Burden Calculation Tables

2773t01.xlsx

Greenhouse Gas Reporting Program: Revisions and Confidentiality Determinations for Data Elements for the Greenhouse Gas Reporting Rule; Supplemental Notice of Proposed Rulemaking

Burden Calculation Tables

OMB: 2060-0748

Document [xlsx]
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Overview

Table of Contents
Cost Summary
2.1 Updates to GWPs
Subpart V (Applicability)
Subpart W (Applicability)
Subpart DD (Applicability)
Subpart HH (Applicability)
Subpart II (Applicability)
Subpart OO (Applicability)
Subpart TT (Applicability)
2.2 New Subparts
B (New Subpart)
WW (New subpart)
XX (New subpart)
YY (New subpart)
ZZ (New Subpart)
2.3 Other Applicability
Subpart P (Applicability)
Subpart Y (Applicability)
2.4 Monitoring and Calculations
Subpart AA (Calculations)
Subpart HH (Calculations)
2.5 Recordkeeping and Reporting
Reporting Cost Summary
A (Data Elements)
C (Data Elements)
F (Data Elements)
G (Data Elements)
N (Data Elements)
P (Data Elements)
Y (Data Elements)
AA (Data Elements)
HH (Data Elements)
OO (Data Elements)
PP (Data Elements)
QQ (Data Elements)


Sheet 1: Table of Contents

Table of Contents for this Workbook Content Notes


Cost Summary Summary of Initial, Subsequent Year, and Capital/O&M Costs for All Changes, by Subpart
2.1 Updates to GWPs Links to spreadsheets containing burden for updates to GWPs, by Subpart, as discussed in Section 2.1 of the impacts assessment
2.2 New Subparts Links to spreadsheets containing burden for new subparts, by Subpart, as discussed in Section 2.2 of the impacts assessment
2.3 Other Applicability Links to spreadsheets containing burden for subparts with other applicability changes, by Subpart, as discussed in Section 2.3 of the impacts assessment
2.4 Monitoring and Calculations Links to spreadsheets containing burden for subparts with changes to monitoring and calculations, by Subpart, as discussed in Section 2.4 of the impacts assessment
2.5 Recordkeeping and Reporting Links to spreadsheets containing burden for subparts with changes to recordkeeping or reporting requirements, including total and by Subpart, as discussed in Section 2.5 of the impacts assessment

Sheet 2: Cost Summary

Table 4-1. Incremental Implementation Costs by Subpart (2021$)







Subpart Number of Affected Facilities Labor Costs Capital and O&M
Total Initial Year Costs (Labor + Non Labor) Total Subsequent Year Costs (Labor + Non-Labor)
Initial Year Subsequent Years



A – General Provisions 7,840 $64,133 $64,133 $-
$64,133 $64,133
B – Energy Consumption  7,840 $8,771,243 $4,700,877 $489,050
$9,260,294 $5,189,927
C – General Stationary Fuel Combustion Sources 346 $9,906 $9,906

$9,906 $9,906
F – Aluminum Production  7 $57 $57

$57 $57
G – Ammonia Manufacturing  29 $119 $119

$119 $119
I – Electronics Manufacturing  46 $- $- $-
$- $-
N – Glass Production  100 $1,227 $1,227

$1,227 $1,227
P – Hydrogen Production   116 $7,179 $7,179 $4,481
$11,660 $11,660
V – Nitric Acid Production 1 $(2,680) $(2,680) $(11,085)
$(13,765) $(13,765)
W – Petroleum and Natural Gas Systems   188 $2,620,418 $2,620,418 $2,717,864
$5,338,282 $5,338,282
Y – Petroleum Refineries   6 $(6,881) $(6,881) $(3,930)
$(10,810) $(10,810)
AA – Pulp and Paper Manufacturing  1 $104 $104

$104 $104
DD – Electrical Transmission  2 $6,200 $6,200 $3,119
$9,319 $9,319
HH – Municipal Solid Waste Landfills  1,126 $130,188 $127,330 $374
$130,563 $127,704
II – Industrial Wastewater Treatment 2 $5,288 $4,713 $3,077
$8,364 $7,789
OO – Suppliers of Industrial Greenhouse Gases 104 $6,680 $6,680 $62
$6,742 $6,742
PP – Suppliers of Carbon Dioxide 11 $135 $135

$135 $135
QQ – Importers and Exporters of Fluorinated Greenhouse Gases Contained in Pre-Charged Equipment or Closed-Cell Foams  33 $384 $384

$384 $384
RR – Geologic Sequestration of Carbon Dioxide 9 $- $- $-
$- $-
TT – Industrial Waste Landfills 1 $4,853 $3,934 $62
$4,915 $3,996
UU – Injection of Carbon Dioxide







VV – Geologic Sequestration of Carbon Dioxide with Enhanced Oil Recovery Using ISO 27916 2 $- $- $-
$- $-
WW – Coke Calciners  15 $37,847 $34,525 $19,649
$57,497 $54,175
XX – Calcium Carbide Production  1 $2,849 $2,627 $62
$2,911 $2,690
YY – Caprolactam,  Glyoxyl, and Glyoxylic Acid Production  6 $12,285 $11,089 $374
$12,660 $11,464
ZZ – Ceramics Production  34 $77,083 $72,062 $2,121
$79,203 $74,183
Total 7,990 $11,748,619 $7,664,140 $3,225,282
$14,973,900 $10,889,422










