Burden Calculation Tables

1189t31.xlsx

Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities (Proposed Rule)

Burden Calculation Tables

OMB: 2050-0053

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Overview

Assumptions
Exhibit 1
Exhibit 4_Part 1
Exhibit 6_Part 9
Exhibit X (Phase Two Summary)
Labor Rates
Capital Costs
O&M Costs

Sheet 1: Assumptions
Assumptions Value Source
# Beneficial Users subject to criterion 4 472 Average from high and low estimate in EA
% Beneficial Users triggering location-based standards 5.85% Average from high and low estimate in EA
# investigations required for each beneficial use demonstration for location-based standards 5 EA
# Beneficial Users required to read the regulations 1036 Average from high and low estimate in EA
# CCR Units required to revise corrective action and groundwater reports 764 EA
# owner/operators required to update publically accessible website 5 EA
# owner/operators required to reviese corrective action and groundwater reports 300 EA
# CCR units per owner/operator 2.5 EA (# units / # facilities)

Sheet 2: Exhibit 1

EXHIBIT CCR-1
































DISPOSAL OF COAL COMBUSTION RESIDUALS FROM ELECTRIC UTILITIES





















ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - OWNERS AND OPERATORS OF CCR UNITS a






















Hours and Costs Per Respondent Per Activity Total Hours and Costs






Reporting
Recordkeeping
Third Party Disclosure


Leg. Mgr. Tech. Cler. Respon. Labor Capital/
Number of Total Total
Total Total



Number Total Total Total
Number Total Total Total
Number Total Total Total


$125.14/ $105.75/ $50.98/ $29.90/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/
Capital Cost/ O&M Cost/ Total Labor
Type of
Responses/ Hours/ Capital Cost/ O&M Cost/
Responses/ Hours/ Capital Cost/ O&M Cost/
Responses/ Hours/ Capital Cost/ O&M Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year
Year Year Costs/Year
Activity
Year Year Year Year
Year Year Year Year
Year Year Year Year

Beneficial use of CCR










Location-Based Standard Investigation Costs (annual) 0.00 0.25 1.00 0.75 2.00 $99.84 0.00 0.00 2,360 4,720.00 $235,622.40
$0.00 $0.00 $235,622.40
Reporting
0.00 0.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00

Criterion 4 Demonstration (annual) 2.00 2.00 35.00 1.00 40.00 $2,275.98 0.00 0.00 28 1,104.48 $62,844.36
$0.00 $0.00 $62,844.36
Reporting
27.61 1,104.48 $0.00 $0.00
0.00 0.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00

Read the regulations (one-time) 0.00 0.50 0.50 0.00 1.00 $78.37 0.00 0.00 345 345.34 $27,063.77
$0.00 $0.00 $27,063.77
Reporting
345.33 345.34 $0.00 $0.00
0.00 0.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00

TOTAL Varies Varies Varies Varies Varies Varies $0.00 Varies Varies 6,169.82 $325,530.53
$0.00 $0.00 $325,530.53


372.95 1,449.82 $0.00 $0.00
0.00 0.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00

a Exhibit includes rounding error.































Sheet 3: Exhibit 4_Part 1

EXHIBIT CCR-4
































DISPOSAL OF COAL COMBUSTION RESIDUALS FROM ELECTRIC UTILITIES






























ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - OWNERS AND OPERATORS OF CCR UNITS a




























Hours and Costs Per Respondent Per Activity Total Hours and Costs






Reporting
Recordkeeping
Third Party Disclosure


Leg. Mgr. Tech. Cler. Respon. Labor Capital/
Number of Total Total
Total Total



Number Total Total Total
Number Total Total Total
Number Total Total Total


$125.14/ $105.75/ $50.98/ $29.90/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/
Capital Cost/ O&M Cost/ Total Labor
Type of
Responses/ Hours/ Capital Cost/ O&M Cost/
Responses/ Hours/ Capital Cost/ O&M Cost/
Responses/ Hours/ Capital Cost/ O&M Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year
Year Year Costs/Year
Activity
Year Year Year Year
Year Year Year Year
Year Year Year Year

