Burden Calculation Tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)
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
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarization with the regulatory requirements c
New sources	40	1	40	0	0	0	0	$0
Existing sources	1	1	1	99	99	4.95	9.9	$12,466.92
B. Required activities
1) Initial performance test and reports
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) 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)
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	$299,206.12
4) Quarterly Appendix F audits of CEMS (CO)
a) RATA audit (one per year) f	4	1	4	99	396	19.8	39.6	$49,867.69
b) RAA audit (three per year) f	4	3	12	99	1188	59.4	118.8	$149,603.06
c) Daily calibration and operation f, g	1	250	250	99	24750	1237.5	2475	$3,116,730.38
C. Create information	See 3B
D. Gather information	See 3E
E. Report preparation
1) Contract or secure alternative means of disposal d	40	1	40	0	0	0	0	$0
2) Notification of final compliance d	1.5	1	1.5	0	0	0	0	$0
3) Initial compliance report d	40	1	40	0	0	0	0	$0
4) Waste management plan d	40	1	40	0	0	0	0	$0
5) Annual compliance reports	40	1	40	99	3960	198	396	$498,676.86
6) Semiannual deviation reports	24	2	48	99	4752	237.6	475.2	$598,412.23
Subtotal for Reporting Requirements					43,149			$4,724,963
4. Recordkeeping requirements
A. Read and understand rule requirement	See 3A
B. Plan activities	See 3B
C. Implement Activities	See 3B
D. Develop record system	N/A
E. Record information
1) Records of SSM h	1.5	52	78	99	7722	386.1	772.2	$972,419.88
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	$972,419.88
3) Records of employee review of operations manual	4	1	4	99	396	19.8	39.6	$49,867.69
4) Record of control device operating parameters h	1.5	52	78	99	7722	386.1	772.2	$972,419.88
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					27,096			$2,967,127
TOTAL LABOR BURDEN AND COST (roundedi)					70,200			$7,690,000
Total Capital/O&M Costs (roundedi)j								$495,000
Grand Total (Labor and Capital/O&M Costs) (roundedi)								$8,190,000
Assumptions:							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.
b This ICR uses the following labor rates: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They 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.
d We have assumed that all respondents have achieved final compliance for the emission guidelines.
e We have assumed that 20 percent of respondents will repeat initial tests due to failure.
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.
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.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
j Capital and O&M costs represent costs for CEMS.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)
					48.08	64.8	26.02
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
2. Familiarization with rule requirements	N/A
3. Required activities
A. Create information	N/A
B. Gather information	See 3A
C. Report reviews
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	$213,531.12
4) Review semiannual deviation reports	16	2	32	99	3168	158.4	316.8	$170,824.90
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	$21,353.11
TOTAL ANNUAL BURDEN AND COST (rounded)e					8,650			$406,000
Assumptions:
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 ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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.
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.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: 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)
Continuous emission monitoring system	$44,445	0	$0	$5,000	99	$495,000
Total			$0			$495,000
Annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.