| 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 |
| Table 4-1. Incremental Implementation Costs by Subpart (2021$) |
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| 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 |
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|
|
|
| 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 |
$10,889,422 |
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| Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1) |
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| Applicability is affected by changes to the globabl warming potential values. |
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Assumes the cost impacts would be for a facility using the annual performance test option (without abatement); if they need abatement, they would be less likely to be able to cease reporting. |
| Table V-1. Labor Costs – Subpart V (hours from Appendix H to the 2019 ICR) |
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Hours for first year are from Table 4-26 of the 2009 Final Impacts Analsysis |
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
|
|
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
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 |
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| Total labor, 1 facility: |
1 |
1 |
58 |
3.8 |
78 |
28.8 |
12 |
2.7 |
$11,579 |
$2,680 |
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| Table V-2. Capital and O&M Costs – Subpart V – All facilities (from Appendix H to the 2019 ICR) |
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| Activity |
Cost Categories |
Total Capital and O&M Cost per Year per Facility (2021$) |
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| Capital Cost (2021$) |
Equipment Lifetime |
Annualized Capital Cost (2021$/year) |
O&M Costs (2021$/year) |
Initial Year |
Subseq. Years |
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|
| Equipment (selection, purchase, installation) |
$- |
|
$- |
$- |
$- |
$- |
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| Performance testing |
$- |
|
$- |
$11,022 |
$- |
$11,022 |
*Costs of performance testing, assumes 1.63 nitric acid trains per facility. |
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| Recordkeeping |
$- |
|
$- |
$62 |
$- |
$62 |
*covers cost to store records, such as a flash drive, paper file or cloud storage |
|
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| Travel |
$- |
|
$- |
$- |
$- |
$- |
|
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|
| Sampling and Analysis Costs |
$- |
|
$- |
$- |
$- |
$- |
|
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| Total |
$- |
$- |
$- |
$11,085 |
$- |
$11,085 |
|
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| Total Capital and O&M, 1 facility: |
|
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|
$0 |
$11,085 |
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| Total Costs of Proposed Revisions, 1 facility: |
|
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|
$11,579 |
$13,765 |
|
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| Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs. |
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| Labor Costs of Proposed Revisions |
|
O&M Cost Per Year |
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| # of Facilities |
Initial Year |
Subseq. Years |
|
Initial Year |
Subseq. Years |
|
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| -1 |
($2,680) |
($2,680) |
|
($11,085) |
($11,085) |
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| Calculation Methodology: |
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Assumes one facility may potentially meet the offramp provisions of 40 CFR 98.2(b) and stop reporting |
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| Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility |
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Assumed the initial year savings are the same as the subsequent year savings because the facility is going to off-ramp and does not have any initial year costs. |
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| Back to Table of Contents |
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Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1) |
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Applicability is affected by changes to the globabl warming potential values. |
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This is the list of new reporters per segment from the increase in methane GWP provided by Jennifer Bohman on November 10, 2022.* |
|
Baseline W Monitoring Burden and Costs Per Reporter
Calculated from From ICR Appendix E-4: Burden and Cost for Petroleum and Natural Gas Systems (Subpart W) June 2019
Calculated averages per reporter, scaled to 2021$ |
|
Incremental Labor Changes for New Reporters from W Data Elements After June 2022 Proposed W Amendments |
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Incremental Labor and O&M Cost Changes for Monitoring After June 2022 Proposed W Amendments (2021$) |
|
Total Costs (2021$) for All New W Reporters |
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| 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 |
|
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|
| 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 |
|
$- |
$- |
|
- |
$- |
$- |
$- |
|
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| 5 |
Natural Gas Processing |
462 |
0 |
|
|
69 |
$7,617 |
$26,686 |
$34,304 |
|
3.68 |
$397 |
|
10.18 |
$1,166.58 |
$- |
$1,166.58 |
|
- |
$- |
$- |
$- |
|
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| 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 |
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Total |
