Burden Calculation Tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year	Clerical hours per year	Total cost per year ($) b
			(C=AxB)			(F=Ex0.05)	(G=Ex0.10)
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$141.06
3. Reporting Requirements										Technical	$120.27
A. Familiarize with regulatory requirements c, d	16	1	16	74	1,184	59.2	118	$157,696.96		Clerical	$58.67
B. Required Activities
1) Initial requirements e
a) Initial stack test and report	16	1	16	0	0	0	0	$0
b) Establish and teach operator qualification course	64	1	64	0	0	0	0	$0
c) Obtain operator qualification	72	1	72	0	0	0	0	$0
d) Establish operating parameters (maximum and minimum)	160	1	160	0	0	0	0	$0
e) Continuous parameter monitoring initial costs (including by-pass stack) f	9	1	9	0	0	0	0	$0
2) Periodic requirements
a) Annual stack test and test report (PM, HCl, and opacity)	12	1	12	74	888	44.4	88.8	$118,272.72
b) Annual refresher operator training course	12	1	12	74	888	44.4	88.8	$118,272.72
c) Annual review of site-specific information	8	1	8	74	592	29.6	59.2	$78,848.48
d) Continuous parameter monitoring (including by-pass stack) annual costs g	83	1	83	74	6,142	307	614	$818,052.98
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Control plan	40	1	40	0	0	0	0	$0
2) Notification of final compliance	4	1	4	0	0	0	0	$0
3) Report of initial performance test	8	2	16	0	0	0	0	$0
4) Siting analysis for new units only (establishes values for site-specific operating parameters)	8	1	8	0	0	0	0	$0
5) Waste management plan	160	1	160	0	0	0	0	$0
6) Annual Report h
a) Site-specific operating parameters	8	1	8	74	592	29.6	59.2	$78,848.48
b) Emissions/parameter exceedances and malfunctions	See 3E
c) Results of stack tests conducted during the year	See 3B
d) Statement of no exceedances i	8	1	8	66.6	533	26.6	53.3	$70,963.63
e) Documentation of use of by-pass stack	See 3B
f) Documentation for periods when all qualified operators were unavailable for more than 8 hours	8	1	8	74	592	29.6	59.2	$78,848.48
7) Status report for operators that are off-site for more than 2 weeks j	8	1	8	7.4	59	2.96	5.92	$7,884.85
8) Corrective action summary for operators that are off-site for more than 2 weeks j	8	2	16	7.4	118	5.92	11.8	$15,769.70
9) Qualified operator deviation notification of resumed operation	8	1	8	7.4	59.2	2.96	5.92	$7,884.85
10) Semiannual report of emissions/parameter exceedances i	12	2	24	7.4	178	8.88	17.8	$23,654.54
Subtotal for Reporting Requirements					13,599			$1,574,998
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c, d	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record Information
1) Records of operating parameters	See 3B
2) Records of periods for which minimum amount of data on operating parameters were not obtained	0.5	52	26	7.4	192	9.62	19.2	$25,625.76
3) Records of malfunction of the unit	1.5	1	1.5	7.4	11.1	0.56	1.11	$1,478.41
4) Records of exceedances of operating parameters	1.5	1	1.5	7.4	11.1	0.56	1.11	$1,478.41
5) Records of stack tests	See 3E
6) Records of persons who have reviewed operating procedures	1	1	1	74	74	3.7	7.4	$9,856.06
7) Records of persons who have completed operator training	1	1	1	74	74	3.7	7.4	$9,856.06
8) Records of persons who meet operator qualification criteria	1	1	1	74	74	3.7	7.4	$9,856.06
9) Records of monitoring device calibration	See 3B
10) Records of site-specific documentation	24	1	24	74	1,776	88.8	178	$236,545.44
F. Personnel Training	See 3B
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					2,544			$294,696
Total Labor Burden and Costs (rounded) k					16,100			$1,870,000
Total Capital and O&M Cost (rounded) k								$1,130,000
Grand Total (rounded) k								$3,000,000
Assumptions:
a We estimate that an average of 74 existing respondents and zero new respondents per year will be subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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.
c We assume that all respondents will have to familiarize themselves with the regulatory requirements each year.