Groundwater Monitoring and Corrective Action










Applicability (40 CFR 257.90)










Revisions to the Annual Groundwater Monitoring and Corrective Action Report Requirements (One-time) 0.00 1.00 1.00 0.00 2.00 $156.73 $0.00 $0.00 255 509.34 $39,913.91
$0.00 $0.00 $39,913.91
Reporting
254.67 509.34 $0.00 $0.00
0.00 0.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00

Revisions to the Annual Groundwater Monitoring and Corrective Action Report Requirements (Annual) 0.00 0.50 1.00 0.00 1.50 $103.86 $0.00 $0.00 764 1,146.00 $79,349.04
$0.00 $0.00 $79,349.04
Reporting
764.00 1,146.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00

a Exhibit includes rounding error.
































TOTAL Varies Varies Varies Varies Varies Varies $0.00 Varies Varies 1,655.34 $119,262.95
$0.00 $0.00 $119,262.95


1,018.67 1,655.34 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Sheet 4: Exhibit 6_Part 9

EXHIBIT CCR-6 (continued)
































DISPOSAL OF COAL COMBUSTION RESIDUALS FROM ELECTRIC UTILITIES






























ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - OWNERS AND OPERATORS OF CCR UNITS a




























Hours and Costs Per Respondent Per Activity Total Hours and Costs






Reporting
Recordkeeping
Third Party Disclosure


Leg. Mgr. Tech. Cler. Respon. Labor Capital/
Number of Total Total
Total Total



Number Total Total Total
Number Total Total Total
Number Total Total Total


$125.14/ $105.75/ $50.98/ $29.90/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/
Capital Cost/ O&M Cost/ Total Labor
Type of
Responses/ Hours/ Capital Cost/ O&M Cost/
Responses/ Hours/ Capital Cost/ O&M Cost/
Responses/ Hours/ Capital Cost/ O&M Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year
Year Year Costs/Year
Activity
Year Year Year Year
Year Year Year Year
Year Year Year Year

Recordkeeping, Notification, and Posting of Information to the Internet










Publicly Accessible Internet Site Requirements (40 CFR 257.107)










Develop Internet Site





















Update Website (One-time) 0.00 1.00 1.00 0.00 2.00 $156.73 $0.00 $0.00 2 3.34 $261.22
$0.00 $0.00 $261.22
Reporting
1.67 3.34 $0.00 $0.00
0.00 0.00 $0.00 $0.00
0.00 0.00 $0.00 $0.00

a Exhibit includes rounding error.































Sheet 5: Exhibit X (Phase Two Summary)
EXHIBIT X




DISPOSAL OF COAL COMBUSTION RESIDUALS FROM ELECTRIC UTILITIES




TOTAL ESTIMATED RESPONDENT HOUR AND COST BURDEN SUMMARY a

















Annual Burden Hours Annual Labor Cost Annual Capital/ Startup Cost Annual O&M Cost Total Annual Cost
Beneficial Use (Exhibit 1) 6,170 $325,531 $0 $0 $325,531
Groundwater Monitoring and Corrective Action (Exhibit 4) 1,655 $119,263 $0 $0 $119,263
Recordkeeping, Notification, and Posting of Information to the Internet - Owners and Operators of CCR Units (Exhibit 6) 3 $261 $0 $0 $261
Total 7,829 $445,055 $0 $0 $445,055
3-year Total 23,486 $1,335,163 $0 $0 $1,335,163
a Exhibit includes rounding error.






















Number of Annual Responses 3753



Sheet 6: Labor Rates
Owners and Operators of CCR Units


(Note: changes here WILL be reflected in the column headings of the tables.)






