Burden Tables

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Overview

Table 1
Table 2
Capital and O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Sewage Sludge Incinerators (40 CFR Part 60, Subpart MMMM) (Renewal)
					108.28	144.33	53.34
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Respondent Hours per Occurrence	Number of Occurrences Per Respondent Per Year	Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CxD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Total Costs, $ b
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements
A. Familiarize with the regulatory requirements c, d	40	1	40	86	3,440	172	344	$415,657
B. Required Activities
1) Initial stack test and report e	40	1	40	0	0	0	0	$0
2) Annual stack test and test report f, g	40	0.33	13.2	170	2,244	112.2	224.4	$271,143.64
3) Operator training and qualification
a) Establish and teach operator qualification course d, e	64	1	64	0	0	0	0	$0
b) Obtain operator qualification d, e	72	1	72	0	0	0	0	$0
c) Annual refresher course d, f	12	1	12	86	1,032	51.6	103.2	$124,697.08
d) Initial review of site-specific information	See 3B 3) a)
e) Annual review of site-specific information d, f	8	1	8	86	688	34.4	68.8	$83,131.38
4) Establish operating parameters (maximum and minimum) e	40	1	40	0	0	0	0	$0
5) Continuous parameter monitoring (including CEMS)
a) Initial monitoring e	11	1	11	0	0	0	0	$0
b) Annual monitoring f	11	1	11	170	1,870	93.5	187	$225,953.04
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Notification of initial performance test e	2	1	2	0	0	0	0	$0
2) Notification of initial CMS Demonstration d, e	2	1	2	0	0	0	0	$0
3) Final Control Plan e	20	1	20	0	0	0	0	$0
4) Initial Compliance Report e	40	1	40	0	0	0	0	$0
5) Report for site-specific parameter petition e, h	14	1	14	0	0	0	0	$0
6) Annual Compliance Report	40	1	40	170	6,800	340	680	$821,647.40
7) Notification for operators that are off-site for more than 2 weeks i	8	1	8	9	72	3.6	7.2	$8,699.80
8) Status report for operators that are off-site for more than 2 weeks i	8	2	16	9	144	7.2	14.4	$17,399.59
9) Semiannual Deviation Report j	24	2	48	9	432	21.6	43.2	$52,198.78
Subtotal for Reporting Requirements					19,230			$2,020,528
4. Recordkeeping Requirements
A. Familiarize with the regulatory requirements	See 3A
B. Plan Activities	N/A
C. Implement Activities	N/A
D. Develop Record System	N/A
E. Record Information
1) Records of operating parameters	2	52	104	86	8,944	447.2	894.4	$1,080,708
2) Records of exceedances of the operating parameters j	2	1	2	9	18	0.9	1.8	$2,174.95
3) Records of stack tests g	2	0.33	0.66	86	56.76	2.84	5.68	$6,858.34
4) Records of persons who have reviewed operating procedures	2	1	2	86	172	8.6	17.2	$20,782.85
5) Records of persons who have completed operator training	2	1	2	86	172	8.6	17.2	$20,782.85
6) Records of persons who meet operator qualification criteria	2	1	2	86	172	8.6	17.2	$20,782.85
7) Records of monitoring device calibration	2	1	2	86	172	8.6	17.2	$20,782.85
8) Records of site-specific documentation	24	1	24	86	2,064	103.2	206.4	$249,394.15
F. Personnel Training	See 3B
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					13,536			$1,422,267		responses	hr/response
TOTAL ANNUAL BURDEN AND COST (rounded) k					32,800			$3,440,000		271	121.033210332103
TOTAL CAPITAL AND O&M COST (rounded) k								$1,350,000
GRAND TOTAL (rounded) k								$4,790,000
Assumptions:
a We have assumed that there will be an average of 170 units at 86 facilities that will be subject to the rule. Because the standard only affects existing units constructed on or before October 14, 2010; there will be no new units subject to the rule.
b This ICR uses the following labor rates: $144.33 per hour for Executive, Administrative, and Managerial labor; $108.28 per hour for Technical labor, and $53.34 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 have assumed that all existing respondents will have to familiarize with the regulatory requirements each year.
d Cost incurred by a facility regardless of the number of affected units at the plant.
e This is a one-time only costs.
f Annual costs are not incurred until the second year of operation.
g 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.
h Assumed that none of the facilities will petition for site-specific parameters.
i Assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year (86 x 10% = 8.6, rounded to 9 facilities). Assumed that this required only two status reports.
j Assumed that 10 percent of the facilities would have an exceedance during the year (86 x 10% = 8.6, rounded to 9 facilities).
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Sewage Sludge Incinerators (40 CFR Part 60, Subpart MMMM) (Renewal)
					48.08	64.8	26.02
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences Per Respondent Per Year	EPA Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CXD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Total Costs, $ b
1. Applications	N/A
2. Read and Understand Rule Requirements	40	1	40	0	0	0	0	$0
3. Required Activities
A. Observe stack tests a	48	1	48	11	528	26.4	52.8	$28,470.82
B. Excess emissions -- Enforcement Activities b	24	1	24	9	216	10.8	21.6	$11,647.15
C. Create Information	N/A
D. Gather Information	N/A
E. Report Reviews
1) Review initial notifications	20	1	20	0	0	0	0	$0
2) Review initial compliance report	40	1	40	0	0	0	0	$0
3) Review annual compliance report	8	1	8	170	1,360	68	136	$73,333.92
4) Review semiannual excess emission and parameter exceedance report b	16	2	32	9	288	14.4	28.8	$15,529.54
5) Review notification and status reports for operators off-site c	4	3	12	9	108	5.4	10.8	$5,823.58
F. Prepare annual summary report	200	1	200	1	200	10	20	$10,784.40
5. Travel expenses: (1 person * 48 hours per trip / 8 hours per day * $75 per diem) + ($600 per round trip) = $1,050 per trip ($1,050 per trip x 11 trips) = $11,550								$11,550.00
TOTAL ANNUAL BURDEN AND COST (rounded) d					3,110			$157,000
Assumptions
a We assume that EPA personnel attends 20 percent of the stack tests. 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. (170 units per year x 0.33 stack test/unit x 20%) = 11.33, rounded to 11 stack tests per year)
b We assume that 10 percent of the facilities would have an exceedance during the year (86 x 10% = 8.6, rounded to 9 facilities).
c We assume that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. We assume that this will require only two status reports, resulting in a total of 3 reports (1 notification and 2 status reports).
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital and O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Fluidized Bed
PBS parameter monitors	$24,300	0	$0	$5,600	6	$33,600
SNCR monitors	$10,300	0	$0	$3,200	2	$6,400
Initial and annual stack test	$61,740	0	$0	$21,348	18	$384,264
Multiple Hearth
PBS parameter monitors	$24,300	0	$0	$5,600	8	$44,800
Initial and annual stack test	$61,740	0	$0	$23,302	38	$885,476
Total			$0			$1,350,000