Burden Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal)
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 year a	(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 year b
1. Applications	N/A									State/Federal Govt. Labor Rates:
2. Survey and Studies	N/A									Management	65.71	These rates were updated 2/4/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
3. Reporting Requirements (States)										Technical	48.75
A. Familiarize with Regulatory Requirements c	1	1	1	22	22	1.1	2.2	$2,881.82		Clerical	26.38
B. Required activities d
- Development of State Plan/Inventory	2,080	1	2,080	0	0	0	0	$0		Private Industry Labor Rates:
- Annual update of State Plan Inventory	20	1	20	22	440	22	44	$57,636.48		Management	147.40	These rates were updated 2/4/19 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
- Public hearing on State Plan	8	1	8	0	0	0	0	$0		Technical	117.92
C. Create information	See 3B									Clerical	57.02
D. Gather information	See 3B
E. Write report
- State Plan/Inventory	See 3B
- Annual update of State Plan Inventory	See 3B
- Notification of public hearing on State Plan	8	1	8	0	0	0	0	$0
- Certification that public hearing on State Plan conducted according to Subpart B State procedures	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements (States)					531			$60,518
4. Reporting requirements (privately-owned HMIWI)
A. Familiarize with Regulatory Requirements c	1	1	1	31	31	1.55	3.1	$4,060.75
B. Required activities e
Annual update of operating information f	20	1	20	31	620	31	62	$81,215.04
Review operating information with each operator g	8	2	16	31	496	24.8	49.6	$64,972.03
Annual equipment inspection (small rural HMIWI)	20	1	20	1	20	1	2	$2,619.84
Annual equipment inspection (all other HMIWI)	20	1	20	30	600	30	60	$78,595.20
C. Create information	See 4B
D. Gather information	See 4B
E. Write report e
Annual report
CMS operating parameters	32	1	32	31	992	49.6	99.2	$129,944.06
Emissions/parameter exceedances and periods when emission/parameter data not obtained j
- Small rural HMIWI	16	1	16	0.2	3.2	0.16	0.32	$419.17
- All other HMIWI	64	1	64	6	384	19.2	38.4	$50,300.93
Report of annual performance test
- Small rural HMIWI	20	1	20	1	20	1	2	$2,619.84
- All other HMIWI	280	1	280	30	8,400	420	840	$1,100,332.80
Report of no exceedances
- Small rural HMIWI	8	1	8	0.8	6.4	0.32	0.64	$838.35
- All other HMIWI	32	1	32	24	768	38.4	76.8	$100,601.86
Report of annual equipment inspection	See 4B
Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained (small non-rural, medium, and large HMIWI) j	32	2	64	6	384	19.2	38.4	$50,300.93
Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained (small rural HMIWI) j	8	2	16	0.2	3.2	0.16	0.32	$419.17
Subtotal for Reporting Requirements (Privately-owned HMIWI)					14,637			$1,667,240
5. Reporting requirements (Federally-owned HMIWI)
A. Familiarize with Regulatory Requirements c	1	1	1	5	5	0.25	0.5	$273.37
B. Required activities
Annual update of operating information f	20	1	20	5	100	5	10	$5,467.35
Review operating information with each operator g	8	2	16	5	80	4	8	$4,373.88
Annual control equipment inspection	20	1	20	5	100	5	10	$5,467.35
C. Create information	NA
D. Gather existing information	See 5B
E. Write report
Annual report
CMS operating parameters	32	1	32	5	160	8	16	$8,747.76
Emissions/parameter exceedances and periods when emission/parameter data not obtained j	64	1	64	1	64	3.2	6.4	$3,499.10
Report of annual performance test	40	1	40	5	200	10	20	$10,934.70
Report of no exceedances	32	1	32	4	128	6.4	12.8	$6,998.21
Report of annual equipment inspection	See 5B
Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained j	32	2	64	1	64	3.2	6.4	$3,499.10
Subtotal for Reporting Requirements (Federally-owned HMIWI)					1,036			$49,261
6. Reporting requirements (State/locally-owned HMIWI)
A. Familiarize with Regulatory Requirements c	1	1	1	0	0	0	0	$0
B. Required activities
