Burden Calculation Tables

---

Overview

YR1
YR2
YR3
Summary
EPA_Yr1
EPA_Yr2
EPA_Yr3
EPA_Summary
O&M

---

Sheet 1: YR1

Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) - Year 1 Incremental Burden
							117.92	147.4		57.02	Updated to 2018 labor rates
						Person-hours per year
Burden item	(A) Person hours per occurrence	(B) Non-Labor Costs Per Occurrence	(C) No. of occurrences per respondent per year	(D) Person hours per respondent per year (C=AxB)	(E) Respondents per yeara	(F) Technical person- hours per year (E=CxD)	(G) Management person hours per year (Ex0.05)	(H) Clerical person hours per year (Ex0.1)	(I) Total Hours per Year (F + G + H)	(J) Total Labor Cost per yearb	(K) Total Non-Labor Costs Per Year (B x C x E)	(L) Total Number of Responses per Year (C X E)
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with rule requirementsc	18	$0	1	18	155	2790	139.5	279	3208.5	$365,467.68	$0	155
B. Required activities
1) Initial performance test and reports
a) Initial performance tests (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c	24	$57,333	1	24	63	1512	75.6	151.2	1738.8	$198,059.90	$4,472,000	63
b) Repeat of initial performance tests c,d	24	$11,467	1	24	0	0	0	0	0	$0	$0	0
c) Initial performance tests - Air Curtain Incinerators (opacity) c	3	$3,000	1	3	0	0	0	0	0	$0	$0	0
d) Repeat of initial performance tests - Air Curtain Incinerators c,d	3	$600	1	3	0	0	0	0	0	$0	$0	0
2) CEMS demonstration (CO, O2)											$0	0
a) Initial demonstration e	229	$351,000	1	229	0	0	0	0	0	$0	$0	0
b) Annual Costs	See 3.B.5										$0	0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)f	24	$0	1	24	0	0	0	0	0	$0	$0	0
4) Annual performance tests and test reports - Air Curtain Incinerators (opacity)f	3	$0	1	3	0	0	0	0	0	$0	$0	0
5) Quarterly Appendix F audits of CEMS (CO)
a) RATA audit (one per year) e,f	4	1	4	16	0	0	0	0	0	$0	$0	0
b) RAA audit (three per year) e,f	4	3	12	48	0	0	0	0	0	$0	$0	0
c) Daily calibration and operation e,f	0.25	$64,600	250	62.5	0	0	0	0	0	$0	$0	0
6) Waste management plan c	20	$0	1	20	0	0	0	0	0	$0	$0	0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
1) Preconstruction reportc	8	$0	1	8	0	0	0	0	0	$0	$0	0
2) Startup notificationc	2	$0	1	2	0	0	0	0	0	$0	$0	0
3) Initial test report c
a) Initial test report (non-ACI) c	40	$0	1	40	63	2520	126	252	2898	$330,099.84	$0	63
b) Initial test report (ACI) c	10	$0	1	10	0	0	0	0	0	$0	$0	0
4) Annual compliance reports
a) Annual compliance report (non-ACI) g	28	$0	1	28	0	0	0	0	0	$0	$0	0
b) Annual compliance report (ACI) g	10	$0	1	10	0	0	0	0	0	$0	$0	0
5) Semiannual deviation reports i	24	$0	2	48	0	0	0	0	0	$0	$0	0
6) Notification of final compliance	1	$0	1	1	126	126	6.3	12.6	144.9	$16,504.99	$0	126
Subtotal for Reporting Requirements						6,948	347	695	7,990	$910,132	$4,472,000	407
4. Recordkeeping requirements
A. Familiarize with rule requirementsc	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Record information
1) Records of SSM h	1.5	$0	52	78	0	0	0	0	0	$0	$0	0
2) Records of emission rate computations, all emission exceedances and periods when there is no data i,k	1.5	$0	52	78	0	0	0	0	0	$0	$0	0
3) Records of employee review of operations manual	4	$0	1	4	0	0	0	0	0	$0	$0	0
4) Record of control devices operating parameters k,f	1.5	$25,900	52	78	0	0	0	0	0	$0	$0	0
