SSI NSPS Burden Estimate Tables promulgation

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Overview

Table 1
Table 2
Table 3
Table 4 (Industry Summary)
Table 5
Table 6
Table 7
Table 8

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Sheet 1: Table 1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 1
				(A)		(B)	(C)	(D)	(E)	(F)	(G)				Footnotes
				Respondent	Non-Labor	Number of	Hours	Number of	Technical	Management	Clerical	Total	Total	Total
				Hours per	Costs	Occurrences	Per	Respondents	Hours	Hours	Hours	Labor Costs	Non-Labor	Responses
				Occurrence	Per	Per	Respondent	Per Year	Per Year	Per Year	Per Year	Per Year	Costs	Per Year
				(Technical	Occurrence	Respondent	Per Year						Per Year
Burden Item				hours)		Per Year	(C=A x B)		(CXD)	(E x 0.05)	(E x 0.1)
1.	Applications			N/A
2.	Surveys and Studies			N/A
3.	Reporting Requirements
	A.	Read and Understand Rule Requirements		40	$100	1	40	2	80	4	8	$5,230	$200	0	a,b,i
	B.	Required Activities
		1) Initial stack test and report		40	$61,350	1	40	2	80	4	8	$5,230	$122,700	0	a
		2) Annual stack test and test report		40	$21,350	1	40	0	0	0	0	$0	$0	0	c,j
		3) Operator training and qualification
			a) Establish and teach operator qualification course	64	$0	1	64	2	128	6	13	$8,368	$0	0	a,b
			b) Obtain operator qualification	72	$0	1	72	2	144	7	14	$9,414	$0	0	a,b
			c) Annual refresher course	12	$0	1	12	0	0	0	0	$0	$0	0	c
			d) Initial review of site-specific information	Incl. in a.
			e) Annual review of site-specific information	8	$0	1	8	0	0	0	0	$0	$0	0	c
		4) Establish operating parameters (maximum and minimum)		40	$0	1	40	2	80	4	8	$5,230	$0	0	a
		5) Continuous parameter monitoring (including CEMS)
			a) Initial capital costs	0	$226,946	1	0	2	0	0	0	$0	$453,892	0	a,d
			b) Annualized capital and O&M costs	11	$81,160	1	11	2	22	1	2	$1,438	$162,320	0	c,e
	C.	Create Information		Incl. in 3.B
	D.	Gather Information		Incl. in 3.E
	E.	Report Preparation
		1) Notification of construction (includes siting analysis)		160	$0	1	160	2	320	16	32	$20,921	$0	2	a
		2) Notification of start-up (includes monitoring plan)		40	$0	1	40	2	80	4	8	$5,230	$0	2
		3) Notification of initial performance test		2	$0	1	2	2	4	0	0	$262	$0	2
		4) Notification of initial CMS Demonstration		2	$0	1	2	2	4	0	0	$262	$0	2	b
		5) Initial Compliance Report		40	$0	1	40	2	80	4	8	$5,230	$0	2
		6) Annual Compliance Report		40	$0	1	40	0	0	0	0	$0	$0	0
		7) Status report for operators that are off-site for more than 2 weeks		8	$0	1	8	1	8	0	1	$523	$0	1	g
		8) Corrective action summary for operators that are off-site
			for more than 2 weeks	8	$0	2	16	1	16	1	2	$1,046	$0	2	g
		9) Semiannual Deviation Report		24	$0	2	48	1	48	2	5	$3,138	$0	2	h
ReportingSubtotal									1,094	55	109	$71,524	$285,220	15
4. Recordkeeping Requirements
	A. Read Instructions			Incl. in 3.A
	B. Plan Activities			N/A
	C. Implement Activities			N/A
	D. Develop Record System			N/A
	E. Record Information														g
		1) Records of operating parameters		2	$0	52	104	0	0	0	0	$0	$0	0
		2) Records of exceedances of the operating parameters		2	$0	1	2	1	2	0	0	$131	$0	0
		3) Records of stack tests		2	$0	1	2	0	0	0	0	$0	$0	0
		4) Records of siting analysis		2	$0	1	2	2	4	0	0	$262	$0	0
		5) Records of persons who have reviewed operating procedures		2	$0	1	2	0	0	0	0	$0	$0	0
		6) Records of persons who have completed operator training		2	$0	1	2	0	0	0	0	$0	$0	0
		7) Records of persons who meet operator qualification criteria		2	$0	1	2	0	0	0	0	$0	$0	0
		8) Records of monitoring device calibration		2	$0		#VALUE!	0	#VALUE!	#VALUE!	#VALUE!	$0	#VALUE!	0
		9) Records of site-specific documentation		24	$0	1	24	0	0	0	0	$0	$0	0
	F. Personnel Training			Incl. in 3.B
	G. Time for Audits			N/A
Recordkeeping Subtotal									6	#VALUE!	0.6	$392	#VALUE!	0
TOTAL:									1,100	55	110	$71,916	$285,220	15
										Total Hours	Labor	Non-Labor	Total
							Summary of Respondent Burden			1,265	$71,916	$285,220	$357,136
							Initial Capital and Startup					$454,092
							Annualized Capital/Start-up and O & M					$285,220
FOOTNOTES
a	One-time only costs.
b	Cost incurred by a facility regardless of the number of affected units at the plant.
c	Annual cost. Annual costs are not incurred until the second year of operation.
d	Based on the sum of the total capital costs for each monitoring system required for incinerators.
e	Based on the sum of the annualized capital costs for each monitoring system required for incinerators.
f	Assumed that none of the facilities will petition for site-specific parameters.
g	Assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. Assumed that this required only two corrective action summaries.
h	Assumed that 10 percent of the facilities would have an exceedance during the year.
i	Assumed $100 for puchase of filing cabinet to house copy of rule, records and report copies.
j	Facilities may test every three years if certain requirements are met, thus annual testing is divided by three to give a per year cost. It is assumed most facilities would meet the requirements.

