Burden Calculation Tables

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Overview

industry
agency
O&M
Total Annual Responses

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Sheet 1: industry

Table 1: Annual Respondent Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE).
						117.92	147.4	57.02	Updated to 2018 labor rates
					Person-hours per year
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per yeara	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per yearb
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with rule requirementsc	40	1	40	55	2200	110	220	$288,182.40
B. Required activities
1) Initial performance test and reports
a) Initial performance tests (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c	24	1	24	55	1320	66	132	$172,909.44
b) Repeat of initial performance tests c,d	24	1	24	11	264	13.2	26.4	$34,581.89
2) CEMS demonstration (CO, O2)
a) Initial demonstration	229	1	229	55	12595	629.75	1259.5	$1,649,844.24
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)f	24	1	24	55	1320	66	132	$172,909.44
4) Daily calibration and operation e	1	250	250	110	27500	1375	2750	$3,602,280.00
5) Waste management plan c	20	1	20	55	1100	55	110	$144,091.20	Per comments on SS, have added hours for development of waste management plan. Note, however, per 60.2952, this is submitted with the preconstruction report.
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
1) Preconstruction reportc	8	1	8	55	440	22	44	$57,636.48		Total Respondent Responses (ea)
2) Startup notificationc	2	1	2	55	110	5.5	11	$14,409.12		242
3) Initial test report c	40	1	40	55	2200	110	220	$288,182.40
4) Annual compliance reportsf	40	1	40	55	2200	110	220	$288,182.40		Labor Burden & cost ($)
5) Semiannual deviation reportsi	24	2	48	11	528	26.4	52.8	$69,163.78		79500
Subtotal for Reporting Requirements					59,544			$6,782,373
4. Recordkeeping requirements
A. Familiarize with rule requirementsc	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 g	1.5	52	78	110	8580	429	858	$1,123,911.36
2) Records of emission rate computations, all emission exceedances and periods when there is no data g, i	1.5	52	78	11	858	42.9	85.8	$112,391.14
3) Records of employee review of operations manual	4	1	4	110	440	22	44	$57,636.48
4) Record of control devices operating parameters g	1.5	52	78	110	8580	429	858	$1,123,911.36
F. Perform Audits	N/A
Subtotal for Recordkeeping Requirements					21,227			$2,417,850		242	respones
TOTAL LABOR BURDEN AND COST (rounded)h					80,800			$9,200,000		Owens, Katharine: Why is Labor Burden & Cost used in this calculation? How do we arrive at hours when we're diving dollars by # of reports? 334	hrs/response
TOTAL Capital and O&M Cost (rounded)h								$2,720,000
GRAND TOTAL (Labor Cost + Capital/O&M)h								$11,900,000		See response to comments in supporting statement, but note that we have pulled Total Annual Response table into file to clarify origin of responses.
Assumptions:
a On average, EPA expects 55 new units to be constructed or in operation per year over the next three years. This assumption is based on one new unit per state or U.S. protectorate per year, including American Samoa, Puerto Rico, Virgin Islands, and Northern Mariana Islands.
b This ICR uses the following labor rates: $117.92 (technical), $147.40 (managerial), and $57.02 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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 have assumed that this is a one-time only cost for new respondents. Note that the waste management plan is submitted as part of the preconstruction report.
d We have assumed that only 20% of respondents would be required to repeat a performance test.
e We have assumed that each respondent will take 1 hour 250 times per year to record daily calibration and operation.
f Average number of existing respondents for the three-year period expect to submit an annual report ((0 + 55 + 110)/3 = 55). Annual testing and compliance reports are required to be submitted 12 months following the initial test report. Therefore, no new respondents are anticipated to submit an annual compliance report in the first year of reporting.
g We have assumed that each respondent will record information 52 times per year.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
i We have assumed that 10 percent of the average number of respondents (110 x 0.10) will report exceedances.

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Sheet 2: agency

Table 2: Average Annual EPA Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE)(Renewal).
					48.75	65.71	26.38
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants per yeara	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $b
1. Applications	N/A
2. Familiarization with the regulatory requirements	16	1	16	55	880	44	88	$48,112.68
3. Required activities
A. Create information	N/A
B. Gather information	See 3A & 3F
C. Report reviews
1) Notification of final compliance c	1.5	1	1.5	55	82.5	4.125	8.25	$4,510.56
2) Review initial compliance test report c	40	1	40	55	2200	110	220	$120,281.70
3) Review annual compliance report d	40	1	40	55	2200	110	220	$120,281.70
4) Review semiannual deviation reports e	16	2	32	11	352	17.6	35.2	$19,245.07
5) Review waste management plan c	16	1	16	55	880	44	88	$48,112.68
D. Annual summary report f	4	1	4	55	220	11	22	$12,028.17
TOTAL ANNUAL BURDEN AND COST (rounded)g					7,840			$373,000
Assumptions:
a On average, EPA expects 55 new units to be constructed or in operation per year over the next three years. This assumption is based on one new unit per state or U.S. protectorate per year, including American Samoa, Puerto Rico, Virgin Islands, and Northern Mariana Islands.
b This ICR uses the following labor rates: $48.75 (technical), $65.71 (managerial), and $26.38 (clerical). These rates are from the Office of Personnel Management (OPM), 2018 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 Average number of existing respondents for the three-year period expect to submit an annual report. Annual testing and compliance reports are required to be submitted 12 months following the initial test report. Therefore, no new respondents are anticipated to submit an annual compliance report in the first year of reporting.
e We have assumed that 10 percent of the average number of respondents (110 x 0.10) will report exceedances.
f We have assumed that all affected facilities will be required to prepare an annual summary plan.
g 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	55	$2,444,000	$5,000	55	$275,000

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Sheet 4: Total Annual Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
			Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
Notification to commence construction	55	1	0	55
Notification of initial startup	55	1	0	55
Initial test report	55	1	0	55
Annual compliance reports	55	1	0	55
Semiannual deviation reports a	11	2	0	22
			Total	242