2,350 |
188 |
|
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Avg $/reporter |
$499 |
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Totals |
23,686 |
$2,620,418 |
$2,717,864 |
$5,338,282 |
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Labor |
O&M |
Total |
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Note to EPA: For columns G, H, I, O, P, and Q, see the calculations in hidden input sheets at back of this workbook. |
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Weighted Avg for Individual Reporter: |
$13,938 |
$14,457 |
$28,395.12 |
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QA: |
$13,938 |
$14,457 |
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Straight Average: |
$11,985 |
$10,015 |
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$738.63 |
#REF! |
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$328.97 |
#REF! |
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$813.24 |
#REF! |
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$74.48 |
#REF! |
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$1,563.83 |
#REF! |
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$800.82 |
#REF! |
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$1,384.40 |
#REF! |
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$726.34 |
#REF! |
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$1,716.31 |
#REF! |
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$813.24 |
#REF! |
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#REF! |
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| Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1) |
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| Applicability is affected by changes to the global warming potential values. |
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| Table DD-1. Labor Costs – Subpart DD (from Appendix H to the 2019 ICR) |
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| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
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|
|
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
Assumptions: |
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|
|
|
| $114.80 |
$91.33 |
$73.83 |
$34.09 |
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|
| 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 |
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|
|
|
| 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; |
|
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|
|
| 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 |
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|
| 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 |
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|
| 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). |
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| Total |
1 |
1 |
4.5 |
4.5 |
31 |
31 |
5.5 |
5.5 |
$3,002 |
$3,002 |
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| Total labor, 1 facility: |
1 |
1 |
4.5 |
4.5 |
31 |
31 |
5.5 |
5.5 |
$3,002 |
$3,002 |
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|
Adjusted hours from package 1: |
$98.16 |
| Table DD-2a. Capital and O&M Costs – Subpart DD – All facilities (from Appendix H to the 2019 ICR) |
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| Activity |
Cost Categories |
Total Capital and O&M Cost per Year per Facility (2021$) |
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| Capital Cost (2021$) |
Equipment Lifetime |
Annualized Capital Cost (2021$/year) |
O&M Costs (2021$/year) |
Initial Year |
Subseq. Years |
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| Equipment (selection, purchase, installation) |
– |
|
– |
– |
– |
– |
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|
|
|
|
| Performance testing |
– |
|
– |
– |
– |
– |
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|
| Recordkeeping |
$- |
|
$- |
$62 |
$62 |
$62 |
*covers cost to store records, such as a flash drive, paper file or cloud storage |
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| Travel |
– |
|
– |
– |
– |
– |
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|
| 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. |
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| Total |
$- |
|
$- |
$1,559 |
$1,559 |
$1,559 |
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| Total Capital and O&M, 1 new facility: |
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$1,559 |
$1,559 |
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| Total Costs of Proposed Revisions, 1 facility: |
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|
$4,561 |
$4,561 |
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| Cost of Proposed Revisions from Package 1 (per facility): |
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|
|
$98 |
$98 |
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| Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs . |
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| Labor Costs of Proposed Revisions |
|
O&M Cost Per Year |
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| # of Facilities |
Initial Year |
Subseq. Years |
|
Initial Year |
Subseq. Years |
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| 2 |
$6,200 |
$6,200 |
|
$3,119 |
$3,119 |
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| Calculation Methodology: |
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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 $2021) |
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Because affected facilities are existing facilities that will continue reporting (instead of new reporters), the initial year and subsequent year impacts should be the same. |
