SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
1. Identification of the Information Collection
1(a) Title of the Information Collection
Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal), EPA ICR Number 1847.07, OMB Control Number 2060-0390.
1(b) Short Characterization/Abstract
The Emission Guidelines for Large Municipal Waste Combustors (40 CFR Part 60, Subpart Cb) were proposed on September 20, 1994, promulgated on December 19, 1995, and amended on both August 25, 1997, and May 10, 2006. These regulations apply to existing facilities constructed on or before September 20, 1994, that own and operate municipal waste combustion (MWC) units with a combustion capacity greater than 250 tons per day of municipal solid waste (large MWC units). The reporting and recordkeeping requirements discussed below result from the emission guidelines that apply to large MWCs covered by EPA-approved and effective State plans and, where a State plan has not been approved, large MWCs covered by the Federal plan. This information is being collected to assure compliance with 40 CFR part 60, subpart Cb.
In general, all Emission Guidelines require initial notification reports, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to Emission Guidelines.
Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority. In the event that there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.
The “Affected Public” includes MWC units that are owned by the private sector, MWC units that are owned by state and local government, as well as State Administrators. The “burden” to the Affected Public may be found below in Table 1a: Annual Privately-Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal), and in Table 1b: Annual Publicly Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal). The “burden” to the “Designated State Administrator” is attributed entirely to work performed by either the state, or local, or tribal air pollution authority employees or government contractors and may be found below in Table 1c: Average Annual Designated Administrator Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal). The “burden” to the Federal Government is attributed entirely to work performed by either Federal employees or by government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
There are 162 large MWC units located at 63 MWC plants (respondents) in 22 States subject to the emission guidelines through either State or the Federal plans. Of the 63 large MWC plants, 55 plants are located in 18 states with State plans; eight plants are located in 4 states without State plans and are thus subject to the Federal plan. There are approximately 31 large MWC plant (49%), which are owned and operated by the MWC industry. Approximately 32 large MWC plants (51%) in the United States are owned by either state, local, tribal or the Federal government. In addition to the 63 large MWC plants, it is estimated that there are 18 State Designated Administrators. We assume that they will all respond.
Based on our consultations with industry representatives, there are an average of 2.57 affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).
Over the next three years, approximately 81 respondents per year (63 MWC plants and 18 Designated Administrators) will be subject to these standard, and no additional respondents per year will become subject to the standard. The Emission Guidelines only apply to sources constructed on or before September 20, 1994.
The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.”
2. Need for and Use of the Collection
2(a) Need/Authority for the Collection
The EPA is charged under section 111(d)(1) of the Clean Air Act (CAA), as
amended, to:
. . . prescribe regulations which shall establish a procedure similar to that provided by section 110 under which each State shall submit to the Administrator a plan which (A) establishes standards of performance for any existing source for any air pollutant (i) for which air quality criteria have not been issued or which is not included on a list published under section 108(a) . . . but (ii) to which a standard of performance under this section would apply if such existing source were a new source, and (B) provides for the implementation and enforcement of such standards of performance.
The EPA is required under section 129 of the Act, to establish guidelines for existing stationary sources that reflect the maximum achievable control technology (MACT) for achieving continuous emission reductions:
Section 129(a)(1)(A) states:
The Administrator shall establish performance standards and other requirements pursuant to section 111 and this section for each category of solid waste incineration units. Such standards shall include emissions limitations and other requirements applicable to new units and guidelines (under section 111(d) and this section) and other requirements applicable to existing units.
Section 129(a)(2) states:
Standards applicable to solid waste incineration units promulgated under section 111 and this section shall reflect the maximum degree of reduction in emissions of air pollutants listed under section (a)(4) that the Administrator, taking into consideration the cost of achieving such emission reduction, and any non-air quality health and environmental impacts and energy requirements, determines is achievable for new or existing units in each category.
Section 129(b)(1) states:
Performance standards under this section and section 111 for solid waste incineration units shall include guidelines promulgated pursuant to section 111(d) and this section applicable to existing units. Such guidelines shall include, as provided in this section, each of the elements required by subsection (a) (emissions limitations, notwithstanding any restriction in section 111(d) regarding issuance of such limitations), subsection (c) (monitoring), subsection (d) (operator training), subsection (e) (permits), and subsection (h)(4) (residual risk).
Subpart B of 40 CFR Part 60 requires State plans to include monitoring, recordkeeping, and reporting provisions consistent with the emission guidelines. In addition, section 114(a)(1) states that:
the Administrator may require any person who owns or operates any emission source, who manufactures emission control equipment or process equipment, who the Administrator believes may have information necessary for the purposes set forth in this subsection, or who is subject to any requirement of this Act (other than a manufacturer subject to the provisions of section 206(c) or 208 with respect to a provision of title II) on a one-time, periodic or continuous basis to -
(A) establish and maintain such records;
(B) make such reports;
(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods;
(D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods and in such manner as the Administer shall prescribe);
(E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical;
(F) submit compliance certifications in accordance with section 114(a)(3); and
(G) provide such other information, as the Administrator may reasonably require; . . . .
