Calculation Tables

1995t09.xlsx

NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Proposed Rule)

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OMB: 2060-0521

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Overview

Total Annual Responses
No. Respondents
Respondent Burden 1995t09
Agency Burden 1995t09
O&M 1995t09


Sheet 1: Total Annual Responses

Total Annual Responses








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



Number of Existing Respondents That Keep Records But Do Not Submit Reports Total Annual Responses
Information Collection Activity Number of Respondents Number of Responses
E=(BxC)+D
Notification of compliance status 0 1 0 0
Notification/application of construction 0 1 0 0
Notification of actual startup 0 1 0 0
Notification of performance test and test plan 0 1 0 0
Report of performance test results1 5.6 1 0 5.6
Report of performance test results2 2.8 1 0 2.8
Report of performance test results3 2.8 1 0 2.8
Report of performance test results4 2.8 1 0 2.8
Report of performance test results5 1.8 1 0 1.8
Report of performance test results6 1.8 1 0 1.8
Report of performance test results7 1.8 1 0 1.8
Report of performance test results8 0.8 1 0 0.8
Report of performance test results9 0.8 1 0 0.8
Report of performance test results10 0.8 1 0 0.8
Report of performance test results11 0.8 1 0 0.8
Report of performance test results12 1 1 0 1
Report of performance test results13 1 1 0 1
Report of performance test results14 1 1 0 1
Report of performance test results15 1 1 0 1
Report of performance test results16 1 1 0 1
Report of semiannual compliance reports 14 2 0 28
Report of quarterly compliance reports17 9 4 0 36



Total 18 92





1 There is an average of 5.6 respondents per year (14*0.4) submitting Method 5 (PM) performance test reports for pushing.



2 There is an average of 2.8 respondents per year (14*0.2) submitting Method 29 (Hg) performance tests for pushing.



3 There is an average of 2.8 respondents per year (14*0.2) submitting Method 320 (AG and HCN) performance tests for pushing.



4 There is an average of 2.8 respondents per year (14*0.2) submitting CARB 429 (PAH) performance tests for pushing.



5 There is an average of 1.8 respondents per year (9*0.2) submitting Method 29 (Hg) performance tests for ByP battery combustion stacks.



6 There is an average of 1.8 respondents per year (9*0.2) submitting Method 5 (PM) performance tests for ByP battery combustion stacks.



7 There is an average of 1.8 respondents per year (9*0.2) submitting Method 320 (AG and HCN) performance tests for ByP battery combustion stacks.



8 There is an average of 0.8 respondents per year (4*0.2) submitting Method 29 (Hg) performance tests for HNR HRSG main stacks.



9 There is an average of 0.8 respondents per year (4*0.2) submitting Method 5 (PM) performance tests for HNR HRSG main stacks.



10 There is an average of 0.8 respondents per year (4*0.2) submitting Method26/26A (AG) performance tests for HNR HRSG main stacks.



11 There is an average of 0.8 respondents per year (4*0.2) submitting CARB 429 (PAH) performance tests for HNR HRSG main stacks.



12 There is an average of 1.0 respondents per year (5*0.2) submitting Method 29 (Hg) performance tests for HNR HRSG bypass/waste heat stacks.



13 There is an average of 1.0 respondents per year (5*0.2) submitting Method 5 (PM) performance tests for HNR HRSG bypass/waste heat stacks.



14 There is an average of 1.0 respondents per year (5*0.2) submitting Method 26/26A (AG) performance tests for HNR HRSG bypass/waste heat stacks.



15 There is an average of 1.0 respondents per year (5*0.2) submitting CARB 429 (PAH) performance tests for HNR HRSG bypass/waste heat stacks.



16 There is an average of 1.0 respondents per year (5*0.2) submitting Method 316 (formaldehyde) performance tests for HNR HRSG bypass/waste heat stacks.








17 40 CFR 63.7341(b) requires quarterly reporting for the COMS systems monitoring opacity of emissions from stacks on the coke ovens at the eleven by-product recovery plants.