Labor Category Occupation code May 2017 Mean Hourly Ratea Fringe Benefits Rateb Overhead Ratec Fringe/Overhead Multiplier Employment Cost Index Adjustment to 2018 Levels d 2018 Loaded Rate
Legal 23-1011 $68.22 33.3% 12% 1.78 1.028 $125.14
Managerial 11-0000 $57.65 33.3% 12% 1.78 1.028 $105.75
Technical 17-3026 $27.79 33.3% 12% 1.78 1.028 $50.98
Clerical 43-9061 $16.30 33.3% 12% 1.78 1.028 $29.90
a Mean hourly rates from U.S. Bureau of Labor Statistics (BLS)’s May 2017 National Industry-Specific Occupational Employment and Wage Estimates cross all industry sectors, at: http://www.bls.gov/oes/current/oes_nat.htm.


b Applied “All goods-producing” industry group fringe benefits percentage of 33.3% from “Table 6. Private industry, by major industry group” of the US Bureau of Labor Statistics (BLS) “Employer Costs for Employee Compensation” (ECEC), June 2018 at https://www.bls.gov/news.release/ecec.t06.htm.


c In absence of data specific to industry, applied 12% Federal civilian overhead cost factor from Figure C1 of the REVISED February 2008 OMB Circular A-76 at http://www.whitehouse.gov/omb/circulars_a076_a76_incl_tech_correction/.


d Bureau of Labor Statistics, "Table 4. Employment Cost Index for total compensation, for civilian workers, by occupational and industry," Employment Cost Index Historical Listing - Volume V, Continuous Occupational and Industry Series, September 1975 – June 2018; July 2018. Available online at: https://www.bls.gov/web/eci/ecicois.pdf, last accessed on October 29, 2018. Civilian Workers, All Workers, June 2017=129.7 and June 2018=133.3.


















State Government Agencies and Tribal Authorities


(Note: changes here WILL be reflected in the column headings of the tables.)






Labor Category Occupation code May 2017 Mean Hourly Ratea Fringe Benefits Rateb Overhead Ratec Fringe/Overhead Multiplier d Employment Cost Index Adjustment to 2018 Levels e 2018 Loaded Rate
Legal 23-1011 $43.32 37.6% 12% 1.97 1.0230 $87.25
Managerial 11-0000 $42.17 37.6% 12% 1.97 1.0230 $84.94
Technical 19-4091 $22.45 37.6% 12% 1.97 1.0230 $45.22
Clerical 43-9061 $16.02 37.6% 12% 1.97 1.0230 $32.27
a U.S. Bureau of Labor Statistics (BLS)’s May 2017 National Industry-Specific Occupational Employment and Wage Estimates for NAICS 999200 – State Government (OES Designation), at: http://www.bls.gov/oes/current/naics4_999200.htm#b17-0000


b Applied 37.6% fringe benefits percentage from “Table 3. State and local government, by major occupational and industry group” of the US Bureau of Labor Statistics (BLS) “Employer Costs for Employee Compensation” (ECEC), June 2018 at https://www.bls.gov/news.release/ecec.t03.htm.


c In absence of data specific to state governments, applied 12% Federal civilian overhead cost factor from Figure C1 of the REVISED February 2008 OMB Circular A-76 http://www.whitehouse.gov/omb/circulars_a076_a76_incl_tech_correction/.


d Bureau of Labor Statistics, "Table 7. Employment Cost Index for total compensation, for State and local government workers, by occupational and industry," Employment Cost Index Historical Listing - Volume V, Continuous Occupational and Industry Series, September 1975 – June 2018; July 2018. Available online at: https://www.bls.gov/web/eci/ecicois.pdf, last accessed on October 29, 2018. State and local government workers, All workers, June 2017=132.0 and June 2018=135.1.










Agency


Labor Category GS Code January 2018 Base Rate a Overhead Rate 2018 Loaded Rate


Legal GS-15, Step 5 57.09 1.6 $91.34


Managerial GS-15, Step 1 50.37 1.6 $80.59


Technical GS-13, Step 1 36.24 1.6 $57.98


Clerical GS-06, Step 1 15.46 1.6 $24.74


a Office of Policy and Management (OPM) 2018 General Schedule (Base) Hourly Rate Pay Table. Accessed October 30, 2018 at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2018/general-schedule/.