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| Back to Table of Contents |
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| Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1) |
|
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| Applicability is affected by changes to the global warming potential values. |
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| Table HH-1. Labor Costs – Subpart HH - Landfills - Facilities with gas collection systems (from Table HH-2a in Appendix H to the 2019 ICR) |
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| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
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|
|
|
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
Assumptions: |
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|
|
|
| $114.80 |
$91.33 |
$73.83 |
$34.09 |
|
|
Assumes the 6 new facilities affected by CH4 GWP change have GCS. |
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|
| 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 |
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|
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| 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. |
|
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|
|
|
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| QA/QC |
0 |
0 |
1 |
1 |
13 |
6 |
1 |
1 |
$1,085 |
$568 |
|
*QA/QC activities include review of calculations, testing, and reports; |
|
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|
|
|
|
|
| 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 |
|
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|
|
|
|
|
| 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 |
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|
|
|
|
| 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). |
|
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|
|
|
|
| Total |
2 |
1 |
6 |
5 |
89 |
54 |
8 |
6 |
$7,621 |
$4,763 |
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| Total labor, 1 facility: |
2 |
1 |
6 |
5 |
89 |
54 |
8 |
6 |
$7,621 |
$4,763 |
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|
Adjusted hours from package 1: |
$4.49 |
| Table HH-2. Capital and O&M Costs – Subpart HH – Landfills - Facilities without gas collection systems (from Table HH-3b in Appendix H to the 2019 ICR) |
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| Activity |
Cost Categories |
Total Capital and O&M Cost per Year per Facility (2021$) |
|
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|
|
|
|
|
|
|
|
|
|
| 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 . |
|
|
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|
|
|
|
|
|
|
|
|
|
|
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|
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|
|
|
| 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 |
|
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|
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|
|
|
|
|
|
| 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 $2021) |
|
|
|
"Initial year" cost is based on one facility being new and 5 being earlier reporters that have only subsequent year costs. |
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| Back to Table of Contents |
|
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|
| Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1) |
|
|
|
|
|
|
|
|
|
|
|
|
| Applicability is affected by changes to the global warming potential values. |
|
|
|
|
|
|
|
|
|
|
|
|
| Table II-1. Labor Costs – Subpart II (from Appendix H to the 2019 ICR) |
|
|
|
|
|
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|
|
|
|
|
|
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
|
|
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
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 |
$3,077 |
|
|
|
|
|
|
|
| Calculation Methodology: |
|
|
|
|
|
|
Assumed two new reporters would be expected to start reporting to the GHGRP |
|
|
|
|
|
| Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Back to Table of Contents |
|
|
|
|
|
|
|
|
|
|
|
|
| Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Applicability is affected by changes to the global warming potential values. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table OO-1. Labor Costs – Subpart OO - F-GHG Importers (from Table OO-1b in Appendix H to the 2019 ICR) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
|
Note: Package 1 includes costs for new data elements for subpart OO that do not overlap with new data elements added in this package that may need to be considered for new reporters. |
|
|
|
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
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 $2021) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Back to Table of Contents |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1) |
|
|
|
|
|
|
|
|
|
|
|
|
| Applicability is affected by changes to the global warming potential values. |
|
|
|
|
|
|
|
|
|
|
|
|
| Table TT-1. Labor Costs – Subpart TT (from Appendix H to the 2019 ICR) |
|
|
|
|
|
|
|
|
|
|
|
|
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
|
Assumptions: |
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
|
| $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 |
$62 |
|
|
|
|
|
|
|
| Calculation Methodology: |
|
|
|
|
|
|
Assumed to be one new reporter who would be expected to start reporting to the GHGRP. |
|
|
|
|
|
| Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Back to Table of Contents |
|
|
|
|
|
|
|
|
|
|
|
|
| Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table B-1. Labor Costs – Subpart B – Energy Consumption |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
|
Assumptions: |
|
|
|