18 Figures may not add exactly due to rounding.




Sheet 2: No. Respondents


Number of Respondents




Respondents That Submit Reports Respondents That Do Not Submit Any Reports







(A) (B) (C) (D) (E)
Year Number of New Respondents 1 Number of Existing Respondents Number of Existing Respondents that keep records but do not submit reports Number of Existing Respondents That Are Also New Respondents Number of Respondents





(E=A+B+C-D)
1 0 14 0 0 14
2 0 14 0 0 14
3 0 14 0 0 14
Average 0 14 0 0 14

Sheet 3: Respondent Burden 1995t09

Table 1: Annual Respondent Burden and Cost – NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Proposed Amendments)











1995.09











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

1. Applications N/A










2. Survey and Studies N/A







Labor Rates

3. Acquisition, Installation, and Utilization of Technology and Systems 40 1 40 0 0 0 0 $0
Technical $130.28
4. Reporting Requirements








Management $163.17
A. Familiarize with rule requirement 2 1 2 14 28 1.4 2.8 $4,060.27
Clerical $65.71
B. Required activities c, d











Method 5 performance test [PM] - Pushing e, c 40 2.0 80 5.6 448 22.4 44.8 $64,964.26

Facilities Batteries
Method 29 performance test [Hg]- Pushing f 40 2.0 80 2.8 224 11.2 22.4 $32,482.13
Number of Respondents: 14 47
Method 320 performance test [AG+HCN] - Pushing f 40 2.0 80 2.8 224 11.2 22.4 $32,482.13
By-product Batteries 9 27
CARB 429 performance test [PAH] - Pushing f 40 2.0 80 2.8 224 11.2 22.4 $32,482.13
Heat and/or nonrecovery Batteries 5 20
Method 29 performance test [Hg] - ByP Battery g Combustion Stack 40 2.8 112 1.8 201.6 10.08 20.16 $29,233.92



Method 5 performance test [PM] - ByP Battery g Combustion Stack 40 2.8 112 1.8 201.6 10.08 20.16 $29,233.92



Method 320 performance test [AG+HCN] - ByP Battery Combustion Stack g 40 2.8 112 1.8 201.6 10.08 20.16 $29,233.92



Method 29 performance test [Hg] - HNR HRSG Main Stack h 40 1.3 52 0.8 41.6 2.08 4.16 $6,032.40



Method 5 performance test [PM] - HNR HRSG Main Stack h 40 1.3 52 0.8 41.6 2.08 4.16 $6,032.40



Method 26/26A performance test [AG] - HNR HRSG Main Stack h 40 1.3 52 0.8 41.6 2.08 4.16 $6,032.40



CARB 429 performance test [PAH] - HNR HRSG Main Stack h 40 1.3 52 0.8 41.6 2.08 4.16 $6,032.40



Method 29 performance test - HNR HRSG Bypass/Waste Heat Stack i 40 10.6 424 1 424 21.2 42.4 $61,484.03



Method 5 performance test - HNR HRSG Bypass/Waste Heat Stack i 40 10.6 424 1 424 21.2 42.4 $61,484.03



Method 26/26A performance test - HNR HRSG Bypass/Waste Heat Stack i 40 10.6 424 1 424 21.2 42.4 $61,484.03



CARB 429 performance test - HNR HRSG Bypass/Waste Heat Stack i 40 10.6 424 1 424 21.2 42.4 $61,484.03



EPA Method 316 performance test - HNR HRSG Bypass/Waste Heat Stack i 40 10.6 424 1 424 21.2 42.4 $61,484.03



Operation and maintenance plans for by-product coke oven batteries and capture systems and control devices applied to pushing emissions 40 1 40 0 0 0 0 $0



Work practice plan for batteries with horizontal flues (one plant) 40 1 40 1 40 2 4 $5,800.38



Method 9 daily observations for fugitive pushing emissions j 3.4 365 1,225 14 17,155 857.8 1,715.5 $2,487,637.97



Weekly sampling for total dissolved solids (TSD) k 2.0 52 104 14 1,456.0 72.8 145.6 $211,133.83



Monthly inspections and maintenance of affected sources, control devices, and continuous parameter monitoring systems e 2 12 24 14 336 16.8 33.6 $48,723.19



