Burden calculations

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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 – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Respondent Hours per Occurrence	Number of Occurrences Per Respondent Per Year	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 Labor Costs Per Year b
1. Applications	N/A									Labor Rates
2. Surveys and Studies	N/A									Management	$141.06
3. Reporting Requirements										Technical	$120.27
A. Familiarize with regulatory requirements c	1	1	1	11	11	0.55	1.1	$1,465.09		Clerical	$58.67
B. Required Activities
1) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2)	See Capital/ Startup Costs			1
2) Annual stack test and test report (PM, HCl, Opacity, and Fugitive Ash)	See O&M Costs			10
3) Operator training and qualification
a) Establish and teach operator qualification course d	64	1	64	1	64	3.2	6.4	$8,524.16
b) Obtain operator qualification d	72	1	72	1	72	3.6	7.2	$9,589.68
c) Annual refresher course	12	1	12	10	120	6	12	$15,982.80
d) Initial review of site-specific information	See 3A
e) Annual review of site-specific information	8	1	8	10	80	4	8	$10,655.20
4) Establish operating parameters (maximum and minimum) d	40	1	40	1	40	2	4	$5,327.60
5) Continuous parameter monitoring (including CEMS)
a) Initial monitoring	17	1	17	1	17	0.85	1.7	$2,264.23
b) Annual monitoring	17	1	17	10	170	8.5	17	$22,642.30
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Notification of initial performance test d
a) Pollutants, fugitive ash emissions	2	1	2	1	2	0.1	0.2	$266.38
b) Fugitive Ash Emissions	1	1	1	1	1	0.05	0.1	$133.19
2) Notification of initial CMS Demonstration d	2	1	2	1	2	0.1	0.2	$266.38
3) Report of initial performance test d
a) Pollutants, fugitive ash emissions	8	1	8	1	8	0.4	0.8	$1,065.52
b) Fugitive Ash Emissions	2	1	2	1	2	0.1	0.2	$266.38
4) Report of initial CMS demonstration	See Capital/ Startup Costs			1
5) Report prior to construction (includes siting analysis) d	160	1	160	1	160	8	16	$21,310.40
6) Report prior to initial start-up d, e
a) Without site specific parameter petition	6	1	6	0.67	4	0.2	0.4	$532.76
b) With site specific parameter petition	14	1	14	0.33	4.7	0.23	0.47	$621.55
7) Report of initial stack test	See 3B(1)
8) Report established values for site-specific operating parameters	See 3B(4)
9) Waste management plan d	160	1	160	1	160	8	16	$21,310.40
10) Annual Report: Results of performance tests conducted during the year	40	1	40	10	400	20	40	$53,276.00
11) Notification for qualified operators that are off-site for more than 2 weeks f	8	2	16	1	16	0.8	1.6	$2,131.04
12) Status report for qualified operators that are off-site for more than 2 weeks f	8	2	16	1	16	0.8	1.6	$2,131.04
13) Semiannual report of emissions/parameter exceedances g	24	2	48	1.1	52.8	2.64	5.28	$7,032.43
Subtotal for Reporting Requirements					1,613			$186,795
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) Records of operating parameters	See 3B(5b)
2) Records of periods for which minimum amount of data on operating parameters were not obtained g	0.5	52	26	1.1	28.6	1.43	2.86	$3,809.23
3) Records of malfunction of the unit g	1.5	1	1.5	1.1	1.65	0.0825	0.165	$219.76
4) Records of exceedances of the operating parameters g	1.5	2	3	1.1	3.3	0.165	0.33	$439.53
5) Records of stack tests	See 3E
6) Records of siting analysis	See 3E
7) Records of persons who have reviewed operating procedures	1	1	1	11	11	0.55	1.1	$1,465.09
8) Records of persons who have completed operator training	1	1	1	11	11	0.55	1.1	$1,465.09
9) Records of persons who meet operator qualification criteria	1	1	1	11	11	0.55	1.1	$1,465.09
10) Records of monitoring device calibration	See 3B
11) Records of site-specific documentation e	24	1	24	0.33	8	0.4	0.8	$1,065.52
F. Personnel Training	See 3B
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					86			$9,929
Total Labor Burden and Costs (rounded) h					1,700			$197,000
Total Capital and O&M Cost (rounded) h								$769,000
Grand Total (rounded) h								$970,000
Assumptions:
a We assume there are 10 existing sources subject to the rule and 1 additional new source per year (one new respondent) will become subject to the rule during 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 sources will have to familiarize with the regulatory requirements each year.
