Calculation Tables for ICR 1847.07

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Overview

Table 1a
Table 1b
Table 1c
Table 2

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Sheet 1: Table 1a

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)
						103.97	129.93	51.79	176.05
Burden Item	(A) Respondent Person Hours Per Occurrence	(B) Contractor Person Hours Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Hours Per Respondent Per Year (D=AxC)	(E) Number of Respondents Per Year a	(F) Technical Hours Per Year (F=DxE)	(G) Management Hours Per Year (G=Fx0.05)	(H) Clerical Hours Per Year (H=Fx0.1)	(I) Contractor Hours Per Year (I=BxCxE)	(J) Total Costs Per Year b
1.) Applications	N/A
2.) Surveys and Studies	N/A
3.) Reporting Requirements
A. Familiarize with Regulatory Requirementsc	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 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) Annual compliance reports	40	0	1	40	31	1,240	62	124	0	$143,400.42
7) Semi-annual excess emission reports f	40	0	2	80	6	480	24	48	0	$55,509.84
Subtotal for Reporting						156,138				$24,409,324
4.) Recordkeeping Requirements
A. Familiarize with Regulatory Requirementsc	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
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping						36,207				$3,505,838
TOTAL LABOR BURDEN AND COST (Rounded)i						192,000				$27,900,000
Capital and O&M Cost										$768,000
GRAND TOTAL										$28,700,000
Assumptions:
a. Assume 162 large MWC units at 63 plants, 49 percent of which are privately owned.										397,080
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

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Sheet 2: Table 1b

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)
						103.97	129.93	51.79	176.05
Burden Item	(A) Respondent Person Hours Per Occurrence	(B) Contractor Person Hours Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Hours Per Respondent Per Year (D=AxC)	(E) Number of Respondents Per Year a	(F) Technical Hours Per Year (F=DxE)	(G) Management Hours Per Year (G=Fx0.05)	(H) Clerical Hours Per Year (H=Fx0.1)	(I) Contractor Hours Per Year (I=BxCxE)	(J) Total Costs Per Year b
1.) Applications	N/A
2.) Surveys and Studies	N/A
3.) Reporting Requirements
A. Familiarize with Regulatory Requirements	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 c	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 c	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)d	8	350	1	8	82	656	32.8	65.6	28,700	$5,128,498.45
b) RAA audit (three per year)d	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) Annual compliance reports	40	0	1	40	32	1,280	64	128	0	$148,026.24
7) Semi-annual excess emission reports e	40	0	2	80	6.4	512	25.6	51.2	0	$59,210.50
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 f	4	0	47	188	82	15416	770.8	1541.6	0	$1,782,791.03
2) Records of all emission rates, computations, tests f	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 g	4	0	4	16	82	1312	65.6	131.2	0	$151,726.90
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)h						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

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Sheet 3: Table 1c

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)
			46.67	62.9	25.25
Burden Item	(A) Number of Occurences Per Year a	(B) Administrator Hours Per Occurrence	(C) Technical Hours Per Year (C=AxB)	(D) Management Hours Per Year (D=Cx0.05)	(E) Clerical Hours Per Year (E=Cx0.1)	(F) Administrator Costs Per Year b
1.) Applications	N/A
2.) Familiarize with Regulatory Requirementsc	1	40	40	2	4	$2,093.60
3.) Required Activities
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 initial performance test report	0	40	0	0	0	$0
9) Review initial CEMS demonstration report	0	40	0	0	0	$0
10) Review annual compliance report g	55	40	2,200	110	220	$115,148.00
11) Review semi-annual excess emission report f	11	16	176	8.8	17.6	$9,211.84
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

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Sheet 4: Table 2

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)
			46.67	62.9	25.25
Burden Item	(A) Number of Occurences Per Year a	(B) Administrator Hours Per Occurrence	(C) Technical Hours Per Year (C=AxB)	(D) Management Hours Per Year (D=Cx0.05)	(E) Clerical Hours Per Year (E=Cx0.1)	(F) Administrator Costs Per Year b
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 initial performance test report	0	40	0	0	0	$0
9) Review initial CEMS demonstration report	0	40	0	0	0	$0
10) Review annual compliance report f	8	40	320	16	32	$16,748.80
11) Review semi-annual excess emission report e	1.6	16	25.6	1.28	2.56	$1,339.90
F. Prepare annual summary report	0	200	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)h			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.