In the Administrator's judgment, particulate matter, opacity, sulfur dioxide, hydrogen chloride, oxides of nitrogen, carbon monoxide, lead, cadmium, mercury, and dioxins and dibenzofurans emissions from MWCs cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the Emission Guidelines were promulgated for this source category at 40 CFR Part 60, Subpart Cb.
2(b) Practical Utility/Users of the Data
The recordkeeping and reporting requirements in the standards ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.
Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standards. Continuous emission monitors are used to ensure compliance with the standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.
The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated and/or leaks are being detected and repaired and the standard are being met. The performance test may also be observed.
The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.
3. Non-duplication, Consultations, and Other Collection Criteria
The requested recordkeeping and reporting are required under 40 CFR Part 60, Subpart Cb.
3(a) Non-duplication
If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist.
3(b) Public Notice Required Prior to ICR Submission to OMB
An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (80 FR 32116) on June 5, 2015. No comments were received on the burden published in the Federal Register.
3(c) Consultations
The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts.
Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standards as they were being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted: 1) the Solid Waste Association of North America (SWANA), at (800) 467-9262; 2) the National Waste & Recycling Association (NWRA), at (202) 244-4700; and 3) Covanta, at (862) 345-5000.
It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.
3(d) Effects of Less Frequent Collection
Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.
3(e) General Guidelines
These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.
These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.
3(f) Confidentiality
Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).
3(g) Sensitive Questions
The reporting or recordkeeping requirements in the standard do not include sensitive questions.
4. The Respondents and the Information Requested
4(a) Respondents/SIC Codes
The respondents to the recordkeeping and reporting requirements are owners and operators of large MWC units. The United States Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) codes for large MWC units are provided in the following table:
Standard (40 CFR Part 60, Subpart Cb) |
SIC Codes |
NAICS Codes |
Air and Water Resource and Solid Waste Management |
9511 |
92411 |
Refuse System; Solid Waste Combustors and Incinerators |
4953 |
562213 |
4(b) Information Requested
(i) Data Items
In this ICR, all the data that is recorded or reported is required by the Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb).
State/US protectorates must perform the following requirements:
Requirement |
|
Submit a state plan |
60.39b(b), 60.23(a) |
Notification of public hearing on State Plan |
60.23(d) |
Certification that public hearing on State Plan conducted according to part 60 Subpart B State procedures |
60.23(f) |
Negative Declaration, if applicable |
62.06 |
A source must make the following reports:
Notifications |
|
Notification of completion of each increment of progress, including final control plan |
60.39b(c)(1)(i) |
Notification of exemptions |
60.32b(b)(1), (d), (e), (f)(1), (i)(1) |
Notification of initial performance tests (PM, dioxin/furan, opacity, HCl, Cd, Pb, Hg, fugitives) |
60.8(d) |
Notification of starting or stopping use of the particulate matter, cadmium, lead, mercury, hydrogen chloride, and dioxin/furan continuous emission monitoring systems or continuous automated sampling systems. |
60.59b(m) |
Reports |
|
Report initial performance tests for all regulated pollutants and parameters |
60.59b(f), |
Report of Continuous Emissions Monitoring System (CEMS) demonstration and test data |
60.59b(f)(3) |
Annual compliance reports for all pollutants and parameters |
60.59b(g) |
Air Curtain incinerator records |
60.59b(i) |
Semiannual excess emission reports (SO2, CO, load, temperature, PM, dioxin/furan, opacity, HCl, Cd, Pb, Hg, fugitives) |
60.59b(h) |
A source must keep the following records:
Recordkeeping |
|
Records of public hearing conducted on State Plan |
60.23(e) |
Records of calendar date of each record |
60.59b(d)(1) |
Records of CEMS concentration rates and parameters and computations of average emissions and parameters |
60.59b(d)(2), (n) |
Records of exceedances, data availability |
60.59b(d)(3), (d)(6), (d)(7), (h) |
Records of activated carbon for Hg and dioxin/furan control |
60.59b(d)(4), (d)(14), (d)(15) |
Records of results of daily CEMS drift tests, and Appendix F accuracy assessments |
60.59b(d)(8), (d)(10) |
Records of initial performance tests and annual performance tests, including final control plan |
60.59b(d)(9), (f), (g), (i) |
Records of the occurrence and duration of any startup, shutdown, or malfunction of the facility or any malfunction of the CEM |
60.59b(d), (n), (o) |
Records of operator training, availability and corrective action |
60.59b(d)(12) |
Records of names of persons who have completed review of operating manual |
60.59b(d)(13) |
Records of opacity limits for air curtain incinerators burning 100% yard waste |
60.59b(e) |
Records are required to be retained for 5 years at the facility |
60.59b(d), (e), (j) |
Electronic Reporting
Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.