C. Create information See 4B










D. Gather existing information See 4B










E. Write report











Notification of applicability 2 1 2 0 0 0 0 $0



Notification of constr./reconstr. 2 1 2 0 0 0 0 $0



Notification of anticipated startup 2 1 2 0 0 0 0 $0



Notification of actual startup 2 1 2 0 0 0 0 $0



Notification of special compliance 2 1 2 0 0 0 0 $0



Requirements











Compliance extension request 2 1 2 0 0 0 0 $0



Notification of performance testc 2 1.5 3 0 0 0 0 $0



Site-specific test plan 40 1 40 0 0 0 0 $0



Notification of compliance status 8 1 8 0 0 0 0 $0



NESHAP waiver application N/A










Report of performance test l See 4B










Semiannual compliance reports l 40 2 80 14 1120 56 112 $162,410.64



Quarterly COMS compliance reports for battery stacks m 12 4 48 9 432 21.6 43.2 $62,644.10



Subtotal for Reporting Requirements



28,265 $3,564,072



5. Recordkeeping Requirements











A. Familiarize with rule requirement See 4A










B. Plan activities 3 1 3 0 0 0 0 $0



C. Implement activities 12 1 12 0 0 0 0 $0



D. Develop record system 3 1 3 0 0 0 0 $0



E. Time to enter information (through CEDRI using ERT)











Report of other non-performance test submittalsn 4 52.0 208 14 2,912 146 291 $422,267.66



Report of Method 5 performance test - Pushingn 8 2.0 16 5.6 89.6 4.48 8.96 $12,992.85



Report of Method 29, 320, and CARB 429 performance test - Pushingn 24 2.0 48 2.8 134.4 6.72 13.44 $19,489.28



Report of Method 29, 5, and 320 performance tests - ByP Battery Combustionn 24 2.8 67.2 1.8 120.96 6.048 12.096 $17,540.35



Report of Method 29, 5, 26/26A, and CARB 429 performance tests - HNR HRSG Main Stackn 32 1.3 41.6 0.8 33.28 1.664 3.328 $4,825.92



Report of Method 29, 5, 26/26A, CARB 429 and 316 performance tests - HNR HRSG Bypass/Waste Heat Stackn 40 10.6 424 1 424 21.2 42.4 $61,484.03



F. Time to train personnel 3 1 3 0 0 0 0 $0



G. Time to adjust existing ways to comply with previously applicable requirements 3 1 3 0 0 0 0 $0



H. Time to transmit or disclose information See E










I. Time for audits N/A







92 responses/yr
Subtotal for Recordkeeping Requirements



4,271 $538,600
355 hr/resp
TOTAL LABOR BURDEN AND COST (rounded) o



32,500 $4,100,000



Capital and O&M Cost (rounded) o






$125,000



GRAND TOTAL (rounded) o






$4,230,000





























Assumptions:











a There is an average of 14 respondents (i.e., 9 coke plants operating 27 by-product (ByP) batteries and 5 coke plants operating 20 heat and/or nonrecovery (HNR) batteries). We have assumed that there will be no new sources subject to this regulation.



b This ICR uses the following labor rates: $163.17 per hour for Executive, Administrative, and Managerial labor; $130.28 per hour for Technical labor, and $65.71 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.



c We have assumed existing respondents already comply with initial rule requirements and are in full compliance with periodic requirements including quarterly and semiannual reports. New respondents would have to comply with the initial rule requirements including notifications and performance tests for add-on control devices.



d Monitoring and recordkeeping of operations for respondents include: monthly inspection of capture and control systems; daily Method 9 observations; weekly sampling for dissolved solids for quenching operations; work practices for batteries with horizontal flues (one plant); and Method 5 testing for particulate matter.



e The rule requires that every 2.5 years (or 0.4 times per year over the 3 years of the ICR), each control device applied to pushing emissions must be sampled by Method 5 for particulate matter. We have determined that there is an average of 2.0 emission points per respondent (28 pushing units / 14 facilities) that need to be tested. There is an average of 5.6 respondents per year (14*0.4) submitting Method 5 performance test reports.



f We are proposing Hg, AG, HCN, and PAH testing once every five years (or 0.2 times per year over the 3 years of the ICR), each control device applied to pushing emissions must be sampled by Method 29 for Hg; Method 320 for AG and HCN; and CARB 429 for PAH. We have determined that there is an average of 2.0 emission points per respondent (28 pushing units / 14 facilities) that need to be tested. There is an average of 2.8 respondents per year (14*0.2) submitting Method 29, 320, and CARB 429 performance test reports.