5) Records of waste characterizationk	0.5	$0	52	26	63	1638	81.9	163.8	1883.7	$214,565	$0	3276
F. Perform Audits	N/A
Subtotal for Recordkeeping Requirements						1,638	82	164	1,884	$214,565	$0	3,276
TOTAL (rounded) j						8,586	429	859	9,874	$1,120,000	$4,470,000	$3,680
Assumptions:
a EPA estimates that there are 155 existing facilities subject to 40 CFR 60, Subpart FFFF: 29 air curtain incinerator (ACI) facilities and 126 other OSWI facilities. EPA estimates that 63 non-ACI facilities are large facilities with units with capacities that are less than 10 TPD that will be able to do initial testing, and the ACI facilities will be able to do initial testing. For the remaining 63 units with a capacity of less than 10 TPD, the proposed rule allows for an alternative compliance option that allows facilities to demonstrate compliance by requesting a substitute means of compliance demonstration test from their delegated authority. Units with a capacity of greater than or equal to 10 TPD and ACI units have no new initial testing requirements under the proposed rule, therefore, there are no incremental costs associated with these requirements.
b This ICR uses the following labor rates: $117.92 (technical), $147.40 (managerial), and $57.02 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD or units less than 10 TPD that do not meet the substitute means of compliance requirements. We assume 63 respondents at large facilities will test 78 units, and 63 remaining facilities will use the substitute means of compliance option in Year 1. Note that the waste management plan is submitted as part of the preconstruction report. There are no new initial testing requirements under the proposed rule for units with capacities greater than 10 TPD or ACI units, therefore, there are no incremental costs associated with these requirements.
d We have assumed that no respondents would be required to repeat a performance test.
e We have assumed that none of the existing units subject to FFFF have CEMS, all units are less than 10 TPD and will use a substitute means of compliance demonstration; therefore no facilities will submit an initial demonstration report.
f We have assumed that each respondent will use a substitute means of compliance demonstration; therefore, no respondents are expected to conduct annual performance tests or record daily calibration and operation or control devices operating parameters.
g We have assumed that non-ACI facilities will submit an initial test report in lieu of an annual compliance report in Year 1. However, the requirement to submit an annual compliance report is not new, therefore there are no incremental costs associated with this requirement.
h The emission limits will apply at all times, including periods of SSM. Therefore, no facilities will have recordkeeping costs associated with SSM.
i We have assumed that 10 percent of the respondents will report exceedances.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
k We have assumed that each respondent will record information 52 times per year. This includes 63 respondents with units with capacities less than 10 TPD that will use the substitute means of compliance option.

