Burden Calculation Tables

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Overview

Industry
Agency
Public v. Private

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Sheet 1: Industry

					112.98	149.35	54.81		80
Burden item	(A) 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) Emission Test Person- Hours per Occurrence	(I) Emission Testing Contractor Person-Hours per Year (HxD)	(J) Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarization with Regulatory Requirements	1	1	1	23	23	1.15	2.3	1	23	$4,736.36
B. Required activities
Initial performance test for Eb c, d, e	24	1	24	0.33	7.92	0.40	0.79	1,053	347	$28,796.55
Repeat performance test for Eb e, f	24	1	24	0.07	1.68	0.08	0.17	1,053	73.71	$6,108.36
Demonstration/CEMS for Ebc, d	24	1	24	0.33	7.92	0.40	0.79	470	155.1	$13,405.35
Repeat CEM demonstration Eb f	24	1	24	0.07	1.68	0.08	0.17	470	32.9	$2,843.56
Annual compliance test for Ea g, i	24	1	24	18	432	21.6	43.2	826	14,868	$1,243,841.11
Annual compliance test for Eb e, h	24	1	24	5	120	6	12	1,053	5,265	$436,311.42
Appendix F audit for Ea (in-situ)	125	8	1,000	0	0	0	0	0	0	$0
Appendix F audit for Ea (extractive)	36	8	288	0	0	0	0	0	0	$0
C. Create Information	See 3B
D. Gather information	See 3B
E. Write report
Notification of construction/reconstruction for Ea	2	1	2	0	0	0	0	0	0	$0
Notification of actual startup – Ea	2	1	2	0	0	0	0	0	0	$0
Notification of initial performance test – Ea	2	1	2	0	0	0	0	0	0	$0
Notification of CMS demonstration – Ea	2	1	2	0	0	0	0	0	0	$0
Notification of construction/reconstruction – Ebc, d	2	1	2	0.33	0.66	0.03	0.07	0	0	$83.11
Notification of initial performance test – Ebc, d	2	1	2	0.33	0.66	0.03	0.07	0	0	$83.11
Notification of CMS demonstration – Ebc,d	2	1	2	0.33	0.66	0.03	0.07	0	0	$83.11
Annual compliance reports for Ea	16	1	16	18	288	14.4	28.8	0	0	$36,267.41
Annual opacity report of no excess emission for Ea j	8	1	8	14.4	115.2	5.76	11.52	0	0	$14,506.96
Annual opacity report for excess emission for Ea j	16	1	16	3.6	57.6	2.88	5.76	0	0	$7,253.48
Report of daily weight of MSW and fuel for Ea	34	4	136	18	2448	122.4	244.8	0	0	$308,272.97
Appendix F reports for Ea	11	4	44	18	792	39.6	79.2	0	0	$99,735.37
Initial compliance report for Ebc,d	40	1	40	0.33	13.2	0.66	1.32	0	0	$1,662.26
Annual compliance report for Eb	40	1	40	5	200	10	20	0	0	$25,185.70
Semiannual excess emission report Eb k	17	2	34	5	170	8.5	17	0	0	$21,407.85
Appendix F reports for Eb l	11	4	44	5	220	11	22	0	0	$27,704.27
Initial site selection analysis/report for Ebc, d	270	1	270	0.33	89	4.455	8.91	0	0	$11,220.23
Public meeting and comment response for Ebc,d	140	1	140	0.33	46.2	2.31	4.62	0	0	$5,817.90
Subtotal for Reporting Requirements					5,791				20,765	$2,295,326
					26,556
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Plan activities	See 4E
C. Implement activities	See 4E
D. Develop record system	See 4E
E. Time to enter information
Records of SSM for Ea m	1.5	104	156	18	2,808	140.4	280.8	0	0	$353,607.23
Record emission measurements Ea m	1.5	104	156	18	2,808	140.4	280.8	0	0	$353,607.23			Capital/Startup vs. O&M Costs
Record of employee review of operation for Ea n	4	2	8	18	144	7.2	14.4	0	0	$18,133.70			A	B	C	D	E	F	G
Record of emission rates, and computation tests for Eb o	1.5	94	141	5	705	35.25	70.5	0	0	$88,779.59			CEMs for subpart Ea	$60,000	0	$0	$8,972	18	$161,496
Record of SSM for Eb o	1.5	94	141	5	705	35.25	70.5	0	0	$88,779.59			CEMs for subpart Eb	$60,000	0.33	$20,000	$8,972	5	$44,860
Record of employee review of operation for Eb n	4	2	8	5	40	2	4	0	0	$5,037.14			Total			$20,000			$206,000	$226,000
Record amount of sorbent for Hg control for Eb	0.1	94	9.4	5	47	2.35	4.7	0	0	$5,918.64
F. Train personnel	See 4E
G. Audits	See 4E
Subtotal for Recordkeeping Requirements					8,346				0
					8,350					$914,000
TOTAL LABOR BURDEN AND COST (rounded)p					34,900					$3,210,000
TOTAL CAPITAL AND O&M COST (rounded)p										$226,000
GRAND TOTAL (rounded)p										$3,440,000
						hr/resp	167
						No. response	209
a On average, EPA estimates 23 existing sources will be subject to the NESHAP, including 13 sources subject to Ea, and 5 sources subject to Eb. EPA estimates one plant (respondent) to startup in 2019 which will become subject to Subpart Eb.
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. We have estimated that the contractors’ rate for emission testing would be $80.00 per hour.
c Applies to new or reconstructed sources only.
d EPA assumes one existing facility will implement process changes over the next 3 years.
e We have assumed that it will take an emission testing contractor 1,053 hours to perform both initial performance test and repeat performance tests for subpart Eb.
f We have assumed that 20 percent of the respondents will have to repeat a performance test or CEMS demonstration for Eb.
g We have assumed that all of the 18 respondents for subpart Ea will have to complete an annual compliance test.
h We have assumed that all 5 respondents for subpart Eb will have to complete an annual compliance test.
i We have assumed that it will take an emission testing contractor 826 hours to complete an annual compliance test for Eb.
j We have assumed that 80 percent of respondents will file an opacity report of no excess emission for Ea and will submit periodic reports on a semiannual basis, and 20 percent of respondents will file an opacity report of excess emission for Ea and submit periodic reports on a quarterly basis.
k We have assumed that 5 of the respondents will be required to write semiannual excess emission report for Eb two times per year.
l We have assumed that 5 of the respondents will write the appendix F reports four times per year.
m We have assumed that all 18 respondents for subpart Ea will each take 104 hours to complete task.
n We have assumed that all 18 respondents for subpart Ea and all 5 respondents for subpart Eb will each take 4 hours two times per year to record employee review of operations.
o We have assumed that each of the 5 respondents subject to Eb will take 1.5 hours 94 times per year to enter information.
p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