Sheet 3: 2.1 Updates to GWPs

Burden for Subparts in Section 2.1 of Impacts Assessment














Subpart V (Applicability)


Total Costs Section 2.1


Subpart W (Applicability)




Initial Year Subsequent Years
Subpart DD (Applicability)



Total Labor costs: $2,671,132 $2,666,780
Subpart HH (Applicability)



Total Non-Labor costs: $2,713,473 $2,713,473
Subpart II (Applicability)



Total Section 2.1: $5,384,605 $5,380,253
Subpart OO (Applicability)






Subpart TT (Applicability)














Back to Table of Contents







Sheet 4: Subpart V (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)











Applicability is affected by changes to the globabl warming potential values.










Assumes the cost impacts would be for a facility using the annual performance test option (without abatement); if they need abatement, they would be less likely to be able to cease reporting.
Table V-1. Labor Costs – Subpart V (hours from Appendix H to the 2019 ICR)










Hours for first year are from Table 4-26 of the 2009 Final Impacts Analsysis
Activity Labor Rates (per hour) Total Labor Cost per Year per Facility

Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
Assumptions:
$114.80 $91.33 $73.83 $34.09


Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year

Planning 1 1 8 2 16 19.5 0 1 $2,027 $1,771
*planning is related to the required annual performance test: preparing for equipment shutdown prior to testing, contacting the test company, setting up the testing, attending the performance test
QA/QC 0 0 0 0 0 0 0 0 $0 $0
*QA/QC activities include review of calculations, testing, and reports; QA/QC hours are not expected because the annual performance test (and related QA/QC) is performed by a contractor; as such both costs are represented as O&M costs
Recordkeeping 0 0 0 0.5 0 2 0 0.5 $0 $210
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations) 0 0 38 0.3 50 3.3 0 0.2 $7,162 $278
*Sampling and analysis costs for the annual performance test option (without abatement) include time to calculate the N2O emission factor (according to Equation V-1) using the information gathered during the performance test and to calculate total N2O emissions from the nitric acid trains. Confirmed affected facility has no abatement.
Reporting 0 0 12 1 12 4 12 1 $2,391 $421
*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) (for new facilities, set-up of account and first-time use of e-GGRT system.
Total 1 1 58 3.8 78 28.8 12 2.7 $11,579 $2,680














Total labor, 1 facility: 1 1 58 3.8 78 28.8 12 2.7 $11,579 $2,680














Table V-2. Capital and O&M Costs – Subpart V – All facilities (from Appendix H to the 2019 ICR)











Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)





Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years





Equipment (selection, purchase, installation) $-
$- $- $- $-





Performance testing $-
$- $11,022 $- $11,022 *Costs of performance testing, assumes 1.63 nitric acid trains per facility.




Recordkeeping $-
$- $62 $- $62 *covers cost to store records, such as a flash drive, paper file or cloud storage




Travel $-
$- $- $- $-





Sampling and Analysis Costs $-
$- $- $- $-





Total $- $- $- $11,085 $- $11,085


















Total Capital and O&M, 1 facility:



$0 $11,085


















Total Costs of Proposed Revisions, 1 facility:



$11,579 $13,765





Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs.
























Labor Costs of Proposed Revisions
O&M Cost Per Year






# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years






-1 ($2,680) ($2,680)
($11,085) ($11,085)






Calculation Methodology:





Assumes one facility may potentially meet the offramp provisions of 40 CFR 98.2(b) and stop reporting




Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility


Assumed the initial year savings are the same as the subsequent year savings because the facility is going to off-ramp and does not have any initial year costs.

















Back to Table of Contents












Sheet 5: Subpart W (Applicability)







Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)

























Applicability is affected by changes to the globabl warming potential values.















































This is the list of new reporters per segment from the increase in methane GWP provided by Jennifer Bohman on November 10, 2022.*
Baseline W Monitoring Burden and Costs Per Reporter
Calculated from From ICR Appendix E-4: Burden and Cost for Petroleum and Natural Gas Systems (Subpart W) June 2019
Calculated averages per reporter, scaled to 2021$

Incremental Labor Changes for New Reporters from W Data Elements After June 2022 Proposed W Amendments
Incremental Labor and O&M Cost Changes for Monitoring After June 2022 Proposed W Amendments (2021$)
Total Costs (2021$) for All New W Reporters



Segment Number Segment 2020 Facility Count Change in Facility Count

Burden/ Reporter (hrs) Labor Cost/Reporter (2021$) O&M Cost/Reporter (2021$) Total Cost/Reporter (2021$)
Burden/ Reporter (hrs) Labor Cost/Reporter (2021$)
Burden/ Reporter (hrs) Labor $/ Reporter O&M $/ Reporter Total $/ Reporter
Burden (hrs) Labor O&M Total



1 Gathering and Boosting 361 0

98 $10,848 $229 $11,077
6.84 $739
0
$- $-
- $- $- $-
Per Reporter

2 LNG Import/Export 11 0

67 $7,363 $24,421 $31,784
3.05 $329
0
$- $-
- $- $- $-
Labor O&M
3 LNG Storage 5 1