---

Sheet 2: YR2

Table 2: Annual Respondent Burden and Cost – Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) - Year 2 Incremental Burden
							117.92	147.4		57.02	Updated to 2018 labor rates
						Person-hours per year
Burden item	(A) Person hours per occurrence	(B) Non-Labor Costs Per Occurrence	(C) No. of occurrences per respondent per year	(D) Person hours per respondent per year (C=AxB)	(E) Respondents per yeara	(F) Technical person- hours per year (E=CxD)	(G) Management person hours per year (Ex0.05)	(H) Clerical person hours per year (Ex0.1)	(I) Total Hours per Year (F + G + H)	(J) Total Labor Cost per yearb	(K) Total Non-Labor Costs Per Year (B x C x E)	(L) Total Number of Responses per Year (C X E)
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with rule requirementsc	18	$0	1	18	0	0	0	0	0	$0	$0	0
B. Required activities
1) Initial performance test and reports
a) Initial performance tests (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c	24	$57,333	1	24	0	0	0	0	0	$0	$0	0
b) Repeat of initial performance tests c,d	24	$11,467	1	24	0	0	0	0	0	$0	$0	0
c) Initial performance tests - Air Curtain Incinerators (opacity) c	3	$3,000	1	3	0	0	0	0	0	$0	$0	0
d) Repeat of initial performance tests - Air Curtain Incinerators c,d	3	$600	1	3	0	0	0	0	0	$0	$0	0
2) CEMS demonstration (CO, O2)											$0	0
a) Initial demonstration e	229	$351,000	1	229	0	0	0	0	0	$0	$0	0
b) Annual Costs	See 3.B.5										$0	0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)f	24	$57,333	1	24	0	0	0	0	0	$0	$0	0
4) Annual performance tests and test reports - Air Curtain Incinerators (opacity)f	3	$3,000	1	3	0	0	0	0	0	$0.00	$0	0
5) Quarterly Appendix F audits of CEMS (CO)
a) RATA audit (one per year) e,f	4	1	4	16	0	0	0	0	0	$0	$0	0
b) RAA audit (three per year) e,f	4	3	12	48	0	0	0	0	0	$0	$0	0
c) Daily calibration and operation e,f	0.25	$64,600	250	62.5	0	0	0	0	0	$0	$0	0
6) Waste management plan c	20	$0	1	20	0	0	0	0	0	$0	$0	0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
1) Preconstruction reportc	8	$0	1	8	0	0	0	0	0	$0	$0	0
2) Startup notificationc	2	$0	1	2	0	0	0	0	0	$0	$0	0
3) Initial test report c
a) Initial test report (non-ACI) c	40	$0	1	40	0	0	0	0	0	$0	$0	0
b) Initial test report (ACI) c	10	$0	1	10	0	0	0	0	0	$0	$0	0
4) Annual compliance reports
a) Annual compliance report (non-ACI) g	28	$0	1	28	0	0	0	0	0	$0.00	$0	0
b) Annual compliance report (ACI) g	10	$0	1	10	0	0	0	0	0	$0.00	$0	0
5) Semiannual deviation reports i	24	$0	2	48	0	0	0	0	0	$0.00	$0	0
6) Notification of final compliance	1	$0	1	1	0	0	0	0	0	$0.00	$0	0
Subtotal for Reporting Requirements						0	0	0	0	$0	$0	0
4. Recordkeeping requirements
A. Familiarize with rule requirementsc	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Record information
1) Records of SSM h	1.5	$0	52	78	0	0	0	0	0	$0	$0	0
2) Records of emission rate computations, all emission exceedances and periods when there is no data i,k	1.5	$0	52	78	0	0	0	0	0	$0.00	$0	0
3) Records of employee review of operations manual	4	$0	1	4	0	0	0	0	0	$0.00	$0	0
4) Record of control devices operating parameters k,f	1.5	$1,800	52	78	0	0	0	0	0	$0	$0	0
5) Records of waste characterizationk	0.5	$0	52	26	126	3276	163.8	327.6	3767.4	$429,130	$0	6552
F. Perform Audits	N/A
Subtotal for Recordkeeping Requirements						3,276	164	328	3,767	$429,130	$0	6,552
TOTAL (rounded)h						3,276	164	328	3,767	$430,000	$0	13,104
Assumptions:
a EPA estimates that there are 155 existing facilities subject to 40 CFR 60, Subpart FFFF: 29 air curtain incinerator (ACI) facilities and 126 other OSWI facilities. EPA estimates that 63 non-ACI facilities are large facilities with units with capacities that are less than 10 TPD that will be able to do initial testing, and the ACI facilities will be able to do initial testing. For the remaining 63 units with a capacity of less than 10 TPD, the proposed rule allows for an alternative compliance option that allows facilities to demonstrate compliance by requesting a substitute means of compliance demonstration test from their delegated authority. Units with a capacity of greater than or equal to 10 TPD and ACI units have no new initial testing requirements under the proposed rule, therefore, there are no incremental costs associated with these requirements.
b This ICR uses the following labor rates: $117.92 (technical), $147.40 (managerial), and $57.02 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD or units less than 10 TPD that do not meet the substitute means of compliance requirements. We assume 63 respondents at large facilities will test, and 63 remaining facilities will use the substitute means of compliance option in Year 1. Note that the waste management plan is submitted as part of the preconstruction report. There are no new testing requirements under the proposed rule for large units or ACI units, therefore, there are no incremental costs associated with these requirements.
d We have assumed that no respondents would be required to repeat a performance test.
e We have assumed that none of the existing units subject to FFFF have CEMS, all units are less than 10 TPD and will use a substitute means of compliance demonstration; therefore no facilities will submit an initial demonstration report.
f We have assumed that each respondent will use a substitute means of compliance demonstration; therefore, no respondents are expected to conduct annual performance tests or record daily calibration and operation or control devices operating parameters.
g The requirement to submit an annual compliance report is not new, therefore there are no incremental costs associated with this requirement.
h The emission limits will apply at all times, including periods of SSM. Therefore, no facilities will have recordkeeping costs associated with SSM.
i We have assumed that 10 percent of the respondents will report exceedances.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
k We have assumed that each respondent will record information 52 times per year. This includes 63 respondents with units with capacities less than 10 TPD that will use the substitute means of compliance option.