(ii) Respondent Activities
Respondent Activities |
Familiarization with the regulatory requirements. |
Install, calibrate, maintain, and operate continuous emissions monitoring systems for sulfur dioxide, nitrogen oxides, opacity, carbon monoxide, load level, temperature of the fuel gas stream, and oxygen or carbon dioxide. |
Perform initial performance test, applicable Reference Method test, and repeat performance tests if necessary. |
Write the notifications and reports listed above. |
Enter information required to be recorded above. |
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information. |
Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information. |
Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information. |
Train personnel to be able to respond to a collection of information. |
Transmit, or otherwise disclose the information. |
5. The Information Collected: Agency Activities, Collection Methodology, and Information Management
5(a) Agency Activities
EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:
Agency Activities |
Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry. |
Audit facility records. |
Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS. |
5(b) Collection Methodology and Management
Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data.
The records required by this regulation must be retained by the owner/operator for five years.
5(c) Small Entity Flexibility
There are no small entities (i.e., small businesses) affected by this regulation.
5(d) Collection Schedule
The specific frequency for each information collection activity within this request is shown in below Table 1a: Annual Privately Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal), and Table 1b: Annual Publicly Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
6. Estimating the Burden and Cost of the Collection
Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.
The Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number.
6(a) Estimating Respondent Burden
The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 397,000 hours. By individual category, there are: 1) 192,000 hours for privately owned MWCs (Total Labor Hours from Table 1a below); 2) 202,000 hours for publicly owned MWCs (Total Labor Hours from Table 1b below); and 3,080 hours for designated State plan administrators (Total Labor Hours from Table 1c below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the Emission Guidelines, the previously approved ICR, and any comments received.
6(b) Estimating Respondent Costs
(i) Estimating Labor Costs
This ICR uses the following labor rates:
Managerial $129.93 ($61.87+ 110%)
Technical $103.97 ($49.51 + 110%)
Clerical $51.79 ($24.66 + 110%)
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.
Additionally, this ICR assumes a contractor rate of $176.05. The contractor rate was derived by taking the contractor rate in the previous ICR and multiplying by the average increase in managerial, technical, and clerical rates since the previous ICR. The result is a five percent increase in contractor rate since the last ICR. The labor rates for publicly-owned sources and State administrators are detailed in Section 6(c).
(ii) Estimating Capital/Startup and Operation and Maintenance Costs
The type of industry costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs incurred when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.
(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
Capital/Startup vs. Operation and Maintenance (O&M) Costs |
||||||
(A) Continuous Monitoring Device |
(B) Capital/Startup Cost for One Respondent |
(C) Number of New Respondents1 |
(D) Total Capital/Startup Cost, (B X C) |
(E) Annual O&M Costs for One Respondent |
(F) Number of Sources with O&M2 |
(G) Total O&M, (E X F) |
Private sector- Load monitors, temperature monitors, and carbon feed rate monitors. |
$100,000 |
0 |
$0 |
$9,600 |
80 |
$768,000 |
Public sector -Load monitors, temperature monitors, and carbon feed rate monitors. |
$100,000 |
0 |
$0 |
$9,600 |
82 |
$787,200 |
Total |
|
0 |
$0 |
|
162 |
$1,560,000 |
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
1 Since the Emission Guidelines only apply to sources that commenced construction on or before September 20, 1994, no additional MWC units will become subject to the standard over the next three years.
2 Approximately 162 sources located at 63 plants are currently subject to the Emissions Guidelines and each source requires continuous monitoring. Of the 162 sources, 80 sources are within the private sector and 82 sources are publicly-owned.
The total capital/startup costs for this ICR are $0. This is the total of column D in the above table.
The total operation and maintenance (O&M) costs for this ICR are $1,560,000. This is the total of column G.
The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $1,560,000. These are recordkeeping costs.
6(c) Estimating Agency Burden and Cost
The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.
The average annual Agency cost during the three years of the ICR is estimated to be $20,100.
This cost is based on the average hourly labor rate as follows:
Managerial $62.90 (GS-13, Step 5, $39.31 + 60%)
Technical $46.67 (GS-12, Step 1, $29.17 + 60%)
Clerical $25.25 (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. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
6(d) Estimating the Respondent Universe and Total Burden and Costs
Based on our research for this ICR, on average over the next three years, approximately 81 existing respondents will be subject to these standards. The estimate includes 63 MWC plants and 18 State Designated Administrators. It is estimated that no additional respondents per year will become subject. The overall average number of respondents, as shown in the table below, is 81 per year.
The number of respondents is calculated using the following table that addresses the three years covered by this ICR.