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
|
|
|
|
| $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 |
$489,050 |
|
Assume 7,582 existing reporters per year, based on 2021 RY reporters in S3 data subject to direct emitter subparts , + 5 RR reporters, + 200 new reporters from GWP changes + 53 reporters from new subparts WW, XX, YY, and ZZ. |
|
|
|
|
|
|
|
|
| Calculation Methodology: |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility |
|
|
|
|
|
|
|
|
7582 |
Direct Emitters, from file: https://easternresearchgroup.sharepoint.com/:x:/r/sites/GHGRP/Shared%20Documents/General/Rulemaking/Supplemental%20Notice/Impacts/Data%20Pulls/GHGRP_Rulemaking_DataAggregations_220824_FINAL.xlsx?d=w8e531e632f6c455591c93fbeb406e4a7&csf=1&web=1&e=bUnx5E |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
5 |
RR facilities |
|
7,840 |
| Back to Table of Contents |
|
|
|
|
|
|
|
|
|
|
|
200 |
GWP new reporters |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
53 |
New subpart reporters |
|
|
| Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2) |
|
|
|
|
|
|
|
|
|
|
|
Assumptions: |
| Table WW-1. Labor Costs – Subpart WW – Coke Calciners |
|
|
|
|
|
|
|
|
|
|
|
For Subpart Y, EPA previously used model plants to estimate costs that assume a variety of refinery emission units and a set amount of units for each model. For these reasons, these estimates instead assume the same labor hours and O&M costs as used for subpart Q - Iron and Steel Production (carbon mass balance option with sampling, see Table Q-1a(1) in Appendix H) - because both rules rely on a carbon mass balance approach with carbon content sampling. |
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility (2021$) |
|
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. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
|
|
|
|
| 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 |
$19,649 |
|
|
|
|
|
|
|
| Calculation Methodology: |
|
|
|
|
|
|
|
|
|
|
|
|
| Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility |
|
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|
|
| Back to Table of Contents |
|
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|
| Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2) |
|
|
|
|
|
|
|
|
|
|
|
Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
|
From the draft preamble: There is currently one producer of calcium carbide in the U.S., Carbide Industries, LLC, located in Louisville, KY. Carbide Industries LLC, currently reports their process greenhouse gas (GHG) emissions under the GHG Reporting Program (GHGRP; 40 CFR part 98), subpart K – Ferroalloy Production (GHGRP Facility ID 528303). Their reporting under subpart K is voluntary as the subpart does not cover the production of calcium carbide. |
| Table XX-1. Labor Costs – Subpart XX – Calcium Carbide Production |
|
|
|
|
|
|
|
|
|
|
|
Subpart K requires that analysis of the C-content of 6 input and output materials in the mass balance equation; Subpart XX requires the analysis of 4 materials and does not require calculating CH4 emissions. |
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
|
The existing carbide facility does not currently report under subpart C or K using CEMS. Based on this information, assume the same hour and O&M burden as for subpart K, Tables K-1 and K-2 of Appendix H to the 2019 ICR, except assume that hours for sampling and analysis (calculations) for subpart XX are 2/3 of what they are for subpart K (e.g., 8 hours of engineer/technician instead of 12 hours). |
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
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 |
$62 |
|
|
|
|
|
|
|
| Calculation Methodology: |
|
|
|
|
|
|
|
|
|
|
|
|
| Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
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|
|
|
| Back to Table of Contents |
|
|
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|
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|
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|
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|
|
| Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2) |
|
|
|
|
|
|
|
|
|
|
|
Assumptions: |
| Table YY-1. Labor Costs – Subpart YY - Caprolactam, Glyoxal, and Glyoxylic Acid Production |
|
|
|
|
|
|
|
|
|
|
|
|
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
|
Assumed similar labor hours and O&M as for subpart V - Nitirc Acid Production for the Alternative Monitoring Method Option. These are both subparts dealing with sources of N2O that include the use of emission factors and accounting for abatement DRE. |
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
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 |
$374 |
|
There are approximately four to six facilities, which is the known universe of facilities that produce caprolactam, glyoxal, and glyoxylic acid in the United States. |
|
|
|
|
|
| Calculation Methodology: |
|
|
|
|
|
|
|
|
|
|
|
|
| Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
| Back to Table of Contents |
|
|
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|
|
|
|
|
|
|
|
| Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2) |
|
|
|
|
|
|
|
|
|
|
|
Assumptions: |
| Table ZZ-1. Labor Costs – Subpart ZZ - Ceramics Production |
|
|
|
|
|
|
|
|
|
|
|
Because the emissions from ceramics occur from the calcination of the materials, the labor and O&M burden was assumed to be the same as for the non-CEMS option for lime manufacturing, which is also a calcination process. Subsequent year hours and O&M are from Tables S-1b and S-2 in Appendix H of the 2019 ICR. Assumed additional planning hours for the initial year. |
| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
|