---

Sheet 3: YR3

Table 3: Annual Respondent Burden and Cost – Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) - Year 3 Incremental Burden
							117.92	147.4		57.02	Updated to 2018 labor rates
						Person-hours per year
Burden item	(A) Person hours per occurrence	(B) Non-Labor Costs Per Occurrence	(C) No. of occurrences per respondent per year	(D) Person hours per respondent per year (C=AxB)	(E) Respondents per yeara	(F) Technical person- hours per year (E=CxD)	(G) Management person hours per year (Ex0.05)	(H) Clerical person hours per year (Ex0.1)	(I) Total Hours per Year (F + G + H)	(J) Total Labor Cost per yearb	(K) Total Non-Labor Costs Per Year (B x C x E)	(L) Total Number of Responses per Year (C X E)
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with rule requirementsc	18	$0	1	18	0	0	0	0	0	$0	$0	0
B. Required activities
1) Initial performance test and reports
a) Initial performance tests (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c	24	$57,333	1	24	0	0	0	0	0	$0	$0	0
b) Repeat of initial performance tests c,d	24	$11,467	1	24	0	0	0	0	0	$0	$0	0
c) Initial performance tests - Air Curtain Incinerators (opacity) c	3	$3,000	1	3	0	0	0	0	0	$0	$0	0
d) Repeat of initial performance tests - Air Curtain Incinerators c,d	3	$600	1	3	0	0	0	0	0	$0	$0	0
2) CEMS demonstration (CO, O2)											$0	0
a) Initial demonstration e	229	$351,000	1	229	0	0	0	0	0	$0	$0	0
b) Annual Costs	See 3.B.5										$0	0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)f	24	$57,333	1	24	0	0	0	0	0	$0	$0	0
4) Annual performance tests and test reports - Air Curtain Incinerators (opacity)f	3	$3,000	1	3	0	0	0	0	0	$0.00	$0	0
5) Quarterly Appendix F audits of CEMS (CO)
a) RATA audit (one per year) e,f	4	1	4	16	0	0	0	0	0	$0	$0	0
b) RAA audit (three per year) e,f	4	3	12	48	0	0	0	0	0	$0	$0	0
c) Daily calibration and operation e,f	0.25	$64,600	250	62.5	0	0	0	0	0	$0	$0	0
6) Waste management plan c	20	$0	1	20	0	0	0	0	0	$0	$0	0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
1) Preconstruction reportc	8	$0	1	8	0	0	0	0	0	$0	$0	0
2) Startup notificationc	2	$0	1	2	0	0	0	0	0	$0	$0	0
3) Initial test report c
a) Initial test report (non-ACI) c	40	$0	1	40	0	0	0	0	0	$0	$0	0
b) Initial test report (ACI) c	10	$0	1	10	0	0	0	0	0	$0	$0	0
4) Annual compliance reports
a) Annual compliance report (non-ACI) g	28	$0	1	28	0	0	0	0	0	$0.00	$0	0
b) Annual compliance report (ACI) g	10	$0	1	10	0	0	0	0	0	$0.00	$0	0
5) Semiannual deviation reports i	24	$0	2	48	0	0	0	0	0	$0.00	$0	0
6) Notification of final compliance	1	$0	1	1	0	0	0	0	0	$0.00	$0	0
Subtotal for Reporting Requirements						0	0	0	0	$0	$0	0
4. Recordkeeping requirements
A. Familiarize with rule requirementsc	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Record information
1) Records of SSM h	1.5	$0	52	78	0	0	0	0	0	$0	$0	0
2) Records of emission rate computations, all emission exceedances and periods when there is no data i,k	1.5	$0	52	78	0	0	0	0	0	$0.00	$0	0
3) Records of employee review of operations manual	4	$0	1	4	0	0	0	0	0	$0.00	$0	0