d These are one-time only costs associated with the startup of a new source. We assume there will be 1 new respondent per year.
e We assume that one-third of the facilities will petition for site-specific parameters.
f We assume that 10 percent of the existing facilities would not have a qualified operator available for more than two weeks at least once a year (Note: each deviation requires 2 notifications, 1 for when the deviation occurs and 1 for when operation resumes). We also assume that each deviation will require only two status reports.
g We assume that 10 percent of all facilities (both new and existing) would have a malfunction or an exceedance during the year.
h 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 – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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
A. Observe initial stack tests (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2) c	48	1	48	0.2	9.6	0.48	0.96	$532		Clerical	$26.75
B. Excess emissions -- Enforcement Activities d	24	1	24	1.1	26.4	1.32	2.64	$1,464
C. Create Information	N/A
D. Gather Information	N/A
E. Report Reviews
1) Review waste management plan and siting analysis e	8	1	8	1	8	0.4	0.8	$444
2) Review report submitted prior to initial startup e	2	1	2	1	2	0.1	0.2	$111
3) Review initial stack test report e	40	1	40	1	40	2	4	$2,218
4) Review annual compliance report	8	1	8	10	80	4	8	$4,436
5) Review semi-annual excess emission and parameter exceedance report d	16	1	16	1.1	17.6	0.88	1.76	$976
6) Review notifications and status reports for qualified operators off-site f	4	4	16	1	16	0.8	1.6	$887
F. Prepare annual summary report g	200	1	200	1	200	10	20	$11,089
TOTAL (rounded) h					460			$22,200
Assumptions:
a We assume there are 10 existing sources subject to the rule and 1 additional new source per year (one new respondent) will become subject to the rule during 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 Assumes EPA personnel attend 20 percent of the stack tests. We estimate initial stack test observations will take 48 hours per plant.
d Assume that 10 percent of all facilities (both existing and new) have an exceedance during the year.
e These are one-time only costs associated with the startup of a new source. We assume there will be 1 new respondent per year.
f We assume that 10 percent of the existing facilities would not have a qualified operator available for more than two weeks at least once a year (Note: each deviation requires 2 notifications, 1 for when the deviation occurs and 1 for when operation resumes). We also assume that each deviation will require only two status reports.
g We assume that each state (i.e., 50 respondents) will take 4 hours to prepare an annual summary of progress for implementing state plans.
h 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
Report prior to construction (includes siting analysis)	1	1	0	1
Report prior to initial start-up	1	1	0	1
Notification of initial performance test	1	1	0	1
Notification of initial CMS Demonstration	1	1	0	1
Report of initial performance test	1	1	0	1
Report established values for site-specific operating parameters	1	1	0	1
Waste management plan	1	1	0	1
Annual Report a	10	1	0	10
Notification for qualified operators that are off-site for more than 2 weeks b	1	2	0	2
Status report for qualified operators that are off-site for more than 2 weeks b	1	2	0	2
Semiannual report of deviations: emissions/parameter exceedances c	1.1	2	0	2.2
			Total	23
a We estimate 10 existing respondents have to submit annual reports.
b We assume that these activities will apply to 10 percent of existing facilities
c We assume that 10 percent of all facilities (both new and existing) would have a malfunction or an exceedance during the year.
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	1	9	0	0	10
2	1	10	0	0	11
3	1	11	0	0	12
Average	1	10	0	0	11
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)
Bag Leak Detectors	$3,500	1	$3,500	$9,700	10	$97,000
CO CEMS	$12,600	1	$12,600	$41,400	10	$414,000
ACI Monitors	$0	1	$0	$4,200	10	$42,000
Stack Tests	$55,000	1	$55,000	$14,533	10	$145,330
Postage for Performance Tests	$7.50	1	$8	$7.50	10	$75
Postage for Semiannual Reports	$0	0	$0	$15	1	$15
		Total	$71,100		Total a	$698,000		$769,000
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Summary of Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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
10	23	1,613	86	1,700	$197,000	$769,000	$970,000	73