Annual update of operating information	20	1	20	0	0	0	0	$0
Review operating information with each operator	8	2	16	0	0	0	0	$0
Annual control equipment inspection	20	1	20	0	0	0	0	$0
C. Create information	NA
D. Gather existing information	See 6B
E. Write report
Annual report
CMS operating parameters	32	1	32	0	0	0	0	$0
Emissions/parameter exceedances and periods when emission/parameter data not obtained j	64	1	64	0	0	0	0	$0
Report of annual performance test	40	1	40	0	0	0	0	$0
Report of no exceedances j	32	1	32	0	0	0	0	$0
Report of annual equipment inspection	See 6B
Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained j	32	2	64	0	0	0	0	$0
Subtotal for Reporting Requirements (State/locally-owned HMIWI)					0			$0
7. Reporting requirements (co-fired combustors and pathological/low-level radioactive/chemotherapeutic waste combustors)
A. Familiarize with Regulatory Requirements c, k	1	1	1	13.4	13.4	0.67	1.34	$1,755
B. Required activities	N/A
C. Create information	N/A
D. Gather existing information	N/A
E. Write report
Notification of exemption claim	2	1	2	0	0	0	0	$0
Notification of relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted (co-fired combustors only)	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements (Co-fired combustors and pathological/low-level radioactive/chemotherapeutic waste combustors)					15			$1,755
8. Recordkeeping requirements (States)
A. Familiarize with Regulatory Requirements	See 3A
B. Plan activities	NA
C. Implement activities	NA
D. Develop record system	NA
E. Time to enter information	NA
F. Time to train personnel	NA
G. Time for audits	NA
Subtotal for Recordkeeping Requirements (States)					0			$0
9. Recordkeeping requirements (privately-owned HMIWI)
A. Familiarize with Regulatory Requirements	See 4A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdown, malfunction	1.5	52	78	31	2,418	120.9	241.8	$316,738.66
Records of persons reviewing operating information	2	2	4	31	124	6.2	12.4	$16,243.01
Records of operators completing training requirements	2	1	2	0	0	0	0	$0
Records of operators that have been qualified	2	1	2	0	0	0	0	$0
Records of initial performance test	See 4E
Records of process and control device operating parameters
- Small rural HMIWI	0.5	52	26	1	26	1.3	2.6	$3,405.79
- All other HMIWI	1.5	52	78	30	2,340	117.0	234	$306,521.28
Records of CMS operation and maintenance
- Small rural HMIWI	0.5	250	125	1	125	6.25	12.5	$16,374.00
- All other HMIWI	1.5	250	375	30	11,250	562.5	1,125.0	$1,473,660.00
Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j
- Small rural HMIWI	0.5	52	26	0.2	5.2	0.26	0.52	$681.16
- All other HMIWI	1.5	52	78	6	468	23.4	46.8	$61,304.26
Records of annual and subsequent compliance tests	See 4E
Records of annual equipment inspection	See 4B
F. Time to train personnel	40	1	40	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements (Privately-owned HMIWI)					19,270			$2,194,928
10. Recordkeeping requirements (Federally-owned HMIWI)
A. Familiarize with Regulatory Requirements	See 5A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdown, malfunction	1.5	52	78	5	390	19.5	39	$21,322.67
Records of persons reviewing operating information	2	2	4	5	20	1	2	$1,093.47
Records of operators completing training requirements	2	1	2	0	0	0	0	$0
Records of operators that have been qualified	2	1	2	0	0	0	0	$0
Records of initial performance test	See 5E
Records of process and control device operating parameters	1.5	52	78	5	390	19.5	39	$21,322.67
Records of CMS operation and maintenance	1.5	250	375	5	1,875	93.75	187.5	$102,512.81
Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j	1.5	52	78	1	78	3.9	7.8	$4,264.53
Records of annual and subsequent compliance tests	See 5E
Records of annual equipment inspection	See 5B
F. Time to train personnel	40	1	40	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements (Federally-owned HMIWI)					3,166			$150,516