4) Record of control devices operating parameters k,f	1.5	$1,800	52	78	0	0	0	0	0	$0	$0	0
5) Records of waste characterizationk	0.5	$0	52	26	126	3276	163.8	327.6	3767.4	$429,130	$0	6552
F. Perform Audits	N/A
Subtotal for Recordkeeping Requirements						3,276	164	328	3,767	$429,130	$0	6,552
TOTAL (rounded)h						3,276	164	328	3,767	$430,000	$0	13,104
Assumptions:
a EPA estimates that there are 155 existing facilities subject to 40 CFR 60, Subpart FFFF: 29 air curtain incinerator (ACI) facilities and 126 other OSWI facilities. EPA estimates that 63 non-ACI facilities are large facilities with units with capacities that are less than 10 TPD that will be able to do initial testing, and the ACI facilities will be able to do initial testing. For the remaining 63 units with a capacity of less than 10 TPD, the proposed rule allows for an alternative compliance option that allows facilities to demonstrate compliance by requesting a substitute means of compliance demonstration test from their delegated authority. Units with a capacity of greater than or equal to 10 TPD and ACI units have no new initial testing requirements under the proposed rule, therefore, there are no incremental costs associated with these requirements.
b This ICR uses the following labor rates: $117.92 (technical), $147.40 (managerial), and $57.02 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD or units less than 10 TPD that do not meet the substitute means of compliance requirements. We assume 63 respondents at large facilities will test, and 63 remaining facilities will use the substitute means of compliance option in Year 1. Note that the waste management plan is submitted as part of the preconstruction report. There are no new testing requirements under the proposed rule for large units or ACI units, therefore, there are no incremental costs associated with these requirements.
d We have assumed that no respondents would be required to repeat a performance test.
e We have assumed that none of the existing units subject to FFFF have CEMS, all units are less than 10 TPD and will use a substitute means of compliance demonstration; therefore no facilities will submit an initial demonstration report.
f We have assumed that each respondent will use a substitute means of compliance demonstration; therefore, no respondents are expected to conduct annual performance tests or record daily calibration and operation or control devices operating parameters.
g The requirement to submit an annual compliance report is not new, therefore there are no incremental costs associated with this requirement.
h The emission limits will apply at all times, including periods of SSM. Therefore, no facilities will have recordkeeping costs associated with SSM.
i We have assumed that 10 percent of the respondents will report exceedances.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
k We have assumed that each respondent will record information 52 times per year. This includes 63 respondents with units with capacities less than 10 TPD that will use the substitute means of compliance option.

