Burden Calculation Tables

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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)
						117.92	147.4	57.02	188.26
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	39	1,560	78	156	0	$204,347.52	<--updated to 39 respondents (facilities)
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	$285,533.81
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	$853,457.62
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	$3,535,728.14
d) Plants that qualify for reduced D/F testing with 3 units	24	2,106	1	24	15	360	18	36	31,590	$5,994,290.52
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a) RATA audit (one per year)e	8	350	1	8	104	832	41.6	83.2	36,400	$6,961,649.34	<--updated to 104 resp (units)
b) RAA audit (three per year)e	8	130	3	24	104	2,496	124.8	249.6	40,560	$7,962,781.63	<--updated to 104 resp (units)
c) Daily calibration and operation	1	0	365	365	104	37,960	1,898	3,796	0	$4,972,456.32	<--updated to 104 resp (units)
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 performance tests 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) Notification of starting or stopping use of the CEMS	4	0	1	4	0	0	0	0	0	$0
7) Air Curtain incinerator initial performance tests	4	0	1	4	0	0	0	0	0	$0
8) Annual compliance reports	40	0	1	40	39	1,560	78	156	0	$204,347.52	<--updated to 39 respondents (facilities)
9) Semi-annual excess emission reports f	40	0	2	80	8	640	32	64	0	$83,834.88	<--updated to 20% of 39
10) Notification of exemptions	4	0	1	4	0	0	0	0	0	$0
Subtotal for Reporting						185,775				$31,058,427
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	104	19,552	977.6	1,955	0	$2,561,155.58	<--updated to 104 resp (units)
2) Records of all emission rates, computations, tests g	4	0	47	188	104	19,552	977.6	1,955	0	$2,561,155.58	<--updated to 104 resp (units)
3) Records of employee review of operations manual	4	0	1	4	39	156	7.8	15.6	0	$20,434.75	<--updated to 39 respondents (facilities)
4) Record amount of sorbent used for Hg and dioxin/furan control h	4	0	4	16	104	1,664	83.2	166.4	0	$217,970.69	<--updated to 104 resp (units)
5) Records of emisssion exceedances and periods when emission data not obtained	See 3E
6) Records of CEMS drift tests and Appendix F accuracy assessments	See 4E 1-4
7) Records of initial performance test	See 3E
8) Records of annual performance tests	See 3E
9) Records of opacity limits for air curtain incinerators	See 3E
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping						47,063				$5,360,717
TOTAL LABOR BURDEN AND COST (Rounded)i						233,000				$36,400,000
Capital and O&M Cost i										$998,000	<--updated per O&M table
GRAND TOTAL i										$37,400,000
Assumptions:
a. There are 159 large MWC units located at 62 MWC plants. Of these, there are 104 large MWC units at 39 plants that are privately owned.
b. This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. 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.” 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)
						117.92	147.4	57.02	188.26
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 c	40	0	1	40	23	920	46	92	0	$120,512.64	<--updated to 23 resp (facilities)
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	3	72	3.6	7.2	4,500	$856,601.42
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	$853,457.62
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	$3,807,707.23
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	$6,393,909.89
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a) RATA audit (one per year)e	8	350	1	8	55	440	22	44	19,250	$3,681,641.48	<--updated to 55 resp (units)
b) RAA audit (three per year)e	8	130	3	24	55	1,320	66	132	21,450	$4,211,086.44	<--updated to 55 resp
c) Daily calibration and operation	1	0	365	365	55	20,075	1,003.8	2,008	0	$2,629,664.40	<--updated to 55 resp
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) Notification of starting or stopping use of the CEMS	4	0	1	4	0	0	0	0	0	$0
7) Air Curtain incinerator initial performance tests	4	0	1	4	0	0	0	0	0	$0
8) Annual compliance reports	40	0	1	40	23	920	46	92	0	$120,512.64	<--updated to 23 resp
9) Semi-annual excess emission reports f	40	0	2	80	4.6	368	18.4	36.8	0	$48,205.06	<--updated to 4.6 resp
10) Notification of exemptions	4	0	1	4	0	0	0	0	0	$0
Subtotal for Reporting						132,003				$22,723,299