64 $7,001 $6,897 $13,899
1.55 $168
5.75 $645.65 $- $645.65
71.30 $7,815 $6,897 $14,712
$7,815 $6,897
4 Natural Gas Distribution 164 0

66 $7,231 $8,003 $15,234
0.69 $74
0
$- $-
- $- $- $-



5 Natural Gas Processing 462 0

69 $7,617 $26,686 $34,304
3.68 $397
10.18 $1,166.58 $- $1,166.58
- $- $- $-



6 Natural Gas Transmission Compression 644 130

70 $7,683 $18,401 $26,083
1.44 $155
5.75 $645.65 $- $645.65
10,034.38 $1,102,879 $2,392,078 $3,494,958
$8,484 $18,401
7 Natural Gas Transmission Pipelines 49 1

63 $6,939 $62 $7,001
0.86 $93
11.5 $1,291.30 $- $1,291.30
75.36 $8,323 $62 $8,385
$8,323 $62
8 Offshore Production 134 7

32 $3,556 $62 $3,618
0.75 $81
5.75 $645.65 $- $645.65
269.48 $29,974 $437 $30,410
$4,282 $62
9 Onshore Production 468 40

300 $33,263 $206 $33,469
11.21 $1,210
3.18 $505.95 $- $505.95
12,575.70 $1,399,157 $8,239 $1,407,395
$34,979 $206
10 Underground Natural Gas Storage 52 9

66 $7,217 $34,461 $41,678
1.55 $168
5.75 $645.65 $- $645.65
659.72 $72,271 $310,150 $382,421
$8,030 $34,461




























Total 2,350 188






Avg $/reporter $499




Totals 23,686 $2,620,418 $2,717,864 $5,338,282



























Labor O&M Total






Note to EPA: For columns G, H, I, O, P, and Q, see the calculations in hidden input sheets at back of this workbook.















Weighted Avg for Individual Reporter: $13,938 $14,457 $28,395.12














































QA: $13,938 $14,457
Straight Average: $11,985 $10,015




























Back to Table of Contents



















































































































































$738.63 #REF!
























$328.97 #REF!
























$813.24 #REF!
























$74.48 #REF!
























$1,563.83 #REF!
























$800.82 #REF!
























$1,384.40 #REF!
























$726.34 #REF!
























$1,716.31 #REF!
























$813.24 #REF!




















































#REF!










Sheet 6: Subpart DD (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)















Applicability is affected by changes to the global warming potential values.















Table DD-1. Labor Costs – Subpart DD (from Appendix H to the 2019 ICR)















Activity Labor Rates (per hour) Total Labor Cost per Year per Facility





Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
Assumptions:



$114.80 $91.33 $73.83 $34.09






Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year





Planning 1 1 1 1 2 2 0 0 $354 $354
*reading the rule to become familiar with any changes to the rule requirements, asking questions about applicability, reviewing any overlap in existing reporting programs



QA/QC 0 0 0 0 2 2 0 0 $148 $148
*QA/QC activities include review of calculations, testing, and reports;



Recordkeeping 0 0 0.5 0.5 5 5 0.5 0.5 $432 $432
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method



Sampling and Analysis (Calculations) 0 0 2 2 12 12 4 4 $1,205 $1,205
*Specific labor costs related to sampling and analysis activities for Subpart DD include overseeing a contractor who weighs the gas cylinders and performing emission calculations



Reporting 0 0 1 1 10 10 1 1 $864 $864
*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) (for new facilities, set-up of account and first-time use of e-GGRT system).



Total 1 1 4.5 4.5 31 31 5.5 5.5 $3,002 $3,002






















Total labor, 1 facility: 1 1 4.5 4.5 31 31 5.5 5.5 $3,002 $3,002




















Adjusted hours from package 1: $98.16
Table DD-2a. Capital and O&M Costs – Subpart DD – All facilities (from Appendix H to the 2019 ICR)















Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)









Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years









Equipment (selection, purchase, installation)










Performance testing










Recordkeeping $-
$- $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage








Travel










Sampling and Analysis Costs
$1,497 $1,497 $1,497 *Sampling O&M costs for Subpart DD are for an independent contractor to weigh gas cylinders for facilities that have a high quantity of cylinders.








Total $-
$- $1,559 $1,559 $1,559


























Total Capital and O&M, 1 new facility:



$1,559 $1,559


























Total Costs of Proposed Revisions, 1 facility:



$4,561 $4,561









Cost of Proposed Revisions from Package 1 (per facility):



$98 $98









Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs .
































Labor Costs of Proposed Revisions
O&M Cost Per Year










# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years










2 $6,200 $6,200
$3,119 $3,119










Calculation Methodology:





Assumed two existing reporters would no longer qualify for the off-ramp and would be required to continue reporting.
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility + Cost of Proposed Revision from Package 1 (Adjusted to $2021)


Because affected facilities are existing facilities that will continue reporting (instead of new reporters), the initial year and subsequent year impacts should be the same.

















Back to Table of Contents
















Sheet 7: Subpart HH (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)


















Applicability is affected by changes to the global warming potential values.


















Table HH-1. Labor Costs – Subpart HH - Landfills - Facilities with gas collection systems (from Table HH-2a in Appendix H to the 2019 ICR)


















Activity Labor Rates (per hour) Total Labor Cost per Year per Facility








Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
Assumptions:






$114.80 $91.33 $73.83 $34.09

Assumes the 6 new facilities affected by CH4 GWP change have GCS.






Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year








Planning 2 1 1 1 21 1 2 1 $1,939 $314
*New facilities in their initial year of reporting will incur additional planning hours to familiarize themselves with the rule and hours for setup of compliance activities including sampling and QA/QC. Initial year hours are based on Appendix H of the 2019 ICR.






QA/QC 0 0 1 1 13 6 1 1 $1,085 $568
*QA/QC activities include review of calculations, testing, and reports;






Recordkeeping 0 0 1 1 13 13 1 1 $1,085 $1,085
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method






Sampling and Analysis (Calculations) 0 0 1 0 16 8 2 1 $1,341 $625
*Sampling and analysis (calculations) hours include completion of the measurements and calculations in (§98.346), including calculation of methane generation and emissions, estimating historical waste quantities, and determining annual waste compositions, and the composition, flow, and destruction of landfill gas through the gas collection system






Reporting 0 0 2 2 26 26 2 2 $2,170 $2,170
*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) (for new facilities, set-up of account and first-time use of e-GGRT system).






Total 2 1 6 5 89 54 8 6 $7,621 $4,763




























Total labor, 1 facility: 2 1 6 5 89 54 8 6 $7,621 $4,763


























Adjusted hours from package 1: $4.49
Table HH-2. Capital and O&M Costs – Subpart HH – Landfills - Facilities without gas collection systems (from Table HH-3b in Appendix H to the 2019 ICR)


















Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)












Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years












Equipment (selection, purchase, installation)













Performance testing













Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage











Travel













Sampling and Analysis Costs













Total $0
$0 $62 $62 $62
































Total Capital and O&M, 1 new facility:



$62 $62
































Total Costs of Proposed Revisions, 1 facility:



$7,683 $4,825












Cost of Proposed Revisions from Package 1 (per facility):



$4 $4












Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs .






































Labor Costs of Proposed Revisions
O&M Cost Per Year













# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years













6 $31,461 $28,603
$374 $374













Calculation Methodology:





Assumed 5 open landfills that have previously off-ramped from the GHGRP may have to resume reporting due to the changes to the GWP and Table HH-1, and one open landfill that is anticipated to become a new reporter due to the changes to the GWP and Table HH-1, that would otherwise not have to report.

Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility + Cost of Proposed Revision from Package 1 (Adjusted to $2021)


"Initial year" cost is based on one facility being new and 5 being earlier reporters that have only subsequent year costs.









































Back to Table of Contents



















Sheet 8: Subpart II (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)











Applicability is affected by changes to the global warming potential values.











Table II-1. Labor Costs – Subpart II (from Appendix H to the 2019 ICR)











Activity Labor Rates (per hour) Total Labor Cost per Year per Facility

Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
Assumptions:
$114.80 $91.33 $73.83 $34.09


Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year
Initial year hours are also from Appendix H to the 2019 ICR
Planning 2 1 0.2 0.1 2.0 1.0 0.2 0.1 $402 $201
*New facilities in their initial year of reporting will incur additional planning hours to familiarize themselves with the rule and hours for setup of compliance activities, including QA/QC
QA/QC 0 0 0.2 0.1 2.0 1.0 0.2 0.1 $173 $86
*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping 0 0 0.5 0.5 5.0 5.0 0.5 0.5 $432 $432
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations) 0 0 2.0 2.0 8.0 8.0 0 0 $773 $773
*Sampling and analysis (calculations) hours include completion of the measurements and calculations in §98.356, including calculation of any methane generation, emissions, and biogas collection and recovery amounts and gas characterization if applicable
Reporting 0 0 1.0 1.0 10.0 10.0 1.0 1.0 $864 $864
*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT).
Total 2 1 3.9 3.7 27 25 1.9 1.7 $2,644 $2,356














Total labor, 1 facility: 2 1 3.9 3.7 27 25 1.9 1.7 $2,644 $2,356














Table II-2. Capital and O&M Costs – Subpart II – All facilities (from Appendix H to the 2019 ICR)











Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)





Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years





Equipment (selection, purchase, installation)






Performance testing






Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage




Travel






Sampling and Analysis Costs $0
$0 $1,476 $1,476 $1,476 *Costs for the calibration of the flow meter at a Subpart II facility. The O&M cost of $3,550 only occurs once every three years under Subpart II. Therefore, each facility (both new facilities and existing facilities) will be expected to incur a cost of $1,183 each year over a three-year period




Total $0
$0 $1,538 $1,538 $1,538


















Total Capital and O&M, 1 new facility:



$1,538 $1,538


















Total Costs of Proposed Revisions, 1 facility:



$4,182 $3,895





Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs.
























Labor Costs of Proposed Revisions
O&M Cost Per Year






# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years






2 $5,288 $4,713
$3,077 $3,077






Calculation Methodology:





Assumed two new reporters would be expected to start reporting to the GHGRP




Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility





















Back to Table of Contents












Sheet 9: Subpart OO (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)














Applicability is affected by changes to the global warming potential values.














Table OO-1. Labor Costs – Subpart OO - F-GHG Importers (from Table OO-1b in Appendix H to the 2019 ICR)














Activity Labor Rates (per hour) Total Labor Cost per Year per Facility
Note: Package 1 includes costs for new data elements for subpart OO that do not overlap with new data elements added in this package that may need to be considered for new reporters.


Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
Assumptions:


$114.80 $91.33 $73.83 $34.09

Assumed the new reporter would be an importer (all producers are already required to report).


Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year




Planning 2.0 2.0 1.0 1.0 1 1.0 0 0 $395 $395
*New facilities in their initial year of reporting will incur similar planning hours.


QA/QC 0 0 5.0 5.0 0 0 0 0 $457 $457
*QA/QC activities include review of calculations, testing, and reports;


Recordkeeping 0 0 1.0 1.0 13 13.0 1.0 1.0 $1,085 $1,085
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method


Sampling and Analysis (Calculations) 0 0 0.9 0.9 18 18.0 1.8 1.8 $1,472 $1,472
*Importers develop an annual report that summarizes imports at the corporate level


Reporting 0 0 2.0 2.0 26 26.0 2.0 2.0 $2,170 $2,170
*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT).


Total 2 2.0 9.9 9.9 58 58 4.8 4.8 $5,579 $5,579




















Total labor, 1 facility: 2 2.0 9.9 9.9 58 58 4.8 4.8 $5,579 $5,579


















Adjusted hours from package 1: $12.67
Table OO-2. Capital and O&M Costs – Subpart OO – F-GHG Producers (from Appendix H to the 2019 ICR)














Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)








Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years








Equipment (selection, purchase, installation)









Performance testing









Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage







Travel









Sampling and Analysis Costs









Total $0
$0 $62 $62 $62
























Total Capital and O&M, 1 new facility:



$62 $62
























Total Costs of Proposed Revisions, 1 new facility:



$5,642 $5,642








Cost of Proposed Revisions from Package 1 (per facility, labor):



$13 $13








Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.






























Labor Costs of Proposed Revisions
O&M Cost Per Year









# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years









1 $5,592 $5,592
$62 $62









Calculation Methodology:





Assumed to be one new reporter who would be expected to start reporting to the GHGRP







Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility + Cost of Proposed Revision from Package 1 (Adjusted to $2021)



























Back to Table of Contents















Sheet 10: Subpart TT (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)











Applicability is affected by changes to the global warming potential values.











Table TT-1. Labor Costs – Subpart TT (from Appendix H to the 2019 ICR)











Activity Labor Rates (per hour) Total Labor Cost per Year per Facility
Assumptions:
Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)

$114.80 $91.33 $73.83 $34.09


Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year

Planning 3 1 3 1 3 1 3 1 $942 $314
*New facilities in their initial year of reporting will incur additional planning time to familiarize themselves with the rule. Initial year labor costs also include time for setup of compliance activities.
QA/QC 0 0 2 1 1 1 2 1 $325 $199
*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping 0 0 1 1 13 13 1 1 $1,085 $1,085
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations) 0 0 2 1 2 1 0 0 $330 $165
*Sampling and analysis (calculations) hours include completion of the measurements and calculations in (§98.276), including calculation of emissions, and volatile solids testing for the initial year of reporting, where applicable.
Reporting 0 0 2 2 26 26 2 2 $2,170 $2,170
*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT).
Total 3 1 10 6 45 42 8 5 $4,853 $3,934














Total labor, 1 new facility: 3 1 10 6 45 42 8 5 $4,853 $3,934














Table TT-2. Capital and O&M Costs – Subpart TT – All facilities (from Appendix H to the 2019 ICR)











Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)





Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years





Equipment (selection, purchase, installation)






Performance testing






Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage




Travel






Sampling and Analysis Costs






Total $0
$0 $62 $62 $62


















Total Capital and O&M, 1 new facility:



$62 $62


















Total Costs of Proposed Revisions, 1 new facility:



$4,915 $3,996





Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility (Table I-I) + Capital and O&M Costs (Table I-2a).
























Labor Costs of Proposed Revisions
O&M Cost Per Year






# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years






1 $4,853 $3,934
$62 $62






Calculation Methodology:





Assumed to be one new reporter who would be expected to start reporting to the GHGRP.




Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility





















Back to Table of Contents












Sheet 11: 2.2 New Subparts

Burden for Subparts in Section 2.2 of Impacts Assessment





B (New Subpart)

Total Costs Section 2.2


WW (New subpart)



Initial Year Subsequent Years
XX (New subpart)


Total Labor costs: $8,901,308 $4,821,181
YY (New subpart)


Total Non-Labor costs: $511,257 $511,257
ZZ (New Subpart)


Total Section 2.2: $9,412,565 $5,332,438







Back to Table of Contents






Sheet 12: B (New Subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)














Table B-1. Labor Costs – Subpart B – Energy Consumption














Activity Labor Rates (per hour) Total Labor Cost per Year per Facility
Assumptions:


Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)




$114.80 $91.33 $73.83 $34.09





Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year




Planning 0.5 0.1 0.4 0.1 6.0 2.0 0.8 0.2 $564 $175
Planning: sources are required to develop an Metered Energy Monitoring Plan (MEMP). Assumed time to develop the initial plan and update it annually. Note that an energy audit would be required once every 5 years.
QA/QC 0 0 0.1 0.1 2.0 0.5 0.2 0.1 $164 $49
QA/QC: Meters must comply with specified standards for electric metering. Assumed time to confirm that meters comply initially and periodically thereafter.