Threshold analysis assumes 34 facilities would exceed the 25,000 mtCO2e threshold. Of the 16 facilities identified currently reporting under subpart C of Part 98, none appear to use CEMS. Additionally, other air quality regulations for ceramics manufacturers (NESHAP 5K and 6R) do not appear to require CEMS. Therefore, we assume most ceramics manufacturers would not have CEMs unless required by state or other regulation. However, we estimate that the recordkeeping and reporting burden from facilities using CEMS would be similar to costs for non-CEMS facilities; these sources would not have burden associated with planning, QA/QC, or sampling and analysis. |
| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
|
| $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 |
$2,119 |
|
|
|
|
|
|
|
|
|
|
|
|
|
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| Table ZZ-2a. Capital and O&M Costs – Subpart ZZ |
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| Activity |
Cost Categories |
Total Capital and O&M Cost per Year per Facility (2021$) |
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| Capital Cost (2021$) |
Equipment Lifetime |
Annualized Capital Cost (2021$/year) |
O&M Costs (2021$/year) |
Initial Year |
Subseq. Years |
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| Equipment (selection, purchase, installation) |
– |
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– |
– |
– |
– |
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| Performance testing |
– |
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– |
– |
– |
– |
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| Recordkeeping |
$0 |
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$0 |
$62 |
$62 |
$62 |
*covers cost to store records, such as a flash drive, paper file or cloud storage |
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| Travel |
– |
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– |
– |
– |
– |
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| Sampling and Analysis Costs |
– |
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– |
– |
– |
– |
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| Total |
$0 |
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$0 |
$62 |
$62 |
$62 |
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| Total Capital and O&M, 1 new facility: |
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$62 |
$62 |
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| Total Costs of Proposed Revisions, 1 new facility: |
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$2,330 |
$2,182 |
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| Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs. |
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| Labor Costs of Proposed Revisions |
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O&M Cost Per Year |
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| # of Facilities |
Initial Year |
Subseq. Years |
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Initial Year |
Subseq. Years |
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| 34 |
$77,083 |
$72,062 |
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$2,121 |
$2,121 |
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| Calculation Methodology: |
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| Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility |
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| Back to Table of Contents |
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| Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.3) |
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| Applicability is affected by rule changes that increase the number of hydrogen plants reporting. |
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| Table P-1. Labor Costs – Subpart P - Hydrogen Production - Mass Balance Option; Natural Gas and Liquid/Solid Fuels (from Table P-1e of Appendix H to the 2019 ICR) |
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| Activity |
Labor Rates (per hour) |
Total Labor Cost per Year per Facility |
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| Lawyer |
Industrial Manager |
Industrial Engineer/ Technician |
Administrative Support |
(2021$) |
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Assumptions: |
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| $114.80 |
$91.33 |
$73.83 |
$34.09 |
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| 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 |
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| Planning |
0 |
0 |
0.4 |
0.4 |
4 |
4 |
0.4 |
0.4 |
$345 |
$345 |
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*reading the rule to become familiar with any changes to the rule requirements, asking questions about applicability, reviewing any overlap in existing reporting programs |
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| QA/QC |
0 |
0 |
0.2 |
0.2 |
2 |
2 |
0.2 |
0.2 |
$173 |
$173 |
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*QA/QC activities include review of calculations, testing, and reports; |
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| Recordkeeping |
0 |
0 |
0.5 |
0.5 |
5 |
5 |
0.5 |
0.5 |
$432 |
$432 |
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*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method |
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| Sampling and Analysis (Calculations) |
0 |
0 |
0.1 |
0.1 |
1 |
1 |
0.1 |
0.1 |
$86 |
$86 |
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*Sampling and analysis to determine the molecular weight and carbon content of the natural gas is performed annually |
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| Reporting |
0 |
0 |
1 |
1 |
10 |
10 |