Respondents 280
Total Estimated Burden Hours 8,490
Total Estimated Costs $1,020,000
Annualized Capital O&M $37,100
Total Annual Responses 585
Form Number 5900-600

Sheet 2: Table 1

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





1. Applications N/A







Labor Rates


2. Survey and Studies N/A







Management $157.61


3. Reporting Requirements








Technical $123.94


A. Familiarization with the regulatory requirements c 4 1 4 280 1120 56 112 $154,642.82
Clerical $62.52


B. Required Activities











237 gas-fired turbines
Initial CMS performance evaluation d 12 1 12 8 96 4.8 9.6 $13,255



7 landfill gas/digester turbines
Performance test e 12 1 12 8 96 4.8 9.6 $13,255



20 oil-fired turbines
C. Create Information See 3B












D. Gather Existing Information See 3B












E. Write Report













Initial notification f 2 1 2 8 16 0.8 1.6 $2,209.18





Notification of construction/reconstruction g 2 1 2 8 16 0.8 1.6 $2,209





Notification of actual startup g 2 1 2 8 16 0.8 1.6 $2,209





Notification of performance test g 2 1 2 8 16 0.8 1.6 $2,209





Notification of CMS performance evaluation g 2 1 2 8 16 0.8 1.6 $2,209





Notification of compliance status g 2 1 2 8 16 0.8 1.6 $2,209





Annual compliance report h 8 1 8 7 56 2.8 5.6 $7,732.14





Semiannual compliance reports i 8 2 16 265 4240 212 424 $585,433.55





Subtotal for Reporting Requirements



6,560 $787,573.81





4. Recordkeeping Requirements













A. Familiarization with the regulatory requirements See 3A












B. Plan Activities See 3B












C. Implement Activities See 3B












D. Time to Enter Information













Records of operating parameters j 0.5 12 6 280 1680 84 168 $231,964.24





F. Train Personnel N/A












G. Audits N/A












Subtotal for Recordkeeping Requirements



1,932 $231,964





TOTAN ANNUAL BURDEN AND COST (rounded) k



8,490 $1,020,000
15 hr per resp


Capital and O&M Cost (see Section 6(b)(iii)): k






$37,100





TOTAL COST: k






$1,060,000



































Assumptions:













a. We estimate 8 new sources, comprising 8 gas-fired, and 0 landfill/digester gas-fired or oil-fired stationary combustion turbines, will become subject to the rule over the three-year period of this ICR. We also estimate 264 existing sources are subject, comprising 237 facilities with gas-fired turbines, 7 facilities with landfill/digester gas-fired turbines, and 20 facilities with oil-fired stationary combustion turbines. The March 9, 2022 final rule lifted the stay of effectivness for existing gas-fired sources, which were required to comply with the emission standards on or before March 9, 2022.


b. This ICR uses the following labor rates: Managerial $157.61 ($75.05+ 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.


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













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













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













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













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













h. We assume eight hours are required to prepare annual compliance reports. This activity only applies to existing sources in the landfill/digester gas-fired turbine subcategory. (7 existing sources)


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













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













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














Sheet 3: Table 2

Activity (A) EPA Hours per occurrence (B) Number of occurrences per Year (C) EPA Hours per Year (AxB) (D) Plants per Year a (E) Technical Hours per Year (CxD) (F) Managerial Hours per Year (Ex0.05) (G) Clerical Hours per Year (Ex0.10) (H) Total cost per year, $ b


Initial notification c 2 1 2 8 16 0.8 1.6 $939.71
Labor Rates
Notification of construction/reconstruction d 2 1 2 8 16 0.8 1.6 $940
Management $70.56
Notification of actual startup d 2 1 2 8 16 0.8 1.6 $940
Technical $52.37
Notification of performance test d 2 1 2 8 16 0.8 1.6 $940
Clerical $28.34
Notification of CMS performance evaluation d 2 1 2 8 16 0.8 1.6 $940