g We are proposing Hg, PM, AG and AG testing once every five years (or 0.2 times per year over the 3 years of the ICR), each ByP battery combustion stack must be sampled by Method 29 for Hg, Method 5 for PM, and Method 320 for AG and HCN. We have determined that there is an average of 2.8 emission points per respondent (25 ByP battery combustion stacks / 9 ByP facilities) that need to be tested. There is an average of 1.8 respondents per year (9*0.2) submitting Method 29, 5, and 320 performance test reports.



h We are proposing Hg, PM, AG, and PAH testing once every five years (or 0.2 times per year over the 3 years of the ICR), each HNR heat recovery steam generator (HRSG) main stack must be sampled by Method 26 for Hg, Method 5 for PM, Method 26/26A for AG, and CARB 429 for PAH. We have determined that there is an average of 1.3 emission points per respondent (5 HNR HRSG main stacks / 4 heat recovery facilities) that need to be tested. There is an average of 0.8 respondents per year (4*0.2) submitting Method 29, 5, 26/26A, and CARB 429 performance test reports.



i We are proposing Hg, PM, AG, PAH, and Formaldehyde testing once every five years (or 0.2 times per year over the 3 years of the ICR), each HNR HRSG bypass/waste heat stack must be sampled by Method 29 for Hg, Method 5 for PM, Method 26/26A for AG, CARB 429 for PAH, and Method 316 for Formaldehyde. We have determined that there is an average of 10.6 emission points per respondent (53 HNR HRSG bypass/waste heat stacks / 5 HNR facilities) that need to be tested. There is an average of 1 respondents per year (5*0.2) submitting Method 29, 5, 26/26A, CARB 429 and 316 performance test reports.



j Assumes one hour of observations per day per battery.



k The measuring of the total dissolved solids (TDS) in the make-up water used for quenching is a requirement. In past analysis, we determined there is an average of 2.0 quenching towers per facility.



l The rules requires the submittal of quarterly compliance reports for all battery stacks. If no deviation occurred and no continuous monitoring systems were out of control, only a summary report is required. For other affected sources, semiannual reports are required for any deviation from an emission limitation (including an operating limit), work practice standard, or O&M requirement.



m 40 CFR 63.7341(b) requires quarterly reporting for the COMS monitoring opacity of emissions from the stacks on by-product recovery coke ovens, which are present at nine plants.



n Submittal of other non-performance reports through the EPA's CEDRI in ERT format is estimated to require 4 hours; submittal of performance test data through the EPA's CEDRI in ERT format is estimated to require 8 hours per test method report, includes keeping records of failures to meet the standards and the actions taken to minimize emissions.



o Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.




Sheet 4: Agency Burden 1995t09

Table 2: Average Annual EPA Burden and Cost – NESHAP for Coke Oven Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) (Proposed Amendments)











1995.09











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

Initial performance test 40 1 40 0 0 0 0 $0
Labor Rates

Repeat performance test-Retesting preparation 2 1 2 0 0 0 0 $0
Technical $52.37
Repeat performance- Retesting 40 1 40 0 0 0 0 $0
Management $70.56
Report Review








Clerical $28.34
Notification of construction/reconstruction N/A








Facilities Batteries
Notification of anticipated startup N/A







Number of Respondents: 14 47
Notification of actual startup N/A







By-product Batteries 9 27
Notification of special compliance requirements N/A







Heat and/or nonrecovery Batteries 5 20
Notification of initial performance test 2 1 2 0 0 0 0 $0



Notification of compliance status d 2 1 2 0 0 0 0 $0



Review of repeat Method 5 performance test report - Pushing (through CEDRI using ERT) 8 2.0 16 5.6 89.6 4.48 8.96 $5,262.39



Review of repeat Method 5, 320, and CARB 429 performance test - Pushing (through CEDRI using ERT) 24 2.0 48 2.8 134.4 6.72 13.44 $7,893.58



Review of repeat Method 29, 5, and 320 performance tests - ByP Battery Combustion Stack (through CEDRI using ERT) 24 2.8 67.2 1.8 120.96 6.048 12.096 $7,104.22



Review of repeat Method 29, 5, 26/26A, and CARB 429 performance tests - HNR HRSG Main Stack (through CEDRI using ERT) 32 1.3 41.6 0.8 33.28 1.664 3.328 $1,954.60