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Sheet 2: Table 2

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 2
				(A)		(B)	(C)	(D)	(E)	(F)	(G)				Footnotes
				Respondent	Non-Labor	Number of	Hours	Number of	Technical	Management	Clerical	Total	Total	Total
				Hours per	Costs	Occurrences	Per	Respondents	Hours	Hours	Hours	Labor Costs	Non-Labor	Responses
				Occurrence	Per	Per	Respondent	Per Year	Per Year	Per Year	Per Year	Per Year	Costs	Per Year
				(Technical	Occurrence	Respondent	Per Year						Per Year
Burden Item				hours)		Per Year	(C=A x B)		(CXD)	(E x 0.05)	(E x 0.1)
1.	Applications			N/A
2.	Surveys and Studies			N/A
3.	Reporting Requirements
	A.	Read and Understand Rule Requirements		40	$0	1	40	0	0	0	0	$0	$0	0	a,b,i
	B.	Required Activities
		1) Initial stack test and report		40	$61,350	1	40	0	0	0	0	$0	$0	0	a
		2) Annual stack test and test report		40	$21,350	1	40	2	80	4	8	$5,230	$42,700	0	c,j
		3) Operator training and qualification
			a) Establish and teach operator qualification course	64	$0	1	64	0	0	0	0	$0	$0	0	a,b
			b) Obtain operator qualification	72	$0	1	72	0	0	0	0	$0	$0	0	a,b
			c) Annual refresher course	12	$0	1	12	2	24	1	2	$1,569	$0	0	c
			d) Initial review of site-specific information	Incl. in a.
			e) Annual review of site-specific information	8	$0	1	8	2	16	1	2	$1,046	$0	0	c
		4) Establish operating parameters (maximum and minimum)		40	$0	1	40	0	0	0	0	$0	$0	0	a
		5) Continuous parameter monitoring (including CEMS)
			a) Initial capital costs	0	$0	1	0	0	0	0	0	$0	$0	0	a,d
			b) Annualized capital and O&M costs	11	$81,160	1	11	2	22	1	2	$1,438	$162,320	0	c,e
	C.	Create Information		Incl. in 3.B
	D.	Gather Information		Incl. in 3.E
	E.	Report Preparation
		1) Notification of construction (includes siting analysis)		160	$0	1	160	0	0	0	0	$0	$0	0	a
		2) Notification of start-up (includes monitoring plan)		40	$0	1	40	0	0	0	0	$0	$0	0
		3) Notification of initial performance test		2	$0	1	2	0	0	0	0	$0	$0	0
		4) Notification of initial CMS Demonstration		2	$0	1	2	0	0	0	0	$0	$0	0	b
		5) Initial Compliance Report		40	$0	1	40	0	0	0	0	$0	$0	0
		6) Annual Compliance Report		40	$0	1	40	2	80	4	8	$5,230	$0	2
		7) Status report for operators that are off-site for more than 2 weeks		8	$0	1	8	1	8	0	1	$523	$0	1	g
		8) Corrective action summary for operators that are off-site
			for more than 2 weeks	8	$0	2	16	1	16	1	2	$1,046	$0	2	g
		9) Semiannual Deviation Report		24	$0	2	48	1	48	2	5	$3,138	$0	2	h
ReportingSubtotal									294	15	29	$19,221	$205,020	7
4. Recordkeeping Requirements
	A. Read Instructions			Incl. in 3.A
	B. Plan Activities			N/A
	C. Implement Activities			N/A
	D. Develop Record System			N/A
	E. Record Information														g
		1) Records of operating parameters		2	$0	52	104	0	0	0	0	$0	$0	0
		2) Records of exceedances of the operating parameters		2	$0	1	2	1	2	0	0	$131	$0	0
		3) Records of stack tests		2	$0	1	2	2	4	0	0	$262	$0	0
		4) Records of siting analysis		2	$0	1	2	0	0	0	0	$0	$0	0
		5) Records of persons who have reviewed operating procedures		2	$0	1	2	2	4	0	0	$262	$0	0
		6) Records of persons who have completed operator training		2	$0	1	2	2	4	0	0	$262	$0	0
		7) Records of persons who meet operator qualification criteria		2	$0	1	2	2	4	0	0	$262	$0	0
		8) Records of monitoring device calibration		2	$0	1	2	2	4	0	0	$262	$0	0
		9) Records of site-specific documentation		24	$0	1	24	2	48	2	5	$3,138	$0	0
	F. Personnel Training			Incl. in 3.B
	G. Time for Audits			N/A
Recordkeeping Subtotal									70	3.5	7	$4,576	$0	0
TOTAL:									364	18	36	$23,798	$205,020	7
										Total Hours	Labor	Non-Labor	Total
							Summary of Respondent Burden			419	$23,798	$205,020	$228,818
							Initial Capital and Startup					$0
							Annualized Capital/Start-up and O & M					$205,020
FOOTNOTES
a	One-time only costs.
b	Cost incurred by a facility regardless of the number of affected units at the plant.
c	Annual cost. Annual costs are not incurred until the second year of operation.
d	Based on the sum of the total capital costs for each monitoring system required for incinerators.
e	Based on the sum of the annualized capital costs for each monitoring system required for incinerators.
f	Assumed that none of the facilities will petition for site-specific parameters.
g	Assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. Assumed that this required only two corrective action summaries.
h	Assumed that 10 percent of the facilities would have an exceedance during the year.
i	Assumed $100 for puchase of filing cabinet to house copy of rule, records and report copies.
j	Facilities may test every three years if certain requirements are met, thus annual testing is divided by three to give a per year cost. It is assumed most facilities would meet the requirements.