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 g	4	0	47	188	55	10340	517	1034	0	$1,354,457.28	<--updated to 55 resp
2) Records of all emission rates, computations, tests g	4	0	47	188	55	10340	517	1034	0	$1,354,457.28	<--updated to 55 resp
3) Records of employee review of operations manual	4	0	1	4	23	92	4.6	9.2	0	$12,051.26	<--updated to 23 resp
4) Record amount of sorbent used for Hg and dioxin/furan control h	4	0	4	16	55	880	44	88	0	$115,272.96	<--updated to 55 resp
5) Records of emisssion exceedances and periods when emission data not obtained f	See 3E
6) Records of CEMS drift tests and Appendix F accuracy assessments	See 4E 1-4
7) Records of initial performance test	See 3E
8) Records of annual performance tests	See 3E
9) Records of opacity limits for air curtain incinerators	See 3E
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping						24,900				$2,836,239
TOTAL LABOR BURDEN AND COST (Rounded)i						157,000				$25,600,000
Capital and O&M Cost i										$528,000	<--updated per O&M table
GRAND TOTAL i										$26,100,000
Assumptions:
a. There are 159 large MWC units located at 62 MWC plants. Of these, there are 55 large MWC units at 23 plants that are publicly owned.
b. This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. 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.” 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)
			48.75	65.71	26.38
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	15	40	600	30	60	$32,804.10	<-- updated to 15 respondents
3.) Required Activities
A. Develop a state plan	0	2,080	0	0	0	$0
B. Public Hearing on state plan	0	8	0	0	0	$0
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	$14,433.80	<--updated column (A) to 0.2*53= ~ 11 occurances per year
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 notification of starting or stopping use of the CEMS	0	8	0	0	0	$0
9) Review initial performance test report	0	40	0	0	0	$0
10) Review initial CEMS demonstration report	0	40	0	0	0	$0
11) Review annual compliance report g	53	40	2,120	106	212	$115,907.82	<--changed to 53 plants in column (a) (fall under State Plan)
12) Review semi-annual excess emission report f	11	16	176	8.8	17.6	$9,622.54	<--updated to 0.2*53= ~ 11 respondents
13) Review of notifications of exemption	0	4	0	0	0	$0
F. Prepare annual summary report	0	200	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)h			3,630			$173,000
Assumptions:
a. Assume 140 affected units as 53 plants in 15 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 $65.71 Managerial rate (GS-13, Step 5, $41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (GS-6, Step 3, $16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) 2018 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.
e. Assume a 20 percent failure rate and that EPA personnel attend 10 percent of the retests.
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)
			48.75	65.71	26.38
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	1.8	24	43.2	2.16	4.32	$2,361.90	<--changed column (A) to 0.2*9 = 1.8 occurances per year
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 notification of starting or stopping use of the CEMS	0	8	0	0	0	$0
9) Review initial performance test report	0	40	0	0	0	$0
10) Review initial CEMS demonstration report	0	40	0	0	0	$0
11) Review annual compliance report f	9	40	360	18	36	$19,682.46	<-- changed column (a) to 9
12) Review semi-annual excess emission report e	1.8	16	28.8	1.44	2.88	$1,574.60	<--changed column (A) to 0.2*9 = 1.8 occurances per year
13) Review of notifications of exemption	0	4	0	0	0	$0
F. Prepare annual summary report	0	200	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)g			497			$23,600
Assumptions:
a. Assumes 22 affected units at 9 facilities in 4 states without State Plans and thus are subject to the Federal Plan.
b. The cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses $65.71 Managerial rate (GS-13, Step 5, $41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (GS-6, Step 3, $16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) 2018 General Schedule, which excludes locality rates of pay.
c. Assume EPA personnel attend about 8 percent of tests.
d. Assume a 20 percent failure rate and that EPA personnel attend 10 percent of the retests.
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.
g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.