Recordkeeping 0 0 0.4 0.3 2.0 2.0 0.8 0.6 $211 $196
Recordkeeping: the rule has provisions for accounting for missing billing statements. Assumed 0.26 hours per month (3.2 hours per year) for recordkeeping in the initial year and 0.21 hours/month in subsequent years.
Sampling and Analysis (Calculations) 0 0 0.1 0.1 1.0 1.0 0.3 0.3 $93 $93
Sampling and calculations: The rule does not have any calculations, but if a facility is subject to multiple DE subparts, they need to estimate the fraction attributable to each subpart. Assume 1.4 hours per year for reporters to split energy consumption among subparts.
Reporting 0 0 0.1 0.1 1.0 1.0 0.1 0.1 $86 $86
Estimated Reporting Costs (represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT)):


Total 0.5 0.1 1.1 0.7 12 6.5 2.2 1.3 $1,119 $600

12 data items (b) though (m) must be reported














Assume that all reporters have to report data items for both electricity and thermal energy (e.g., natural gas).

Total labor, 1 new facility: 0.5 0.1 1.1 0.7 12 6.5 2.2 1.3 $1,119 $600

Data items (f) and (l) apply only to electricity and not thermal energy, so the total for a facility using both electricity and thermal energy is 20 data elements.














20 data elements x 0.05 hours per element = 1 hour of reporting.

Table B-2. Capital and O&M Costs – Subpart B











Assumed manager hours are 5% of technical (rounded up to a minimum of 0.1 hour) and administrative support are 10% of technical

Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)








Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years








Equipment (selection, purchase, installation)









Performance testing









Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage







Travel









Sampling and Analysis Costs









Total $0
$0 $62 $62 $62
























Total Capital and O&M, 1 new facility:



$62 $62
























Total Costs of Proposed Revisions, 1 new facility:



$1,181 $662








Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.






























Labor Costs of Proposed Revisions
O&M Cost Per Year

$9,260,294






# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years









7,840 $8,771,243 $4,700,877
$489,050 $489,050
Assume 7,582 existing reporters per year, based on 2021 RY reporters in S3 data subject to direct emitter subparts , + 5 RR reporters, + 200 new reporters from GWP changes + 53 reporters from new subparts WW, XX, YY, and ZZ.







Calculation Methodology:














Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility







7582 Direct Emitters, from file: https://easternresearchgroup.sharepoint.com/:x:/r/sites/GHGRP/Shared%20Documents/General/Rulemaking/Supplemental%20Notice/Impacts/Data%20Pulls/GHGRP_Rulemaking_DataAggregations_220824_FINAL.xlsx?d=w8e531e632f6c455591c93fbeb406e4a7&csf=1&web=1&e=bUnx5E













5 RR facilities
7,840
Back to Table of Contents










200 GWP new reporters













53 New subpart reporters


Sheet 13: WW (New subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)










Assumptions:
Table WW-1. Labor Costs – Subpart WW – Coke Calciners










For Subpart Y, EPA previously used model plants to estimate costs that assume a variety of refinery emission units and a set amount of units for each model. For these reasons, these estimates instead assume the same labor hours and O&M costs as used for subpart Q - Iron and Steel Production (carbon mass balance option with sampling, see Table Q-1a(1) in Appendix H) - because both rules rely on a carbon mass balance approach with carbon content sampling.
Activity Labor Rates (per hour) Total Labor Cost per Year per Facility (2021$)
Because these facilities are already reporting under subpart Y or C, we asumed that the initial and subsequent year costs are similar, though additional planning hours were added for the initial year.
Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support
Only 1 of the 15 facilities currently reporting under subparts Y or C are Calciner Units with/ CEMs. For this facility, we assume the same burden for reporting and recordkeeping, no burden for planning or QA/QC, and a burden of 2.0 hours for industrial technician, 0.2 hours for industrial manager, and 0.1 hours for administrative support for sampling and analysis/calculations. This would result in a total labor cost of $1,030/facility ($2021) in initial and subsequent years.
$114.80 $91.33 $73.83 $34.09
Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year

Planning 1 1 0.3 0.3 6 3 0.2 0.2 $592 $370
*Planning activities include familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC
QA/QC 1 1 0.2 0.2 2 2 0.1 0.1 $284 $284
*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping 0 0 0.5 0.5 2 2 0.5 0.5 $210 $210
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations) 0 0 1.2 1.2 12 12 0.6 0.6 $1,016 $1,016
*Sampling and analysis (calculations) hours include completion of the measurements and calculations, including entering mass of materials used in the process into equations Eq. AAA-1 to estimate CO2 emissions and use of emission factors in Eq. AAA-2 and AAA-3 to estimate N2O and CH4 emissions.
Reporting 0 0 1 1 4 4 1 1 $421 $421
*Reporting: Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), including set-up of account and first-time use of e-GGRT system).
Total 2 2 3.2 3.2 26 23 2.4 2.4 $2,523 $2,302














Total labor, 1 new facility: 2 2 3.2 3.2 26 23 2.4 2.4
















Table WW-2. Capital and O&M Costs – Subpart WW – Coke Calciners











Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)





Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years





Equipment (selection, purchase, installation)






Performance testing






Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage




Travel






Sampling and Analysis Costs $0
$0 $1,248 $1,248 $1,248 *Cost to collect and analyze samples to determine carbon content.