d Cost is incurred by a facility regardless of the number of affected units at the plant.
e This activity is based on a one-time cost only.
f Based on the “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions (A-91-61,IV-B-66)," we assume 9 hours (($300 for planning + $500 for selection)/$89.94 per hour = 9 hours).
g Based on the "Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions (A-91-61, IV-B-66)," respondents spend 83 hours for reporting.
h Respondents make one combined annual report per year.
i We assume that 10 percent of the facilities will have an exceedance during the year. The remaining 90% of facilities would submit a statement of no exceedance.
j Assume that 10 percent of facilities will not have a qualified operator available for more than two weeks at least once a year, and that two corrective action summaries will be required.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences Per Respondent Per Year	EPA Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CXD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Total Costs, $ b
1. Applications	N/A									Labor Rates
2. Familiarize with regulatory requirements	16	1	16	0	0	0	0	$0		Management	$66.62
3. Required Activities										Technical	$49.44
Report Reviews										Clerical	$26.75
1) Review control plan	8	1	8	0	0	0	0	$0
2) Review notification of final compliance	8	1	8	0	0	0	0	$0
3) Review waste management plan	8	1	8	0	0	0	0	$0
4) Review initial stack test report	40	1	40	0	0	0	0	$0
5) Review annual compliance report	8	1	8	74	592	29.6	59.2	$32,824
6) Review semi-annual excess emission and parameter exceedance report c	16	1	16	7.4	118.4	5.92	11.84	$6,565
7) Review status reports and corrective action summary for operators off-site	4	1	4	7.4	29.6	1.48	2.96	$1,641
TOTAL (rounded) d					851			$41,000
Assumptions:
a We estimate that an average of 74 existing respondents and zero new respondents per year will be subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 assume that 10 percent of the facilities will have exceedance reports and operator off-site reports.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records but Do Not Submit Reports	Total Annual Responses E=(BxC)+D
State plans	0	1	0	0
Construction/reconstruction notification	0	1	0	0
Startup notification	0	1	0	0
Demonstration date of continuous monitoring system performance notification	0	1	0	0
Anticipated date for conducting opacity observations notification	0	1	0	0
Use of continuous opacity monitoring system data notification	0	1	0	0
Final control plan notification	0	1	0	0
Final compliance notification	0	1	0	0
Waste management plan	0	1	0	0
Initial performance test report	0	1	0	0
Annual report a	74	1	0	74
Emission limitation or operating limit deviation report b	7.4	2	0	14.8
Qualified operator deviation notification b	7.4	2	0	14.8
Qualified operator deviation status report b	7.4	1	0	7.4
Qualified operator deviation notification of resumed operation b	7.4	1	0	7.4
			Total (rounded)	118
a Annual reports are not required until the second year that units are in operation; therefore, annual reports will only apply to existing sources (i.e., 74 respondents).
b Assume that these activities will apply to 10 percent of existing sources.
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	74	0	0	74
2	0	74	0	0	74
3	0	74	0	0	74
Average	0	74	0	0	74
Note: New respondents include sources with constructed, reconstructed and modified affected facilities.
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)
Wet scrubber a	$2,240	0	$0	$0	0	$0
Annual stack testing b	$0	0	$0	$15,034	74	$1,112,516
Continuous parameter monitoring (including bypass stack) c	$0	0	$0	$211	74	$15,614
		Total	$0		Total d	$1,130,000
a Total capital cost of parameter monitoring for wet scrubbers minus planning and equipment selecting cost equals: $18,786 - $800 = $17,986. Based on 0.11746 capital recovery factor, 10 percent interest rate, and 20 year lifetime of the units = $2,113; $2,113 x 1.06 cost adjustment = $2,240.
b Assume 125 contractor hours per respondent and an average contractor labor rate of $120.27 per hour. The labor rate is based on the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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.
c Based on the memorandum titled " Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions (A-91-61,IV-B-66)," O&M cost = $1,693 x 0.11746 = $199; $199 x 1.06 cost adjustment = $211.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Summary of Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal)
Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs	Hours per Response
74	118	13,599	2,544	16,100	$1,870,000	$1,130,000	$3,000,000	136