---

Sheet 4: Summary

Table 4 - Summary of Incremental Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements - Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF)
	Year	Technical Hours	Clerical Hours	Management Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
	1	8,586	859	429	9,874	$1,120,000	$4,470,000	$5,590,000
	2	3,276	328	164	3,767	$430,000	$0	$430,000
	3	3,276	328	164	3,767	$430,000	$0	$430,000
	Total	15,138	1,514	757	17,409	$1,980,000	$4,470,000	$6,450,000
	Average	5,046	505	252	5,803	$660,000	$1,490,000	$2,150,000
	Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
	1	126	189	7,990	1,884	9,874	52	78
	2	126	0	0	3,767	3,767	0	30
	3	126	0	0	3,767	3,767	0	30
	Total	126	189	7,990	9,419	17,409	92	138
	Average	126	63	2,663	3,140	5,803	92	46

---

Sheet 5: EPA_Yr1

Table 5: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) - Year 1 Incremental Burden
					48.08	64.8	26.02
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Applications	N/A
2. Familiarization with rule requirements	N/A
3. Required activities
A. Create information	N/A
B. Gather information	See 3A
C. Report reviews
1) Notification of final compliance c	1.5	1	1.5	126	189	9.45	18.9	$10,191
2) Review initial compliance test report
a) Initial test report (non-ACI) c	40	1	40	63	2520	126	252	$135,883
b) Initial test report (ACI) c	10	1	10	0	0	0	0	$0
3) Review annual compliance report
a) Annual compliance report (non-ACI)	40	1	40	0	0	0	0	$0
b) Annual compliance report (ACI)	10	1	10	0	0	0	0	$0
4) Review semiannual deviation reports	16	2	32	0	0	0	0	$0
5) Review waste management plan c	16	1	16	0	0	0	0	$0
6) Review grant applications for initial testingf	20	1	20	10	200	10	20	$10,784.40
D. Annual summary report d	4	1	4	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)e					2,909	145	291	$157,000
Assumptions:
a EPA estimates that there are 155 existing facilities subject to 40 CFR 60, Subpart FFFF: 29 air curtain incinerator (ACI) facilities and 126 other OSWI facilities. EPA estimates that 63 non-ACI facilities are large facilities with units with capacities that are less than 10 TPD that will be able to do initial testing, and the ACI facilities will be able to do initial testing. For the remaining 63 units with a capacity of less than 10 TPD, the proposed rule allows for an alternative compliance option that allows facilities to demonstrate compliance by requesting a substitute means of compliance demonstration test from their delegated authority. Units with a capacity of greater than or equal to 10 TPD and ACI units have no new initial testing requirements under the proposed rule, therefore, there are no incremental costs associated with these requirements.
b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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 have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD or units less than 10 TPD that do not meet the substitute means of compliance requirements. We assume 63 non-ACI respondents will test in Year 1.
d We have assumed that all affected facilities in the states will be required to prepare an annual summary plan.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
fWe have assumed that EPA will review one grant application per EPA Region.

---

Sheet 6: EPA_Yr2

Table 6: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) - Year 2 Incremental Burden
					48.08	64.8	26.02
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Applications	N/A
2. Familiarization with rule requirements	N/A
3. Required activities
A. Create information	N/A
B. Gather information	See 3A
C. Report reviews
1) Notification of final compliance c	1.5	1	1.5	0	0	0	0	$0
2) Review initial compliance test report
a) Initial test report (non-ACI) c	40	1	40	0	0	0	0	$0
b) Initial test report (ACI) c	10	1	10	0	0	0	0	$0
3) Review annual compliance report
a) Annual compliance report (non-ACI)	40	1	40	0	0	0	0	$0
b) Annual compliance report (ACI)	10	1	10	0	0	0	0	$0
4) Review semiannual deviation reports	16	2	32	0	0	0	0	$0
5) Review waste management plan c	16	1	16	0	0	0	0	$0
6) Review grant applications for initial testingf	20	1	20	0	0	0	0	$0
D. Annual summary report d	4	1	4	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)e					0	0	0	$0
Assumptions:
a EPA estimates that there are 155 existing facilities subject to 40 CFR 60, Subpart FFFF: 29 air curtain incinerator (ACI) facilities and 126 other OSWI facilities. EPA estimates that 63 non-ACI facilities are large facilities with units with capacities that are less than 10 TPD that will be able to do initial testing, and the ACI facilities will be able to do initial testing. For the remaining 63 units with a capacity of less than 10 TPD, the proposed rule allows for an alternative compliance option that allows facilities to demonstrate compliance by requesting a substitute means of compliance demonstration test from their delegated authority. Units with a capacity of greater than or equal to 10 TPD and ACI units have no new initial testing requirements under the proposed rule, therefore, there are no incremental costs associated with these requirements.
b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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 have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD or units less than 10 TPD that do not meet the substitute means of compliance requirements. We assume 63 non-ACI respondents will test in Year 1.
d We have assumed that all affected facilities in the states will be required to prepare an annual summary plan.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
fWe have assumed that EPA will review one grant application per EPA Region.

