| Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal) |
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103.97 |
129.93 |
51.79 |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year (C=AxB) |
Respondents per year a |
Technical person- hours per year (E=CxD) |
Management person hours per year (Ex0.05) |
Clerical person hours per year (Ex0.1) |
Total Cost Per year b |
| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting requirements |
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| A. Read and understand rule requirement c |
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| New sources |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| Existing sources |
1 |
1 |
1 |
99 |
99 |
4.95 |
9.9 |
$11,448.90 |
| B. Required activities |
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| 1) Initial performance test and reports |
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| a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) c, d |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
| b) Repeat of initial performance tests d, e |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
| 2) CEMS demonstration (CO, 02) |
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| a) Repeat of initial demonstration e |
229 |
1 |
229 |
0 |
0 |
0 |
0 |
$0 |
| 3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) |
24 |
1 |
24 |
99 |
2376 |
118.8 |
237.6 |
$274,773.71 |
| 4) Quarterly Appendix F audits of CEMS (CO) |
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| a) RATA audit (one per year) f |
4 |
1 |
4 |
99 |
396 |
19.8 |
39.6 |
$45,795.62 |
| b) RAA audit (three per year) f |
4 |
3 |
12 |
99 |
1188 |
59.4 |
118.8 |
$137,386.85 |
| c) Daily calibration and operation f, g |
1 |
250 |
250 |
99 |
24750 |
1237.5 |
2475 |
$2,862,226.13 |
| C. Create information |
See 3B |
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| D. Gather information |
See 3E |
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| E. Report preparation |
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| 1) Contract or secure alternative means of disposal d |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| 2) Notification of final compliance c, d |
1.5 |
1 |
1.5 |
0 |
0 |
0 |
0 |
$0 |
| 3) Initial compliance report c, d |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| 4) Waste management plan c, d |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| 5) Annual compliance reports |
40 |
1 |
40 |
99 |
3960 |
198 |
396 |
$457,956.18 |
| 6) Semiannual deviation reports |
24 |
2 |
48 |
99 |
4752 |
237.6 |
475.2 |
$549,547.42 |
| Subtotal for Reporting Requirements |
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43,149 |
$4,339,135 |
| 4. Recordkeeping requirements |
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| A. Read and understand rule requirement |
See 3A |
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| B. Plan activities |
See 3B |
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| C. Implement Activities |
See 3B |
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| D. Develop record system |
N/A |
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| E. Record information |
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| 1) Records of SSM h |
1.5 |
52 |
78 |
99 |
7722 |
386.1 |
772.2 |
$893,014.55 |
| 2) Records of emission rate computations, all emission exceedances and periods when there is no data h |
1.5 |
52 |
78 |
99 |
7722 |
386.1 |
772.2 |
$893,014.55 |
| 3) Records of employee review of operations manual |
4 |
1 |
4 |
99 |
396 |
19.8 |
39.6 |
$45,795.62 |
| 4) Record of control devices operating parameters h |
1.5 |
52 |
78 |
99 |
7722 |
386.1 |
772.2 |
$893,014.55 |
| F. Personnel training |
N/A |
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| G. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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27,096 |
$2,724,839 |
| TOTAL LABOR BURDEN AND COST (rounded†) |
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70,200 |
$7,060,000 |
| Total Capital/O&M Costs (rounded†) |
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$495,000 |
| Grand Total (Labor and Capital/O&M Costs) (rounded†) |
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$7,560,000 |
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| Assumptions: |
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236 |
hr/resp |
| a We have assumed that there are approximately 99 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. |
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| b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 “Table 2: Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. |
| c We assume existing sources will take one hour to re-familiarize with rule requirements. |
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DWang:
Original footnote d: "This is the fifth year when a respondent will have reached the compliant date for the emission guidelines."
Table 1 in the regs say:
The final compliance date can be no later than 3 years after the effective date of State plan approval or December 16, 2010, whichever is earlier.
d We have assumed that all respondents have achieved final compliance for the emission guidelines. |
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| e We have assumed that 20 percent of respondents will repeat initial tests due to failure. |
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| f We have assumed that RATA audits are performed for one of the four quarterly audits, and RAA tests are performed for three of the four quarterly audits. |
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| g We have assumed that each operation day requires a CEMS calibration; Combustor models 2, 3, and 4 assume 250 days of operation per year, Model 1 = 121 days/yr. For consistency, 250 operating days are assumed for all models. Emission testing hours (0.25 hr/occurrence) accounts for periodic contractor operation and maintenance support. Annual hours averaged to a daily basis. |
| h We have assumed that each respondent will record information 52 times per year. |
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| † Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal) |
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46.67 |
62.9 |
25.25 |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| EPA person- hours per occurrence |
No. of occurrences per plant per year |
EPA person- hours per plant per year (C=AxB) |
Plants per year a |
Technical person- hours per year (E=CxD) |
Management person-hours per year (Ex0.05) |
Clerical person-hours per year (Ex0.1) |
Cost, $ b |
| 1. Applications |
N/A |
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| 2. Read and understand rule requirements |
ERG:
Previously 16 EPA person-hr per occurrence. The burden will depend on the number of EPA personnel, not the number of plants. For this renewal, we assume existing EPA staff are familiar with the rule they work on, and will not need to re-familiarize themselves with the reg. requirement every year. (consistent with prev. ICR, which had 0 burden hours for this item)
N/A |
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| 3. Required activities |
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| A. Create information |
N/A |
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| B. Gather information |
DWang:
This used to say "See 3A & 3F" but there is no 3F.
See 3A |
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| C. Report reviews |
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| 1) Notification of final compliance c |
1.5 |
1 |
1.5 |
0 |
0 |
0 |
0 |
$0 |
| 2) Review initial compliance test report c |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| 3) Review annual compliance report |
40 |
1 |
40 |
99 |
3960 |
198 |
396 |
$207,266.40 |
| 4) Review semiannual deviation reports |
16 |
2 |
32 |
99 |
3168 |
158.4 |
316.8 |
$165,813.12 |
| 5) Review waste management plan c |
16 |
1 |
16 |
0 |
0 |
0 |
0 |
$0 |
| D. Annual summary report d |
4 |
1 |
4 |
99 |
396 |
19.8 |
39.6 |
$20,726.64 |
| TOTAL ANNUAL BURDEN AND COST (rounded) |
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8,650 |
$394,000 |
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| Assumptions: |
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DWang:
I added the last sentence. Instead of that sentence, this footnote used to say "For the purpose of the burden calculation, we are averaging the number of respondents over the three years period of this ICR. In year two and three of this ICR all respondents will have reached the compliant date for the emission guidelines, which is five years after promulgation."
a We have assumed that there are approximately 99 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. We assume that all respondents have achieved final compliance for the emission guidelines. |
| b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for Managerial (GS-13, Step 5, $39.31 + 60%), $46.21 for Technical (GS-12, Step 1, $29.17 + 60%) and $25.25 Clerical (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM), 2014 General Schedule, which excludes locality rates of pay. |
| c We have assumed that this is a one-time only cost. |
| d We have assumed that all affected facilities in the states will be required to prepare an annual summary plan. |
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DWang:
I am going to delete this because "Designated Administrator" does not show up anywhere in the table or assumpations.
Designated Administrator refers to the person indicated by each State plan as the compliance authority or to the USEPA Administrator in the event that a Federal plan must be developed. |
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| † Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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