Number of Respondents |
|||||
|
Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports |
|
||
Year |
(A) Number of New Respondents 1 |
(B) Number of Existing Respondents2 |
(C) Number of Existing Respondents that keep records but do not submit reports |
(D) Number of Existing Respondents That Are Also New Respondents |
(E) Number of Respondents (E=A+B+C-D) |
1 |
0 |
81 |
0 |
0 |
81 |
2 |
0 |
81 |
0 |
0 |
81 |
3 |
0 |
81 |
0 |
0 |
81 |
Average |
0 |
81 |
0 |
0 |
81 |
1 New respondents include sources with constructed, reconstructed and modified affected facilities.
2An average of 63 large MWC plants (respondents) will be subject to the standards over the next three years. Approximately 31 respondents are privately-owned and 32 respondents are publicly-owned. Additionally, it is estimated there will 18 State Designated Administrators. Total number of respondents = (63 + 18) = 81.
Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is 81.
The total number of annual responses per year is calculated using the following table:
Total Annual Responses |
||||
(A) Information Collection Activity |
(B) Number of Respondents |
(C) Number of Responses |
(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports |
(E) Total Annual Responses E=(BxC)+D |
Privately owned large MWCs |
||||
Increments of Progress (Plant Control Plan, notifications, etc.) |
0 |
3 |
0 |
0 |
Initial Testing Notifications and Reports (Performance Test, CEMS Demonstration, etc. |
0 |
4 |
0 |
0 |
Annual Performance Tests and Reports |
31 |
1 |
0 |
31 |
Annual Compliance Reports |
31 |
1 |
0 |
31 |
Semiannual Excess Emission Reports |
6 |
2 |
0 |
12 |
|
|
|
Total |
74 |
Publicly owned large MWCs |
||||
Increments of Progress (Plant Control Plan, notifications, etc.) |
0 |
3 |
0 |
0 |
Initial Testing Notifications and Reports (Performance Test, CEMS Demonstration, etc. |
0 |
4 |
0 |
0 |
Annual Performance Tests and Reports |
32 |
1 |
0 |
32 |
Annual Compliance Reports |
32 |
1 |
0 |
32 |
Semiannual Excess Emission Reports |
7 |
2 |
0 |
14 |
|
|
|
Total |
78 |
Designated State Plan Administrators |
||||
Excess Emissions – Enforcement Activities |
11 |
1 |
0 |
11 |
Review Annual Compliance Report |
55 |
1 |
0 |
55 |
Review Semiannual Excess Emissions Report |
11 |
1 |
0 |
11 |
|
|
|
Total |
77 |
The combined total of Annual Responses is 229. These individual totals are as follows: 1) 74 for privately-owned MWCs; 2) 78 for publicly-owned MWCs; and 3) 77 for designated State- plan administrators.
The total annual labor costs for privately-owned MWCs are $28,100,000. Details regarding these estimates may be found below in Table 1a: Annual Privately-Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
The total annual labor costs for publicly-owned MWCs are $29,700,000. Details regarding these estimates may be found below in Table 1b: Annual Publicly-Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
The total annual labor costs for designated State plan administrators are $140,000. Details regarding these estimates may be found below in Table 1c: Average Annual Designated- Administrator Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
6(e) Bottom Line Burden Hours and Cost Tables
The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1a, 1b, 1c, and 2, respectively, and summarized below.
(i) Respondent Tally
The total annual labor hours for privately owned MWCs are 192,000 hours. Details regarding these estimates may be found below in Table 1a: Annual Privately Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
The total annual labor hours for publicly owned MWCs are 202,000 hours. Details regarding these estimates may be found below in Table 1b: Annual Publicly Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
The total, annual labor hours for designated State administrator respondents are 3,080 hours. Details regarding these estimates may be found below in Table 1c: Average Annual Designated Administrator Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,734 (rounded) hours per response.
The total annual capital/startup and O&M costs to the regulated entity are $1,560,000. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.
(ii) The Agency Tally
The average annual Agency burden and cost over next three years is estimated to be 442 labor hours at a cost of $20,100. See below in Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).
We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
6(f) Reasons for Change in Burden
There is a small adjustment increase in the respondent labor hours and costs and the total O&M costs as currently identified in the OMB Inventory of Approved Burdens. The increase in labor hours and cost is due to a change in assumption. In this ICR, we assume all existing sources will take some time each year to re-familiarize themselves with the regulatory requirements. The increase in total O&M cost is due to rounding of all calculated values to three significant figures.
6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,734 hours per response. “Burden” means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.
To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OECA-2012-0503. An electronic version of the public docket is available at http://www.regulations.gov/, which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2012-0503 and OMB Control Number 2060-0390 in any correspondence.
Part B of the Supporting Statement
This part is not applicable because no statistical methods were used in collecting this information.