11. Recordkeeping requirements (State/locally-owned HMIWI)
A. Familiarize with Regulatory Requirements	See 6A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdown, malfunction	1.5	52	78	0	0	0	0	$0
Records of persons reviewing operating information r	2	2	4	0	0	0	0	$0
Records of operators completing training requirements	2	1	2	0	0	0	0	$0
Records of operators that have been qualified	2	1	2	0	0	0	0	$0
Records of initial performance test	See 6E
Records of process and control device operating parameters	1.5	52	78	0	0	0	0	$0
Records of CMS operation and maintenance	1.5	250	375	0	0	0	0	$0
Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j	1.5	52	78	0	0	0	0	$0
Records of annual and subsequent compliance tests	See 6E
Records of annual equipment inspection	See 6B
F. Time to train personnel	40	1	40	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements (State/Locally-owned HMIWI)					0			$0
12. Recordkeeping requirements (co-fired and pathological/low-level radioactive/ chemotherapeutic combustors)
A. Familiarize with Regulatory Requirements	See 7A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Quarterly records of periods when only pathological, low-level radioactive, chemotherapeutic waste burned k	2	4	8	13.4	107.2	5.36	10.72	$14,042.34
Quarterly records of weight of hospital waste and medical/infectious waste combusted, and weight of all other fuels and waste combusted (co-fired only) k	2	4	8	5	40	2	4	$5,239.68
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements (Co-fired and pathological/low level radioactive / chemotherapeutic combustors)					169			$19,282
TOTAL REPORTING REQUIREMENTS (FROM SUBTOTALS)					16,220			$1,778,774
TOTAL RECORDKEEPING REQUIREMENTS (FROM SUBTOTALS)					22,605			$2,364,726
TOTAL LABOR BURDEN AND COSTs (rounded) l,m					38,800			$4,140,000		4,202	Federally owned burden
TOTAL CAPITAL AND O&M COST (rounded) l								$479,000
GRAND TOTAL (rounded) l								$4,620,000
										224	hr/response
Note: States and tribes may choose to impose requirements that are more stringent. However, the burden estimates provided in this ICR assume that the state and tribal plans mirror the federal Emission Guidelines.
Assumptions:
a We have assumed that there are approximately 58 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. The breakdown is as follows: 31 privately-owned HMIWI (including 1 small rural HMIWI), 5 Federally-owned HMIWI, and 0 State/locally-owned HMIWI. Additionally, there are 22 States that require annual State Plan Inventory.
b This ICR uses the following labor rates for industry: $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% to account for the benefit packages available to those employed by private industry. In addition, this ICR uses the following labor rates for Federal and State government: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). 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 State government employees and government overhead expenses.
c We have assumed all respondents will have to familiarize with regulatory requirements
d Assume all 22 states with HMIWI have approved State Plan by the first year of this ICR. However, the State Plan/Inventory is updated on an annual basis.
e The zero value for number of respondents indicates that burden was incurred prior to the time period covered by this supporting statement or for new respondents.
f We have assumed that it would take each respondent 20 hours each to update the annual operating information.
g We have assumed that it would take each respondent 8 hours to review the operating information with each operator.
h We have assumed that each facility will take 160 hours to develop the operating information.
i We have assumed that each facility will take 40 hours to develop the waste management plan.
j Assume 20 percent of respondents report exceedances, and 80 percent report no exceedances.