					48.08	64.8	26.02
Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Initial performance tests for Ea	180	1	180	0	0	0	0	$0
Initial performance tests for Ebc	180	1	180	Tracy Curtis: References cell E8 in the industry tab 0.33	59.4	2.97	5.94	$3,202.97
Review report of initial performance test for Ea	24	1	24	0	0	0	0	$0
Review report of initial performance test for Ebc	24	1	24	0.33	7.92	0.396	0.792	$427.06
Repeat performance test for Ea	12	1	12	0	0	0	0	$0
Repeat performance test for Ebd	12	1	12	0.07	0.84	0.04	0.08	$45.29
Report review for Ea
Notification of construction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of initial test	2	1	2	0	0	0	0	$0
Notification of CMS demonstration	12	1	12	0	0	0	0	$0
Review of CEMS demonstration for Ea	96	1	96	0	0	0	0	$0
Review excess emission reports for Ea
No excess emission report e	8	1	8	14.4	115.2	5.76	11.52	$6,211.81
Excess emission report f	2	1	2	3.6	7.2	0.36	0.72	$388.24
Review quarterly appendix F reports for Ea g	0.5	4	2	18	36	1.8	3.6	$1,941.19
Review quarterly compliance report for Ea	8	4	32	18	576	28.8	57.6	$31,059.07
Review annual compliance tests for Ea	18	1	18	18	324	16.2	32.4	$17,470.73
Report review for Eb d
Notification of construction c	2	1	2	0.33	0.66	0.03	0.07	$35.59
Notification of initial performance test c	8	1	8	0.33	2.64	0.13	0.26	$142.35
Notification of CEMS demonstration c	5	1	5	0.33	1.65	0.08	0.17	$88.97
Review CEMS demonstration for Eb c	40	1	40	0.33	13.2	0.66	1.32	$711.77
Review semiannual excess emission reports for Eb h	12	2	24	5	120	6	12	$6,470.64
Review of quarterly Appendix F reports for Eb i	5	4	20	5	100	5	10	$5,392.20
Review annual compliance reports for Eb	5	1	5	5	25	1.25	2.5	$1,348.05
Review siting requirements study for Eb c	24	1	24	0.33	7.92	0.40	0.79	$427.06
TOTAL ANNUAL BURDEN AND COST (rounded)j					1,610			$75,400
Assumptions:
a On average, EPA estimates 23 existing sources will be subject to the NESHAP, including 13 sources subject to Ea, and 5 sources subject to Eb. EPA estimates one plant
(respondent) to startup in 2019 which will become subject to Subpart Eb.
b This ICR uses the following labor rates: $64.80 per hour for Managerial (GS-13, Step 1, $30.05 + 60%); $48.08 per hour for Technical labor (GS-12, Step 3, $16.26 + 60%), and
$26.02 per hour for Clerical (GS-6, Step 3, $16.26 + 60%). The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Applies to new or reconstructed sources only.
d We have assumed that 20 percent of the respondents will repeat performance test for Eb.
e We have assumed that 80 percent of respondents will file an opacity report of no excess emission for Ea.
f We have assumed that 20 percent of respondents will file an opacity report of excess emission for Ea.
g We have assumed that 18 of the respondents will write the appendix F reports four times per year for Ea.
h We have assumed that 5 of the respondents will be required to write semiannual excess emission report for Eb two times per year.
i We have assumed that 5 of the respondents will write the appendix F reports four times per year.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Public v. Private

Table 1b: Annual Respondent Burden and Cost Breakdown by Affected Sector– NSPS for Municipal Solid Waste Combustors (40 CFR Part 60, Subparts Ea and Eb) (Renewal)											# of facilities
Affected Sector	Number of Responses	Labor Hours			Labor Cost	Capital and O&M Cost					Ea	Eb	Total	Percent by Sector
		Reporting	Recordkeeping	Total						Public-Owned	8	5	13	57%
Private	90	11,419	3,591	15,000	$1,380,300	$97,180				Private-Owned	10	0	10	43%
Public (State/Local/Tribal)	119	15,137	4,760	19,900	$1,829,700	$128,820					18	5	23
Total	209	26,556	8,350	34,900	3,210,000	226,000
*Assumes 57% of respondents are public sector owned by state or local entities and privately operated. The remaining facilities are owned and operated by the private sector. There are no Federally-owned facilities.