Total $0
$0 $1,310 $1,310 $1,310


















Total Capital and O&M, 1 new facility:



$1,310 $1,310


















Total Costs of Proposed Revisions, 1 new facility:



$3,833 $3,612





Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.
























Labor Costs of Proposed Revisions
O&M Cost Per Year






# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years






15 $37,847 $34,525
$19,649 $19,649






Calculation Methodology:











Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility





















Back to Table of Contents












Sheet 14: XX (New subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)










Assumptions:












From the draft preamble: There is currently one producer of calcium carbide in the U.S., Carbide Industries, LLC, located in Louisville, KY. Carbide Industries LLC, currently reports their process greenhouse gas (GHG) emissions under the GHG Reporting Program (GHGRP; 40 CFR part 98), subpart K – Ferroalloy Production (GHGRP Facility ID 528303). Their reporting under subpart K is voluntary as the subpart does not cover the production of calcium carbide.
Table XX-1. Labor Costs – Subpart XX – Calcium Carbide Production










Subpart K requires that analysis of the C-content of 6 input and output materials in the mass balance equation; Subpart XX requires the analysis of 4 materials and does not require calculating CH4 emissions.
Activity Labor Rates (per hour) Total Labor Cost per Year per Facility
The existing carbide facility does not currently report under subpart C or K using CEMS. Based on this information, assume the same hour and O&M burden as for subpart K, Tables K-1 and K-2 of Appendix H to the 2019 ICR, except assume that hours for sampling and analysis (calculations) for subpart XX are 2/3 of what they are for subpart K (e.g., 8 hours of engineer/technician instead of 12 hours).
Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
Assumed additional planning hours for the initial year.
$114.80 $91.33 $73.83 $34.09


Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year

Planning 1 1 0.3 0.3 6 3 0.2 0.2 $592 $370
*Planning activities include familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC
QA/QC 1 1 0.2 0.2 2 2 0.1 0.1 $284 $284
*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping 0 0 0.5 0.5 5 5 0.5 0.5 $432 $432
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations) 0 0 0.8 0.8 8 8 0.4 0.4 $677 $677
*Sampling and analysis (calculations) hours include completion of the measurements and calculations, including collecting carbon content and calculating CO2 emissions from each calcium carbide process unit
Reporting 0 0 1 1 10 10 1 1 $864 $864
*Reporting: Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), including set-up of account and first-time use of e-GGRT system).
Total 2 2 2.8 2.8 31 28 2.2 2.2 $2,849 $2,627














Total labor, 1 new facility: 2 2 2.8 2.8 31 28 2.2 2.2 $2,849 $2,627














Table XX-2a. Capital and O&M Costs – Subpart XX











Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)





Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years





Equipment (selection, purchase, installation)






Performance testing






Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage




Travel






Sampling and Analysis Costs






Total $0
$0 $62 $62 $62


















Total Capital and O&M, 1 new facility:



$62 $62


















Total Costs of Proposed Revisions, 1 new facility:



$2,911 $2,690





Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.
























Labor Costs of Proposed Revisions
O&M Cost Per Year






# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years






1 $2,849 $2,627
$62 $62






Calculation Methodology:











Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility
























Back to Table of Contents












Sheet 15: YY (New subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)










Assumptions:
Table YY-1. Labor Costs – Subpart YY - Caprolactam, Glyoxal, and Glyoxylic Acid Production











Activity Labor Rates (per hour) Total Labor Cost per Year per Facility
Assumed similar labor hours and O&M as for subpart V - Nitirc Acid Production for the Alternative Monitoring Method Option. These are both subparts dealing with sources of N2O that include the use of emission factors and accounting for abatement DRE.
Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
Assumed additional planning hours for the initial year.
$114.80 $91.33 $73.83 $34.09


Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year

Planning 1 1 0.3 0.3 6 3.3 0.2 0.2 $592 $393
*Planning activities include familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC
QA/QC 0 0 0.8 0.8 8.1 8.1 0.4 0.4 $685 $685
*QA/QC hours related to maintaining the equipment used to comply with the alternative monitoring method option, along with review of all measurements and calculations used to determine emissions
Recordkeeping 0 0 0.5 0.5 2 2 0.5 0.5 $210 $210
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations) 0 0 0.2 0.2 1.6 1.6 0.1 0.1 $140 $140
*Sampling and analysis (calculations) hours include completion of the measurements and calculations, including estimating N2O base on the use of emission factors and accounting for abatement DRE.
Reporting 0 0 1 1 4 4 1 1 $421 $421
*Reporting: Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), including set-up of account and first-time use of e-GGRT system).
Total 1 1 2.8 2.8 21.7 19 2.2 2.2 $2,048 $1,848














Total labor, 1 new facility: 1 1 2.8 2.8 21.7 19 2.2 2.2 $2,048 $1,848














Table YY-2. Capital and O&M Costs – Subpart YY - Caprolactam, Glyoxal, and Glyoxylic Acid Production











Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)





Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years





Equipment (selection, purchase, installation)






Performance testing






Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage




Travel






Sampling and Analysis Costs






Total $0
$0 $62 $62 $62


















Total Capital and O&M, 1 new facility:



$62 $62


















Total Costs of Proposed Revisions, 1 new facility:



$2,110 $1,911





Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.
