Sheet 7: Capital Costs
Item Cost Data Source









Sheet 8: O&M Costs
Item 2018 Cost Data Source
Generic cost for engineer certification $380.00 Based on cost of $340 in RIA, 2011 dollars.

Bureau of Labor Statistics, "Historical Consumer Price Index for All Urban Consumers (CPI-U): U. S. city average, all items, by month." September 2018. Available online at: https://www.bls.gov/cpi/tables/supplemental-files/historical-cpi-u-201809.pdf, last accessed on October 26, 2018. All items, December 2011=225.672 and September 2018=252.439.
Development EAP - surface impoundment $1,119.00 Based on cost of $1,000 in RIA, 2011 dollars.

Bureau of Labor Statistics, "Historical Consumer Price Index for All Urban Consumers (CPI-U): U. S. city average, all items, by month." September 2018. Available online at: https://www.bls.gov/cpi/tables/supplemental-files/historical-cpi-u-201809.pdf, last accessed on October 26, 2018. All items, December 2011=225.672 and September 2018=252.439.
Development/Amendment of Fugitive Dust Control Plan $5,593.00 Based on cost of $1,000 in RIA, 2011 dollars.

Bureau of Labor Statistics, "Historical Consumer Price Index for All Urban Consumers (CPI-U): U. S. city average, all items, by month." September 2018. Available online at: https://www.bls.gov/cpi/tables/supplemental-files/historical-cpi-u-201809.pdf, last accessed on October 26, 2018. All items, December 2011=225.672 and September 2018=252.439.
Documentation on the design, installation, development, and decommissioning of any monitoring wells, piezometers and other measurement, sampling, and analytical devices $104,384.00 Based on cost of $93,316 in RIA, 2011 dollars.

Bureau of Labor Statistics, "Historical Consumer Price Index for All Urban Consumers (CPI-U): U. S. city average, all items, by month." September 2018. Available online at: https://www.bls.gov/cpi/tables/supplemental-files/historical-cpi-u-201809.pdf, last accessed on October 26, 2018. All items, December 2011=225.672 and September 2018=252.439.
Development of sampling and analysis program $16,779.00 Based on cost of $15,000 in RIA, 2011 dollars.

Bureau of Labor Statistics, "Historical Consumer Price Index for All Urban Consumers (CPI-U): U. S. city average, all items, by month." September 2018. Available online at: https://www.bls.gov/cpi/tables/supplemental-files/historical-cpi-u-201809.pdf, last accessed on October 26, 2018. All items, December 2011=225.672 and September 2018=252.439.
Report describing selected remedy $100,295.00 Based on cost of $89,660 (90,000 -340) in RIA, 2011 dollars.

Bureau of Labor Statistics, "Historical Consumer Price Index for All Urban Consumers (CPI-U): U. S. city average, all items, by month." September 2018. Available online at: https://www.bls.gov/cpi/tables/supplemental-files/historical-cpi-u-201809.pdf, last accessed on October 26, 2018. All items, December 2011=225.672 and September 2018=252.439.
Closure and post-closure plan $13,938.00 Based on cost of $12,460 (12,800 -340) in RIA, 2011 dollars.

Bureau of Labor Statistics, "Historical Consumer Price Index for All Urban Consumers (CPI-U): U. S. city average, all items, by month." September 2018. Available online at: https://www.bls.gov/cpi/tables/supplemental-files/historical-cpi-u-201809.pdf, last accessed on October 26, 2018. All items, December 2011=225.672 and September 2018=252.439.
Standard Envelope (4 1/8" x 9 1/2") $0.03 Based on cost from Staples' Web site: Standard Business Envelopes with Gummed Closure, 500/Box for $15.99 (http://www.staples.com/Staples-10-Standard-Business-Gummed-Envelopes-500-Box/product_187013, last accessed on December 8, 2017)
First Class Postage (1 ounce) $0.49 U.S. Postal Service (https://www.usps.com/business/prices.htm?, last accessed on December 8, 2017)
Certified Mail Service $3.35 U.S. Postal Service (https://www.usps.com/ship/insurance-extra-services.htm, last accessed on December 8, 2017)
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