Burden Calculation Tables

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Overview

industry
agency
O&M
Total Annual Responses

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Sheet 1: industry

Table 1: Annual Respondent Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE) (Renewal).
					122.66	149.84	60.88
					Person-hours per year
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per yeara	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per yearb
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with rule requirementsc	40	1	40	2	80	4	8	$10,899.20
B. Required activities
1) Initial performance test and reports
a) Initial performance tests (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c	24	1	24	0	0	0	0	$0
b) Repeat of initial performance tests c,d	24	1	24	0	0	0	0	$0
2) CEMS demonstration (CO, O2)
a) Initial demonstration	229	1	229	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)f	24	1	24	2	48	2.4	4.8	$6,539.52
4) Daily calibration and operation e	1	250	250	2	500	25	50	$68,120.00
5) Waste management plan c	20	1	20	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
1) Preconstruction reportc	8	1	8	0	0	0	0	$0
2) Startup notificationc	2	1	2	0	0	0	0	$0
3) Initial test report c	40	1	40	0	0	0	0	$0
4) Annual compliance reports	40	1	40	2	80	4	8	$10,899.20
5) Semiannual deviation reportsf	24	2	48	0.2	9.6	0.48	0.96	$1,307.90
Subtotal for Reporting Requirements					825			$97,766
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 g	1.5	52	78	2	156	7.8	15.6	$21,253.44
2) Records of emission rate computations, all emission exceedances and periods when there is no data f, g	1.5	52	78	0.2	15.6	0.78	1.56	$2,125.34
3) Records of employee review of operations manual	4	1	4	2	8	0.4	0.8	$1,089.92
4) Record of control devices operating parameters g	1.5	52	78	2	156	7.8	15.6	$21,253.44
F. Perform Audits	N/A
Subtotal for Recordkeeping Requirements					386			$45,722		2	responses
TOTAL LABOR BURDEN AND COST (rounded)h					1,210			$143,000		605	hrs/response
TOTAL Capital and O&M Cost (rounded)h								$10,000
GRAND TOTAL (Labor Cost + Capital/O&M)h								$153,000
Assumptions:
a EPA estimates that there are 2 existing facilities subject to 40 CFR 60, Subpart EEEE with capacities greater than or equal to 10 tons per day with no new units expected to be constructed in the next 3 years. The 2 existing facilities have already conducted initial testing.
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 have assumed that this is a one-time only cost for new respondents. Note that the waste management plan is submitted as part of the preconstruction report.
d We have assumed that only 20% of respondents would be required to repeat a performance test.
e We have assumed that each respondent will take 1 hour 250 times per year to record daily calibration and operation.
f We have assumed that 10 percent of the average number of respondents (2 x 0.10) will report exceedances.
g We have assumed that each respondent will record information 52 times per year.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: agency

Table 2: Average Annual EPA Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE) (Renewal).
					51.23	69.04	27.73
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants per yeara	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $b
1. Applications	N/A
2. Familiarization with the regulatory requirements	16	1	16	2	32	1.6	3.2	$1,838.56
3. Required activities
A. Create information	N/A
B. Gather information	See 3A & 3F
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	2	80	4	8	$4,596.40
4) Review semiannual deviation reports d	16	2	32	0.2	6.4	0.32	0.64	$367.71
5) Review waste management plan c	16	1	16	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)e					136			$6,800
Assumptions:
a EPA estimates that there are 2 existing facilities subject to 40 CFR 60, Subpart EEEE with capacities greater than or equal to 10 tons per day with no new units expected to be constructed in the next 3 years. The 2 existing facilities have already conducted initial testing.
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 10 percent of the average number of respondents (2 x 0.10) will report exceedances.
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	Number of Respondents with O&M	Total O&M,
						(E X F)
Continuous emission monitoring system	$44,445	0	$0	$5,000	2	$10,000

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Sheet 4: Total Annual Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
			Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
Notification to commence construction	0	1	0	0
Notification of initial startup	0	1	0	0
Initial test report	0	1	0	0
Annual compliance reports	2	1	0	2
Semiannual deviation reports a	0.2	2	0	0.4
			Total	2