---

Sheet 7: EPA_Yr3

Table 7: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) - Year 3 Incremental Burden
					48.08	64.8	26.02
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Applications	N/A
2. Familiarization with rule requirements	N/A
3. Required activities
A. Create information	N/A
B. Gather information	See 3A
C. Report reviews
1) Notification of final compliance c	1.5	1	1.5	0	0	0	0	$0
2) Review initial compliance test report
a) Initial test report (non-ACI) c	40	1	40	0	0	0	0	$0
b) Initial test report (ACI) c	10	1	10	0	0	0	0	$0
3) Review annual compliance report
a) Annual compliance report (non-ACI)	40	1	40	0	0	0	0	$0
b) Annual compliance report (ACI)	10	1	10	0	0	0	0	$0
4) Review semiannual deviation reports	16	2	32	0	0	0	0	$0
5) Review waste management plan c	16	1	16	0	0	0	0	$0
6) Review grant applications for initial testingf	20	1	20	0	0	0	0	$0
D. Annual summary report d	4	1	4	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)e					0	0	0	$0
Assumptions:
a EPA estimates that there are 155 existing facilities subject to 40 CFR 60, Subpart FFFF: 29 air curtain incinerator (ACI) facilities and 126 other OSWI facilities. EPA estimates that 63 non-ACI facilities are large facilities with units with capacities that are less than 10 TPD that will be able to do initial testing, and the ACI facilities will be able to do initial testing. For the remaining 63 units with a capacity of less than 10 TPD, the proposed rule allows for an alternative compliance option that allows facilities to demonstrate compliance by requesting a substitute means of compliance demonstration test from their delegated authority. Units with a capacity of greater than or equal to 10 TPD and ACI units have no new initial testing requirements under the proposed rule, therefore, there are no incremental costs associated with these requirements.
b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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 have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD or units less than 10 TPD that do not meet the substitute means of compliance requirements. We assume 63 non-ACI respondents will test in Year 1.
d We have assumed that all affected facilities in the states will be required to prepare an annual summary plan.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
fWe have assumed that EPA will review one grant application per EPA Region.

---

Sheet 8: EPA_Summary

Table 8 - Summary of Incremental Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF)
	Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
	1	2,909	145	291	3,345	$157,000	$0	$157,000
	2	0	0	0	0	$0	$0	$0
	3	0	0	0	0	$0	$0	$0
	Total	2,909	145	291	3,345	$157,000	$0	$157,000
	Average	970	48	97	1,115	$52,333	$0	$52,333

---

Sheet 9: O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Initial Stack Test	Capital/Startup Cost for One Respondent	Number of New Respondents a	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)
Initial Stack Test (non-ACI Facility)	$57,333	63	$4,472,000	$0	0	$0
Initial Stack Test (ACI Facility)	$3,000	0	$0	$0	0	$0
Total			$4,470,000			$0
a It is assumed that 63 facilities will test 78 units. Annual operation and maintenance costs are not included, because it is assumed that all units will use a substitute means of compliance demonstration.