Notification of compliance status e 18 1 18 8 144 7.2 14.4 $8,457


Annual compliance report f 8 1 8 7 56 2.8 5.6 $3,288.99


Semiannual compliance reports g 8 2 16 265 4240 212 424 $249,023.68


TOTAL ANNUAL BURDEN AND COST (rounded) h



5,200 $265,000














Assumptions:










a. We estimate 8 new sources, comprising 8 gas-fired, and 0 landfill/digester gas-fired or oil-fired stationary combustion turbines, will become subject to the rule over the three-year period of this ICR. We also estimate 264 existing sources are subject, comprising 237 facilities with gas-fired turbines, 7 facilities with landfill/digester gas-fired turbines, and 20 facilities with oil-fired stationary combustion turbines. The March 9, 2022 final rule lifted the stay of effectivness for existing gas-fired sources, which were required to comply with the emission standards on or before March 9, 2022.
b. This cost is based on the average hourly labor rate as follows: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.71 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2022 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c. We assume two hours are required to review each initial notification. This activity applies to new sources in all subcategories (i.e., 8 new sources comprising 8 gas-fired, 0 oil-fired, and 0 landfill/digester gas-fired turbines).
d. We assume two hours are required to review each notification. This activity only applies to new sources in the oil-fired and gas-fired turbine subcategories.










e. We assume that performance test and CMS performance evaluation reports will be submitted for review concurrently with the notification of compliance status, and that a total of 18 hours will be required to review each compliance notification (2 hours), performance test report (8 hours), and performance evaluation report (8 hours).
f. We assume eight hours are required to review each annual compliance report. This activity only applies to existing sources in the landfill/digester gas-fired turbine subcategory (7 existing sources).
g. We assume eight hours are required to review each semiannual compliance report. This activity only applies to existing sources in the oil-fired and gas-fired turbine subcategories.
h. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.











Sheet 4: Responses

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
Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory



Initial notification 0 1 0 0
Annual compliance reporta 7 1 0 7
Subtotal


7
Oil-Fired and Gas-Fired Stationary Combustion Turbine Subcategories



Initial notification 8 1 0 8
Notification of construction/reconstruction 8 1 0 8
Notification of actual startup 8 1 0 8
Notification of performance test 8 1 0 8
Notification of CMS performance evaluation 8 1 0 8
Notification of compliance status 8 1 0 8
Semiannual compliance reportb 265 2 0 530
Subtotal


578
TOTAL


585
a This activity applies to new and existing landfill/digester gas-fired sources.



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




Sheet 5: Respondents


Number of Respondents







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





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




1 8 237 0 0 245
2 8 245 0 0 253
3 8 253 0 0 261
Average 8 245 0 0 253
Landfill/Digester Gas-Fired Stationary Combustion Turbine Subcategory




1 0 7 0 0 7
2 0 7 0 0 7
3 0 7 0 0 7
Average 0 7 0 0 7
Oil-Fired Stationary Combustion Turbine Subcategories




1 0 20 0 0 20
2 0 20 0 0 20
3 0 20 0 0 20
Average 0 20 0 0 20
TOTAL 8 272 0 0 280
a New respondents include sources with affected facilities constructed or reconstructed after January 14, 2003.

Sheet 6: Capital O&M




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










(A) (B) (C) (D) (E) (F) (G)

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







(E X F)










Catalyst inlet temperature $4,642 8 $37,100 0 265 $0
$37,100









a We estimate a total capital startup cost of $4,642 per respondent, which comprises a purchase cost of $500 and an installation cost of $4,142. The installation cost assumes 30 technical, 1.5 managerial, and 3 clerical hours at a labor rate of $123.94, $157.61, and $62.52, respectively. As described previously, these rates are based on figures from the United States Department of Labor and have been increased by 110 percent to account for private industry benefit packages.
b At present, only oil-fired and gas-fired subcategories are required to install, operate, and maintain continuous monitoring devices.







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







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