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Sheet 3: Table 3

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 3
				(A)		(B)	(C)	(D)	(E)	(F)	(G)				Footnotes
				Respondent	Non-Labor	Number of	Hours	Number of	Technical	Management	Clerical	Total	Total	Total
				Hours per	Costs	Occurrences	Per	Respondents	Hours	Hours	Hours	Labor Costs	Non-Labor	Responses
				Occurrence	Per	Per	Respondent	Per Year	Per Year	Per Year	Per Year	Per Year	Costs	Per Year
				(Technical	Occurrence	Respondent	Per Year						Per Year
Burden Item				hours)		Per Year	(C=A x B)		(CXD)	(E x 0.05)	(E x 0.1)
1.	Applications			N/A
2.	Surveys and Studies			N/A
3.	Reporting Requirements
	A.	Read and Understand Rule Requirements		40	$0	1	40	0	0	0	0	$0	$0	0	a,b,i
	B.	Required Activities
		1) Initial stack test and report		40	$61,350	1	40	0	0	0	0	$0	$0	0	a
		2) Annual stack test and test report		40	$21,350	1	40	2	80	4	8	$5,230	$42,700	0	c,j
		3) Operator training and qualification
			a) Establish and teach operator qualification course	64	$0	1	64	0	0	0	0	$0	$0	0	a,b
			b) Obtain operator qualification	72	$0	1	72	0	0	0	0	$0	$0	0	a,b
			c) Annual refresher course	12	$0	1	12	2	24	1	2	$1,569	$0	0	c
			d) Initial review of site-specific information	Incl. in a.
			e) Annual review of site-specific information	8	$0	1	8	2	16	1	2	$1,046	$0	0	c
		4) Establish operating parameters (maximum and minimum)		40	$0	1	40	0	0	0	0	$0	$0	0	a
		5) Continuous parameter monitoring (including CEMS)
			a) Initial capital costs	0	$0	1	0	0	0	0	0	$0	$0	0	a,d
			b) Annualized capital and O&M costs	11	$81,160	1	11	2	22	1	2	$1,438	$162,320	0	c,e
	C.	Create Information		Incl. in 3.B
	D.	Gather Information		Incl. in 3.E
	E.	Report Preparation
		1) Notification of construction (includes siting analysis)		160	$0	1	160	0	0	0	0	$0	$0	0	a
		2) Notification of start-up (includes monitoring plan)		40	$0	1	40	0	0	0	0	$0	$0	0
		3) Notification of initial performance test		2	$0	1	2	0	0	0	0	$0	$0	0
		4) Notification of initial CMS Demonstration		2	$0	1	2	0	0	0	0	$0	$0	0	b
		5) Initial Compliance Report		40	$0	1	40	0	0	0	0	$0	$0	0
		6) Annual Compliance Report		40	$0	1	40	2	80	4	8	$5,230	$0	2
		7) Status report for operators that are off-site for more than 2 weeks		8	$0	1	8	1	8	0	1	$523	$0	1	g
		8) Corrective action summary for operators that are off-site
			for more than 2 weeks	8	$0	2	16	1	16	1	2	$1,046	$0	2	g
		9) Semiannual Deviation Report		24	$0	2	48	1	48	2	5	$3,138	$0	2	h
ReportingSubtotal									294	15	29	$19,221	$205,020	7
4. Recordkeeping Requirements
	A. Read Instructions			Incl. in 3.A
	B. Plan Activities			N/A
	C. Implement Activities			N/A
	D. Develop Record System			N/A
	E. Record Information														g