Labor Costs of Proposed Revisions
O&M Cost Per Year






# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years






6 $12,285 $11,089
$374 $374
There are approximately four to six facilities, which is the known universe of facilities that produce caprolactam, glyoxal, and glyoxylic acid in the United States.




Calculation Methodology:











Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility





















Back to Table of Contents












Sheet 16: ZZ (New Subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)










Assumptions:
Table ZZ-1. Labor Costs – Subpart ZZ - Ceramics Production










Because the emissions from ceramics occur from the calcination of the materials, the labor and O&M burden was assumed to be the same as for the non-CEMS option for lime manufacturing, which is also a calcination process. Subsequent year hours and O&M are from Tables S-1b and S-2 in Appendix H of the 2019 ICR. Assumed additional planning hours for the initial year.
Activity Labor Rates (per hour) Total Labor Cost per Year per Facility
Threshold analysis assumes 34 facilities would exceed the 25,000 mtCO2e threshold. Of the 16 facilities identified currently reporting under subpart C of Part 98, none appear to use CEMS. Additionally, other air quality regulations for ceramics manufacturers (NESHAP 5K and 6R) do not appear to require CEMS. Therefore, we assume most ceramics manufacturers would not have CEMs unless required by state or other regulation. However, we estimate that the recordkeeping and reporting burden from facilities using CEMS would be similar to costs for non-CEMS facilities; these sources would not have burden associated with planning, QA/QC, or sampling and analysis.
Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
$114.80 $91.33 $73.83 $34.09


Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year

Planning 1 1 0.4 0.4 6 4 0.2 0.2 $601 $453
*Planning activities include familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC
QA/QC 1 1 0.2 0.2 2 2 0.1 0.1 $284 $284
*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping 0 0 0.5 0.5 5 5 0.5 0.5 $432 $432
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations) 0 0 0.1 0.1 1 1 0.1 0.1 $86 $86
*Sampling and analysis (calculations) hours include completion of the measurements and calculations. Calculations include inputting the amounts of carbonate-based mineral into the equations to calculate CO2 emissions.
Reporting 0 0 1 1 10 10 1 1 $864 $864
*Reporting: Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), including set-up of account and first-time use of e-GGRT system).
Total 2 2 2.2 2.2 24 22 1.9 1.9 $2,267 $2,119














Total labor, 1 new facility: 2 2 2.2 2.2 24 22 1.9 1.9 $2,267 $2,119














Table ZZ-2a. Capital and O&M Costs – Subpart ZZ











Activity Cost Categories Total Capital and O&M Cost per Year per Facility (2021$)





Capital Cost (2021$) Equipment Lifetime Annualized Capital Cost (2021$/year) O&M Costs (2021$/year) Initial Year Subseq. Years





Equipment (selection, purchase, installation)






Performance testing






Recordkeeping $0
$0 $62 $62 $62 *covers cost to store records, such as a flash drive, paper file or cloud storage




Travel






Sampling and Analysis Costs






Total $0
$0 $62 $62 $62


















Total Capital and O&M, 1 new facility:



$62 $62


















Total Costs of Proposed Revisions, 1 new facility:



$2,330 $2,182





Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.
























Labor Costs of Proposed Revisions
O&M Cost Per Year






# of Facilities Initial Year Subseq. Years
Initial Year Subseq. Years






34 $77,083 $72,062
$2,121 $2,121






Calculation Methodology:











Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility





















Back to Table of Contents












Sheet 17: 2.3 Other Applicability

Burden for Subparts in Section 2.3 of Impacts Assessment





Subpart P (Applicability)

Total Costs Section 2.3


Subpart Y (Applicability)



Initial Year Subsequent Years




Total Labor costs: ($3,072) ($3,072)
Back to Table of Contents


Total Non-Labor costs: ($1,689) $551




Total Section 2.3: ($4,761) ($2,521)

Sheet 18: Subpart P (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.3)















Applicability is affected by rule changes that increase the number of hydrogen plants reporting.















Table P-1. Labor Costs – Subpart P - Hydrogen Production - Mass Balance Option; Natural Gas and Liquid/Solid Fuels (from Table P-1e of Appendix H to the 2019 ICR)















Activity Labor Rates (per hour) Total Labor Cost per Year per Facility





Lawyer Industrial Manager Industrial Engineer/ Technician Administrative Support (2021$)
Assumptions:



$114.80 $91.33 $73.83 $34.09






Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Hours Subseq. Year Hours Initial Year Subseq. Year





Planning 0 0 0.4 0.4 4 4 0.4 0.4 $345 $345
*reading the rule to become familiar with any changes to the rule requirements, asking questions about applicability, reviewing any overlap in existing reporting programs



QA/QC 0 0 0.2 0.2 2 2 0.2 0.2 $173 $173
*QA/QC activities include review of calculations, testing, and reports;



Recordkeeping 0 0 0.5 0.5 5 5 0.5 0.5 $432 $432
*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method



Sampling and Analysis (Calculations) 0 0 0.1 0.1 1 1 0.1 0.1 $86 $86
*Sampling and analysis to determine the molecular weight and carbon content of the natural gas is performed annually



Reporting 0 0 1 1 10 10