Table 1a: Annual Privately-Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
(I) |
(J) |
1.) Applications |
N/A |
|
|
|
|
|
|
|
|
|
2.) Surveys and Studies |
N/A |
|
|
|
|
|
|
|
|
|
3.) Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
A. Familiarize with Regulatory Requirements c |
40 |
0 |
1 |
40 |
31 |
1,240 |
62 |
124 |
0 |
$143,400.42 |
B. Required Activities |
|
|
|
|
|
|
|
|
|
|
1) Initial performance tests and reports |
|
|
|
|
|
|
|
|
|
|
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) |
24 |
750 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
b) Repeat of Initial performance tests d |
24 |
750 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2) |
|
|
|
|
|
|
|
|
|
|
a) Installation of CEM units |
24 |
200 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
b) Initial demonstration |
24 |
430 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
c) Repeat of initial demonstration d |
24 |
430 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) |
|
|
|
|
|
|
|
|
|
|
a) Plants that do not qualify for reduced D/F testing with 2 units |
24 |
1,500 |
1 |
24 |
1 |
24 |
1.2 |
2.4 |
1,500 |
$266,850.49 |
b) Plants that do not qualify for reduced D/F testing with 3 units |
24 |
2,250 |
1 |
24 |
2 |
48 |
2.4 |
4.8 |
4,500 |
$797,775.98 |
c) Plants that qualify for reduced D/F testing with 2 units |
24 |
1,428 |
1 |
24 |
13 |
312 |
15.6 |
31.2 |
18,564 |
$3,304,273.60 |
d) Plants that qualify for reduced D/F testing with 3 units |
24 |
2,106 |
1 |
24 |
15 |
360 |
18 |
36 |
31,590 |
$5,603,051.88 |
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO) |
|
|
|
|
|
|
|
|
|
|
a) RATA audit (one per year)e |
8 |
350 |
1 |
8 |
80 |
640 |
32 |
64 |
28,000 |
$5,003,413.12 |
b) RAA audit (three per year)e |
8 |
130 |
3 |
24 |
80 |
1,920 |
96 |
192 |
31,200 |
$5,714,799.36 |
c) Daily calibration and operation |
1 |
0 |
365 |
365 |
80 |
29,200 |
1,460 |
2,920 |
0 |
$3,376,848.60 |
C. Create Information |
See 3B |
|
|
|
|
|
|
|
|
|
D. Gather Information |
See 3E |
|
|
|
|
|
|
|
|
|
E. Report Preparation |
|
|
|
|
|
|
|
|
|
|
1) Plant startup |
|
|
|
|
|
|
|
|
|
|
a) Control plan |
40 |
0 |
1 |
40 |
0 |
0 |
0 |
0 |
0 |
$0 |
b) Notification of contract awards |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
c) Notification of on-site construction start |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
d) Notification of construction completion |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
e) Notification of final compliance |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
2) Notification of initial performance tests |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
3) Initial performance tests reports |
40 |
0 |
1 |
40 |
0 |
0 |
0 |
0 |
0 |
$0 |
4) Notification of CEMS demonstration |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
5) Initial CEMS demonstration report |
90 |
0 |
1 |
90 |
0 |
0 |
0 |
0 |
0 |
$0 |
6) Notification of starting or stopping use of the CEMS |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
7) Air Curtain incinerator initial performance tests |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
8) Annual compliance reports |
40 |
0 |
1 |
40 |
31 |
1,240 |
62 |
124 |
0 |
$143,400.42 |
9) Semi-annual excess emission reports f |
40 |
0 |
2 |
80 |
6 |
480 |
24 |
48 |
0 |
$55,509.84 |
10) Notification of exemptions |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
Subtotal for Reporting |
|
|
|
|
|
156,138 |
$24,409,324 |
|||
4.) Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
A. Familiarize with Regulatory Requirements c |
See 3A |
|
|
|
|
|
|
|
|
|
B. Plan activities |
See 3B |
|
|
|
|
|
|
|
|
|
C. Implement activities |
See 3B |
|
|
|
|
|
|
|
|
|
D. Develop record system |
N/A |
|
|
|
|
|
|
|
|
|
E. Record information |
|
|
|
|
|
|
|
|
|
|
1) Record startups, shutdowns, and malfunctions g |
4 |
0 |
47 |
188 |
80 |
15,040 |
752 |
1,504 |
0 |
$1,739,308.32 |
2) Records of all emission rates, computations, tests g |
4 |
0 |
47 |
188 |
80 |
15,040 |
752 |
1,504 |
0 |
$1,739,308.32 |
3) Records of employee review of operations manual |
4 |
0 |
1 |
4 |
31 |
124 |
6.2 |
12.4 |
0 |
$14,340.04 |
4) Record amount of sorbent used for Hg and dioxin/furan control h |
4 |
0 |
4 |
16 |
80 |
1,280 |
64 |
128 |
0 |
$148,026.24 |
5) Records of emission exceedances and periods when emission data not obtained |
See 3E |
|
|
|
|
|
|
|
|
|
6) Records of CEMS drift tests and Appendix F accuracy assessments |
See 4E 1-4 |
|
|
|
|
|
|
|
|
|
7) Records of initial performance test |
See 3E |
|
|
|
|
|
|
|
|
|
8) Records of annual performance tests |
See 3E |
|
|
|
|
|
|
|
|
|
9) Records of opacity limits for air curtain incinerators |
See 3E |
|
|
|
|
|
|
|
|
|
F. Personnel training |
N/A |
|
|
|
|
|
|
|
|
|
G. Time for audits |
N/A |
|
|
|
|
|
|
|
|
|
Subtotal for Recordkeeping |
|
|
|
|
|
36,207 |
$3,640,983 |
|||
TOTAL LABOR BURDEN AND COST (Rounded)i |
|
|
|
|
|
192,000 |
$28,100,000 |
|||
Capital and O&M Cost |
|
|
|
|
|
|
|
|
|
$768,000 |
GRAND TOTAL |
|
|
|
|
|
|
|
|
|
$28,900,000 |
Assumptions:
a. Assume 162 large MWC units at 63 plants, 49 percent of which are privately owned.