		1) Records of operating parameters		2	$0	52	104	0	0	0	0	$0	$0	0
		2) Records of exceedances of the operating parameters		2	$0	1	2	1	2	0	0	$131	$0	0
		3) Records of stack tests		2	$0	1	2	2	4	0	0	$262	$0	0
		4) Records of siting analysis		2	$0	1	2	0	0	0	0	$0	$0	0
		5) Records of persons who have reviewed operating procedures		2	$0	1	2	2	4	0	0	$262	$0	0
		6) Records of persons who have completed operator training		2	$0	1	2	2	4	0	0	$262	$0	0
		7) Records of persons who meet operator qualification criteria		2	$0	1	2	2	4	0	0	$262	$0	0
		8) Records of monitoring device calibration		2	$0	1	2	2	4	0	0	$262	$0	0
		9) Records of site-specific documentation		24	$0	1	24	2	48	2	5	$3,138	$0	0
	F. Personnel Training			Incl. in 3.B
	G. Time for Audits			N/A
Recordkeeping Subtotal									70	3.5	7	$4,576	$0	0
TOTAL:									364	18	36	$23,798	$205,020	7
										Total Hours	Labor	Non-Labor	Total
							Summary of Respondent Burden			419	$23,798	$205,020	$228,818
							Initial Capital and Startup					$0
							Annualized Capital/Start-up and O & M					$205,020
FOOTNOTES
a	One-time only costs.
b	Cost incurred by a facility regardless of the number of affected units at the plant.
c	Annual cost. Annual costs are not incurred until the second year of operation.
d	Based on the sum of the total capital costs for each monitoring system required for incinerators.
e	Based on the sum of the annualized capital costs for each monitoring system required for incinerators.
f	Assumed that none of the facilities will petition for site-specific parameters.
g	Assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. Assumed that this required only two corrective action summaries.
h	Assumed that 10 percent of the facilities would have an exceedance during the year.
i	Assumed $100 for puchase of filing cabinet to house copy of rule, records and report copies.
j	Facilities may test every three years if certain requirements are met, thus annual testing is divided by three to give a per year cost. It is assumed most facilities would meet the requirements.

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Sheet 4: Table 4 (Industry Summary)

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor (Annualized Capital/Startup and O&M) Costs	Total Costs
1	1,100	55	110	1,265	$71,916	$285,220	$357,136
2	364	18	36	419	$23,798	$205,020	$228,818
3	364	18	36	419	$23,798	$205,020	$228,818
Total	1,828	91	183	2,102	$119,511	$695,260	$814,771
Average	609	30	61	701	$39,837	$231,753	$271,590
																							Recordkeeping hours	reporting hours	total
																						total	168	1934	2102
																						average	56	645	701
																							Responses
																						total	29		72	hrs/response
																						average	9.7

