Burden Calculation Table

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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 Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)
					122.66	149.84	60.88
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost Per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarization with the regulatory requirements c
New sources	40	1	40	0	0	0	0	$0
Existing sources	1	1	1	155	155	7.75	15.5	$21,117.20
B. Required activities
1) Initial performance test and reports
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) d	24	1	24	0	0	0	0	$0
b) Repeat of initial performance tests d, e	24	1	24	0	0	0	0	$0
2) CEMS demonstration (CO, 02)
a) Repeat of initial demonstration e	229	1	229	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)	24	1	24	155	3720	186	372	$506,812.80
4) Quarterly Appendix F audits of CEMS (CO)
a) RATA audit (one per year) f, k	4	1	4	126	504	25.2	50.4	$68,664.96
b) RAA audit (three per year) f, k	4	3	12	126	1512	75.6	151.2	$205,994.88
c) Daily calibration and operation f, g, k	1	250	250	126	31500	1575	3150	$4,291,560.00
C. Create information	See 3B
D. Gather information	See 3E
E. Report preparation
1) Contract or secure alternative means of disposal d	40	1	40	0	0	0	0	$0
2) Notification of final compliance d	1.5	1	1.5	0	0	0	0	$0
3) Initial compliance report d	40	1	40	0	0	0	0	$0
4) Waste management plan d	40	1	40	0	0	0	0	$0
5) Annual compliance reports	40	1	40	155	6200	310	620	$844,688.00
6) Semiannual deviation reports k	24	2	48	126	6048	302.4	604.8	$823,979.52
Subtotal for Reporting Requirements					57,085			$6,762,817
4. Recordkeeping requirements
A. Read and understand rule requirement	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, k	1.5	52	78	126	9828	491.4	982.8	$1,338,966.72
2) Records of emission rate computations, all emission exceedances and periods when there is no data h, k	1.5	52	78	126	9828	491.4	982.8	$1,338,966.72
3) Records of employee review of operations manual k	4	1	4	126	504	25.2	50.4	$68,664.96
4) Record of control device operating parameters h, k	1.5	52	78	126	9828	491.4	982.8	$1,338,966.72
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					34,486			$4,085,565
TOTAL LABOR BURDEN AND COST (roundedi)					91,600			$10,800,000
Total Capital/O&M Costs (roundedi)j								$630,000
Grand Total (Labor and Capital/O&M Costs) (roundedi)								$11,400,000
Assumptions:										225	hr/resp
a We have assumed that there are 155 existing facilities subject to 40 CFR 60, Subpart FFFF: 29 air curtain incinerator (ACI) facilities burning only wood waste, clean lumber, and yard waste and 126 other OSWI facilities. We have assumed there are no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 existing sources will take one hour to re-familiarize with rule requirements.
d We have assumed that all respondents have achieved final compliance for the emission guidelines.
e We have assumed that 20 percent of respondents will repeat initial tests due to failure.
f We have assumed that, for non-ACI units, RATA audits are performed for one of the four quarterly audits, and RAA tests are performed for three of the four quarterly audits.
g We have assumed that each operation day requires a CEMS calibration; Combustor models 2, 3, and 4 assume 250 days of operation per year, Model 1 = 121 days/yr. For consistency, 250 operating days are assumed for all models. Emission testing hours (0.25 hr/occurrence) accounts for periodic contractor operation and maintenance support. Annual hours averaged to a daily basis.
h We have assumed that each respondent will record information 52 times per year.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
j Capital and O&M costs represent costs for CEMS.
k This requirement does not apply to (ACI) facilities burning only wood waste, clean lumber, and yard waste.

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Sheet 2: Table 2

Table 2: Average Annual Designated Administrator Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)
					51.23	69.04	27.73
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Designated Administrator person- hours per occurrence	No. of occurrences per plant per year	Designated Administrator 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 c	40	1	40	0	0	0	0	$0
3) Review annual compliance report	40	1	40	155	6200	310	620	$356,221.00
4) Review semiannual deviation reports	16	2	32	126	4032	201.6	403.2	$231,658.56
5) Review waste management plan c	16	1	16	0	0	0	0	$0
D. Annual summary report d	4	1	4	55	220	11	22	$12,640.10
TOTAL ANNUAL BURDEN AND COST (rounded)e					12,000			$601,000
Assumptions:
a We have assumed that there are 155 existing facilities subject to 40 CFR 60, Subpart FFFF: 29 air curtain incinerator (ACI) facilities burning only wood waste, clean lumber, and yard waste and 126 other OSWI facilities. We have assumed there are no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $51.23 (technical), $69.04 (managerial), and $27.73 (clerical). These rates are from the Office of Personnel Management (OPM), 2021 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.
d We have assumed that the designated administrators of the 50 states, one federal district (Washington D.C.), and four territories (American Samoa, Puerto Rico, American Virgin Islands, and Northern Mariana Islands) listed in 40 CFR Part 62 will prepare an annual summary plan.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

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 a	Number of Respondents with O&M	Total O&M,
						(E X F)
Continuous emission monitoring system b	$44,445	0	$0	$5,000	126	$630,000
Total			$0			$630,000
a Annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.
b This requirement does not apply to (ACI) facilities burning only wood waste, clean lumber, and yard waste