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. The contractor rate was derived by taking the contractor rate used in the previous ICR and multiplying by the average increase in managerial, technical, and clerical rates since the previous ICR.
c. This ICR assumes all respondents will have to familiarize with regulatory requirements
d. Assume 20 percent of reporting plants must repeat initial tests due to failure at one unit at the plant.
e. RATA audits are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
f. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
g. Based on weekly recordkeeping, we assume 47 weeks of operation (90 percent availability) per year per MWC.
h. Based on quarterly calculation of sorbent use for entire plant, regardless of the number of affected facilities at the plant.
i. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
Table 1b: Annual Publicly-Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
(I) |
(J) |
1.) Applications |
N/A |
|
|
|
|
|
|
|
|
|
2.) Surveys and Studies |
N/A |
|
|
|
|
|
|
|
|
|
3.) Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
A. Familiarize with Regulatory Requirements c |
40 |
0 |
1 |
40 |
32 |
1,280 |
64 |
128 |
0 |
$148,026.24 |
B. Required Activities |
|
|
|
|
|
|
|
|
|
|
1) Initial performance tests and reports |
|
|
|
|
|
|
|
|
|
|
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) |
24 |
750 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
b) Repeat of Initial performance tests d |
24 |
750 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2) |
|
|
|
|
|
|
|
|
|
|
a) Installation of CEM units |
24 |
200 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
b) Initial demonstration |
24 |
430 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
c) Repeat of initial demonstration d |
24 |
430 |
1 |
24 |
0 |
0 |
0 |
0 |
0 |
$0 |
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) |
|
|
|
|
|
|
|
|
|
|
a) Plants that do not qualify for reduced D/F testing with 2 units |
24 |
1,500 |
1 |
24 |
3 |
72 |
3.6 |
7.2 |
4,500 |
$800,551.48 |
b) Plants that do not qualify for reduced D/F testing with 3 units |
24 |
2,250 |
1 |
24 |
2 |
48 |
2.4 |
4.8 |
4,500 |
$797,775.98 |
c) Plants that qualify for reduced D/F testing with 2 units |
24 |
1,428 |
1 |
24 |
14 |
336 |
16.8 |
33.6 |
19,992 |
$3,558,448.49 |
d) Plants that qualify for reduced D/F testing with 3 units |
24 |
2,106 |
1 |
24 |
16 |
384 |
19.2 |
38.4 |
33,696 |
$5,976,588.67 |
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO) |
|
|
|
|
|
|
|
|
|
|
a) RATA audit (one per year)e |
8 |
350 |
1 |
8 |
82 |
656 |
32.8 |
65.6 |
28,700 |
$5,128,498.45 |
b) RAA audit (three per year)e |
8 |
130 |
3 |
24 |
82 |
1,968 |
98.4 |
196.8 |
31,980 |
$5,857,669.34 |
c) Daily calibration and operation |
1 |
0 |
365 |
365 |
82 |
29,930 |
1,496.5 |
2,993 |
0 |
$3,461,269.82 |
C. Create Information |
See 3B |
|
|
|
|
|
|
|
|
|
D. Gather Information |
See 3E |
|
|
|
|
|
|
|
|
|
E. Report Preparation |
|
|
|
|
|
|
|
|
|
|
1) Plant startup |
|
|
|
|
|
|
|
|
|
|
a) Control plan |
40 |
0 |
1 |
40 |
0 |
0 |
0 |
0 |
0 |
$0 |
b) Notification of contract awards |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
c) Notification of on-site construction start |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
d) Notification of construction completion |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
e) Notification of final compliance |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