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Sheet 5: Table 5

Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 1
					(A)		(B)	(C)	(D)	(E)	(F)
Burden Item					Number of Occurrences Per Year		EPA Hours Per Occurrence	Tech Hours Per Year (C=AxB)	Management Hours Per Year (D=Cx0.05)	Clerical Hours Per Year (E=Cx0.1)	EPA Cost Per Year
1.	Applications				not applicable
2.	Read and Understand Rule Requirements				2	a	40	80	4	8	$4,146
3.	Required Activities
	A.	Observe stack tests			1	b	48	48	2	5	$2,487
	B.	Excess emissions -- Enforcement Activities			1		24	24	1	2	$1,244
	C.	Create Information			not applicable
	D.	Gather Information			not applicable
	E.	Report Reviews
		1)	Review initial notifications		4	d	40	160	8	16	$8,292
		2)	Review initial compliance report		2		40	80	4	8	$4,146
		3)	Review annual compliance report		0		8	0	0	0	$0
		4)	Review semi-annual excess emission and parameter exceedance report		2		16	32	2	3	$1,658
		5)	Review status reports and corrective action summary for operators off-site		2		4	8	0	1	$415
	F.	Prepare annual summary report			1	c	16	16	1	2	$829
5.	Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =								$881	per trip	$881
	TOTAL							448	22	45	$24,098
FOOTNOTES
a	Since assuming two new units, assume they would be in separate states which would read the rule.
b	Assumes EPA personnel attend 20 percent of the stack tests.
c	Using four hours per state to write annual summary report.
d	Includes notification of contruction and notification of start-up for new units.

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Sheet 6: Table 6

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 2
					(A)		(B)	(C)	(D)	(E)	(F)
Burden Item					Number of Occurrences Per Year		EPA Hours Per Occurrence	Tech Hours Per Year (C=AxB)	Management Hours Per Year (D=Cx0.05)	Clerical Hours Per Year (E=Cx0.1)	EPA Cost Per Year (a,b)
1.	Applications				not applicable
2.	Read and Understand Rule Requirements				0		16	0	0	0	$0
3.	Required Activities
	A.	Observe stack tests			1	b	48	48	2	5	$2,487
	B.	Excess emissions -- Enforcement Activities			1		24	24	1	2	$1,244
	C.	Create Information			not applicable
	D.	Gather Information			not applicable
	E.	Report Reviews
		1)	Review initial notifications		0		40	0	0	0	$0
		2)	Review initial compliance report		0		40	0	0	0	$0
		3)	Review annual compliance report		2		8	16	1	2	$829
		4)	Review semi-annual excess emission and parameter exceedance report		2		16	32	2	3	$1,658
		5)	Review status reports and corrective action summary for operators off-site		2		4	8	0	1	$415
	F.	Prepare annual summary report			1	c	8	8	0	1	$415
5.	Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =								$881	per trip	$881
	TOTAL							136	7	14	$7,929
FOOTNOTES
a	Figures may not add exactly due to rounding.
b	Assumes EPA personnel attend 20 percent of the stack tests.
c	Using four hours per state to write annual summary report.

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Sheet 7: Table 7

Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 3
					(A)		(B)	(C)	(D)	(E)	(F)
Burden Item					Number of Occurrences Per Year		EPA Hours Per Occurrence	Tech Hours Per Year (C=AxB)	Management Hours Per Year (D=Cx0.05)	Clerical Hours Per Year (E=Cx0.1)	EPA Cost Per Year (a,b)
1.	Applications				not applicable
2.	Read and Understand Rule Requirements				0		16	0	0	0	$0
3.	Required Activities
	A.	Observe stack tests			1	b	48	48	2	5	$2,487
	B.	Excess emissions -- Enforcement Activities			1		24	24	1	2	$1,244
	C.	Create Information			not applicable
	D.	Gather Information			not applicable
	E.	Report Reviews
		1)	Review initial notifications		0		40	0	0	0	$0
		2)	Review initial compliance report		0		40	0	0	0	$0
		3)	Review annual compliance report		2		8	16	1	2	$829
		4)	Review semi-annual excess emission and parameter exceedance report		2		16	32	2	3	$1,658
		5)	Review status reports and corrective action summary for operators off-site		2		4	8	0	1	$415
	F.	Prepare annual summary report			1	c	8	8	0	1	$415
5.	Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =								$881	per trip	$881
	TOTAL							136	7	14	$7,929
FOOTNOTES
a	Figures may not add exactly due to rounding.
b	Assumes EPA personnel attend 20 percent of the stack tests.
c	Using four hours per state to write annual summary report.

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Sheet 8: Table 8

Table 8 - Summary of Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	448	22	45	515	$24,098	$0	$24,098
2	136	7	14	156	$7,929	$0	$7,929
3	136	7	14	156	$7,929	$0	$7,929
Total	720	36	72	828	$39,956	$0	$39,956
Average	240	12	24	276	$13,319	$0	$13,319