Review of repeat Method 29, 5, 26/26A, CARB 429 and 316 performance tests - HNR HRSG Bypass/Waste Heat Stack (through CEDRI using ERT) 40 10.6 424 1 424 21.2 42.4 $24,902.37



Review of semi-annual compliance report i 8 0.4 3.2 14 44.8 2.24 4.48 $2,631.19



Review of NESHAP waiver application 2 1 2 0 0 0 0 $0



Review of quarterly compliance report for battery stacks j 1 4 4 9 36 1.8 3.6 $2,114.35



TOTAL ANNUAL COST k



1,015 $51,860
















Assumptions:











a There are an average of 14 respondents (i.e., 9 coke plants operating 27 by-product (ByP) batteries and 5 coke plants operating 20 heat and/or nonrecovery (HNR) batteries). We have assumed that there will be no new sources subject to this regulation.



b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.



c We have assumed that existing sources have complied with the initial rule requirements. New respondents are required to conduct performance test for add-on control equipment, and submit initial notifications.



d Every 2.5 years (or about 0.4 times per year, if averaged over the three-year period of ICR), respondents must sample each pushing emission point using Method 5 for particulate matter and submit a report of results. We have determined that there is an average of 2.0 emission points per respondent (28 pushing units / 14 facilities) that need to be tested. There is an average of 5.6 respondents per year (14*0.4) submitting Method 5 performance test reports.



e We are proposing Hg, AG, HCN, and PAH testing once every five years (or 0.2 times per year over the 3 years of the ICR), each control device applied to pushing emissions must be sampled by Method 29 for Hg; Method 320 for AG and HCN; and CARB 429 for PAH. We have determined that there is an average of 2.0 emission points per respondent (28 pushing units / 14 facilities) that need to be tested. There is an average of 2.8 respondents per year (14*0.2) submitting Method 29, 320, and CARB 429 performance test reports.



f We are proposing Hg, PM, AG and AG testing once every five years (or 0.2 times per year over the 3 years of the ICR), each ByP battery combustion stack must be sampled by Method 29 for Hg, Method 5 for PM, and Method 320 for AG and HCN. We have determined that there is an average of 2.8 emission points per respondent (25 ByP battery combustion stacks / 9 facilities) that need to be tested. There is an average of 1.8 respondents per year (9*0.2) submitting Method 29, 5, and 320 performance test reports.



g We are proposing Hg, PM, AG, and PAH testing once every five years (or 0.2 times per year over the 3 years of the ICR), each HNR heat recovery steam generator (HRSG) main stack must be sampled by Method 26 for Hg, Method 5 for PM, Method 26/26A for AG, and CARB 429 for PAH. We have determined that there is an average of 1.3 emission points per respondent (5 HNR HRSG main stacks / 4 heat recovery facilities) that need to be tested. There is an average of 0.8 respondents per year (4*0.2) submitting Method 29, 5, 26/26A, and CARB 429 performance test reports.



h We are proposing Hg, PM, AG, PAH, and Formaldehyde testing once every five years (or 0.2 times per year over the 3 years of the ICR), each HNR HRSG bypass/waste heat stack must be sampled by Method 29 for Hg, Method 5 for PM, Method 26/26A for AG, CARB 429 for PAH, and Method 316 for Formaldehyde. We have determined that there is an average of 10.6 emission points per respondent (53 HNR HRSG bypass/waste heat stacks / 5 HNR facilities) that need to be tested. There is an average of 1 respondents per year (5*0.2) submitting Method 29, 5, 26/26A, CARB 429 and 316 performance test reports.



i Sources are required to submit semiannual compliance reports.



j 40 CFR 63.7341(b) requires the submittal of quarterly compliance reports for the COMS monitoring opacity on the battery stacks at the nine coke plants utilizing by-product recovery ovens.



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




Sheet 5: O&M 1995t09

1995.09






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







(A) (B) (C) (D) (E) (F) (G)
Continuous Monitoring Device Capital/Startup Cost for One Respondent Number of New Respondents Total Capital/Startup Cost, (B X C) Annual O&M Costs for One Respondent Number of Respondents with O&M Total O&M,






(E X F)
Leak detectors $9,000 0 $0 $500 14 $7,000
Continuous Opacity Monitors $37,000 0 $0 $8,421 14 $117,894
Total

$0

$125,000
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