2) Notification of initial performance tests |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
3) Initial compliance reports |
40 |
0 |
1 |
40 |
0 |
0 |
0 |
0 |
0 |
$0 |
4) Notification of CEMS demonstration |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
5) Initial CEMS demonstration report |
90 |
0 |
1 |
90 |
0 |
0 |
0 |
0 |
0 |
$0 |
6) Notification of starting or stopping use of the CEMS |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
7) Air Curtain incinerator initial performance tests |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
8) Annual compliance reports |
40 |
0 |
1 |
40 |
32 |
1,280 |
64 |
128 |
0 |
$148,026.24 |
9) Semi-annual excess emission reports f |
40 |
0 |
2 |
80 |
6.4 |
512 |
25.6 |
51.2 |
0 |
$59,210.50 |
10) Notification of exemptions |
4 |
0 |
1 |
4 |
0 |
0 |
0 |
0 |
0 |
$0 |
Subtotal for Reporting |
|
|
|
|
|
165,304 |
$25,936,065 |
|||
4.) Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
A. Familiarize with Regulatory Requirements |
See 3A |
|
|
|
|
|
|
|
|
|
B. Plan activities |
See 3B |
|
|
|
|
|
|
|
|
|
C. Implement activities |
See 3B |
|
|
|
|
|
|
|
|
|
D. Develop record system |
N/A |
|
|
|
|
|
|
|
|
|
E. Record information |
|
|
|
|
|
|
|
|
|
|
1) Record startups, shutdowns, and malfunctions g |
4 |
0 |
47 |
188 |
82 |
15416 |
770.8 |
1541.6 |
0 |
$1,782,791.03 |
2) Records of all emission rates, computations, tests g |
4 |
0 |
47 |
188 |
82 |
15416 |
770.8 |
1541.6 |
0 |
$1,782,791.03 |
3) Records of employee review of operations manual |
4 |
0 |
1 |
4 |
32 |
128 |
6.4 |
12.8 |
0 |
$14,802.62 |
4) Record amount of sorbent used for Hg and dioxin/furan control h |
4 |
0 |
4 |
16 |
82 |
1312 |
65.6 |
131.2 |
0 |
$151,726.90 |
5) Records of emission exceedances and periods when emission data not obtained |
See 3E |
|
|
|
|
|
|
|
|
|
6) Records of CEMS drift tests and Appendix F accuracy assessments |
See 4E 1-4 |
|
|
|
|
|
|
|
|
|
7) Records of initial performance test |
See 3E |
|
|
|
|
|
|
|
|
|
8) Records of annual performance tests |
See 3E |
|
|
|
|
|
|
|
|
|
9) Records of opacity limits for air curtain incinerators |
See 3E |
|
|
|
|
|
|
|
|
|
F. Personnel training |
N/A |
|
|
|
|
|
|
|
|
|
G. Time for audits |
N/A |
|
|
|
|
|
|
|
|
|
Subtotal for Recordkeeping |
|
|
|
|
|
37,113 |
$3,732,112 |
|||
TOTAL LABOR BURDEN AND COST (Rounded)i |
|
|
|
|
|
202,000 |
$29,700,000 |
|||
Capital and O&M Cost |
|
|
|
|
|
|
|
|
|
$787,000 |
GRAND TOTAL |
|
|
|
|
|
|
|
|
|
$30,500,000 |
Assumptions:
a. Assume 162 large MWC units at 63 plants, 49 percent of which are privately owned.
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. The contractor rate was derived by taking the contractor rate used in the previous ICR and multiplying by the average increase in managerial, technical, and clerical rates since the previous ICR.
c. This ICR assumes all respondents will have to familiarize with regulatory requirements
d. Assume 20 percent of reporting plants must repeat initial tests due to failure at one unit at the plant.
e. RATA audits are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
f. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
g. Based on weekly recordkeeping, we assume 47 weeks of operation (90 percent availability) per year per MWC.
h. Based on quarterly calculation of sorbent use for entire plant, regardless of the number of affected facilities at the plant.
i. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
Table 1c: Average Annual Designated Administrator Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
1.) Applications |
N/A |
|
|
|
|
|
2.) Familiarize with Regulatory Requirements c |
1 |
40 |
40 |
2 |
4 |
$2,093.60 |
3.) Required Activities |
|
|
|
|
|
|
A. Develop a state plan |
0 |
2,080 |
0 |
0 |
0 |
$0 |
B. Public Hearing on state plan |
0 |
8 |
0 |
0 |
0 |
$0 |
A. Observe initial performance tests |
|
|
|
|
|
|
1) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)d |
0 |
48 |
0 |
0 |
0 |
$0 |
2) Repeat of initial performance tests e |
0 |
10 |
0 |
0 |
0 |
$0 |
B. Excess emissions -- enforcement activities f |
11 |
24 |
264 |
13.2 |
26.4 |
$13,817.76 |
C. Create Information |
|
|
|
|
|
|
D. Gather Information |
|
|
|
|
|
|
E. Report Reviews |
|
|
|
|
|
|
1) Control plan |
0 |
8 |
0 |
0 |
0 |
$0 |
2) Notification of contract awards |
0 |
8 |
0 |
0 |
0 |
$0 |
3) Notification of on-site construction start |
0 |
8 |
0 |
0 |
0 |
$0 |
4) Notification of construction completion |
0 |
8 |
0 |
0 |
0 |
$0 |
5) Notification of final compliance |
0 |
8 |
0 |
0 |
0 |
$0 |
6) Review notification of initial performance test |
0 |
8 |
0 |
0 |
0 |
$0 |
7) Review notification of initial CEMS demonstration |
0 |
4 |
0 |
0 |
0 |
$0 |
8) Review notification of starting or stopping use of the CEMS |
0 |
8 |
0 |
0 |
0 |
$0 |
9) Review initial performance test report |
0 |
40 |
0 |
0 |
0 |
$0 |
10) Review initial CEMS demonstration report |
0 |
40 |
0 |
0 |
0 |
$0 |
11) Review annual compliance report g |
55 |
40 |
2,200 |
110 |
220 |
$115,148.00 |
12) Review semi-annual excess emission report f |
11 |
16 |
176 |
8.8 |
17.6 |
$9,211.84 |
13) Review of notifications of exemption |
0 |
4 |
0 |
0 |
0 |
$0 |
F. Prepare annual summary report |
0 |
200 |
0 |
0 |
0 |
$0 |
TOTAL ANNUAL BURDEN AND COST (rounded)h |
|
|
3,080 |
$140,000 |
||
Assumptions:
a. Assume 144 affected units as 55 plants in 18 states.
b. The cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses $62.27 Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) 2014 General Schedule, which excludes locality rates of pay.
c. This ICR assumes all respondents will have to familiarize with regulatory requirements
d. Assume EPA personnel attend about 8 percent of tests (145 units tested x 8 percent attended =12)
e. Assume a 20 percent failure rate and that EPA personnel attend 10 percent of the retests (7 units tested *20 percent failure* 10 percent retests attended = 1).
f. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
g. Burden not incurred until second year of operation and later.
h. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
1.) Applications |
N/A |
|
|
|
|
|
2.) Familiarize with Regulatory Requirements |
0 |
40 |
0 |
0 |
0 |
$0 |
3.) Required Activities |
|
|
|
|
|
|
A. Observe initial performance tests |
|
|
|
|
|
|
1) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)c |
0 |
48 |
0 |
0 |
0 |
$0 |
2) Repeat of initial performance tests d |
0 |
10 |
0 |
0 |
0 |
$0 |
B. Excess emissions -- enforcement activities e |
1.6 |
24 |
38.4 |
1.92 |
3.84 |
$2,009.86 |
C. Create Information |
|
|
|
|
|
|
D. Gather Information |
|
|
|
|
|
|
E. Report Reviews |
|
|
|
|
|
|
1) Control plan |
0 |
8 |
0 |
0 |
0 |
$0 |
2) Notification of contract awards |
0 |
8 |
0 |
0 |
0 |
$0 |
3) Notification of on-site construction start |
0 |
8 |
0 |
0 |
0 |
$0 |
4) Notification of construction completion |
0 |
8 |
0 |
0 |
0 |
$0 |
5) Notification of final compliance |
0 |
8 |
0 |
0 |
0 |
$0 |
6) Review notification of initial performance test |
0 |
8 |
0 |
0 |
0 |
$0 |
7) Review notification of initial CEMS demonstration |
0 |
4 |
0 |
0 |
0 |
$0 |
8) Review notification of starting or stopping use of the CEMS |
0 |
8 |
0 |
0 |
0 |
$0 |
9) Review initial performance test report |
0 |
40 |
0 |
0 |
0 |
$0 |
10) Review initial CEMS demonstration report |
0 |
40 |
0 |
0 |
0 |
$0 |
11) Review annual compliance report f |
8 |
40 |
320 |
16 |
32 |
$16,748.80 |
12) Review semi-annual excess emission report e |
1.6 |
16 |
25.6 |
1.28 |
2.56 |
$1,339.90 |
13) Review of notifications of exemption |
0 |
4 |
0 |
0 |
0 |
$0 |
F. Prepare annual summary report |
0 |
200 |
0 |
0 |
0 |
$0 |
TOTAL ANNUAL BURDEN AND COST (rounded)g |
|
|
442 |
$20,100 |
||
Assumptions:
a. Assumes 18 affected units at 8 plants in 4 states.
b. The cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses $62.27 Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) 2014 General Schedule, which excludes locality rates of pay.
c. Assume EPA personnel attend about 8 percent of tests (22 units tested x 8 percent attended = 2).
d. Assume a 20 percent failure rate and that EPA personnel attend 10 percent of the retests (7 units tested *20 percent failure* 10 percent retests attended = 1)
e. Assumes 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
f. Burden not incurred until second year of operation and later.
g. Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | ICR Package Instructions |
| Author | rmarshal |
| File Modified | 0000-00-00 |
| File Created | 2021-01-24 |