k We have assumed that all co-fired and pathological/low-level radioactive/ chemotherapeutic combustors units would be owned by the private sector. We assume an average of 13.4 units per year (which includes 5 co-fired units) will need to re-familiarize themselves with regulatory requirements over the three-year period of this ICR.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
m Total includes 4,200 hours from Federally-owned and operated facilities.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal)
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 year a	(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 year b
1. Initial performance test	32	1	32	0	0	0	0	$0		Labor Rates:
2. Repeat performance test										Management	65.71	These rates were updated 2/4/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
A. Retesting preparation	12	1	12	0	0	0	0	$0		Technical	48.75
B. Attend retesting	32	1	32	0	0	0	0	$0		Clerical	26.38
3. Report review
A. Review reports for co-fired combustors
Review notification of exemption claim	2	1	2	0	0	0	0	$0
Review notification of relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted	2	1	2	0	0	0	0	$0
B. Review notification of exemption claim for pathological, low-level radioactive, chemotherapeutic combustors	2	1	2	0	0	0	0	$0
C. Review reports of increments of progress
Review control plan	4	1	4	0	0	0	0	$0
Review notification of construction contracts	2	1	2	0	0	0	0	$0
Review notification of construction commencement	2	1	2	0	0	0	0	$0
Review notification of construction completion	2	1	2	0	0	0	0	$0
Review notification of control plan completion	2	1	2	0	0	0	0	$0
D. Review request for extension for HMIWI planning to shut down late	4	1	4	0	0	0	0	$0
E. Review reports for small non-rural, medium and large HMIWI
Review waste management plan	8	1	8	0	0	0	0	$0
Review notification of initial performance test	8	1	8	0	0	0	0	$0
Review notification of initial CMS demonstration	5	1	5	0	0	0	0	$0
Review report of initial performance test	36	1	36	0	0	0	0	$0
Review report of initial CMS demonstration	24	1	24	0	0	0	0	$0
Review annual report
CMS operating parameters
- Small rural HMIWI	2	1	2	1	2	0.1	0.2	$109.35
- All other HMIWI	6	1	6	35	210	10.5	21	$11,481.44
Emissions/parameter exceedances and periods when emission/parameter data not obtained c
- Small rural HMIWI	4	1	4	0.2	0.8	0.04	0.08	$43.74
- All other HMIWI	16	1	16	7	112	5.6	11.2	$6,123.43
Results of annual performance test
- Small rural HMIWI	6	1	6	1	6	0.3	0.6	$328.04
- All other HMIWI	24	1	24	35	840	42	84	$45,925.74
Report of no exceedances
- Small rural HMIWI	2	1	2	0.8	1.6	0.08	0.16	$87.48
- All other HMIWI	8	1	8	28	224	11.2	22.4	$12,246.86
Review semiannual report of emissions/ parameter exceedances and periods when emission/parameter data not obtained c
- Small rural HMIWI	2	1	2	0.2	0.4	0.02	0.04	$21.87
- All other HMIWI	8	1	8	7	56	2.8	5.6	$3,061.72
Report of annual equipment inspection (Small rural HMIWI)	4	1	4	1	4	0.2	0.4	$218.69
Report of annual control equipment inspection (All other HMIWI)	4	1	4	0	0	0	0	$0
G. Review reports for States
Review annual update of State Plan Inventory d	8	1	8	22	176	8.8	17.6	$9,622.54
4. Prepare annual summary report e	1	1	1	36	36	1.8	3.6	$1,968.25
TOTAL (rounded) f					1,920			$91,000
Assumptions:
a We have assumed that there are approximately 58 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. The breakdown is as follows: 31 privately-owned HMIWI (including 1 small rural HMIWI), 5 Federally-owned HMIWI, and 0 State/locally-owned HMIWI. Additionally, there are 22 States that require annual State Plan Inventory.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c Assume 20 percent of respondents report parameter exceedances, and 80 percent report no exceedances.
d Assume all 22 States have approved State/Plan Inventory. All States are expected to update State Plan/Inventory annually.
e We have assumed that all respondents will have to prepare annual summary report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding