Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Responses
Capital O&M
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	1,870
Number of Respondents	6
Total Estimated Burden Hours	18,700
Total Estimated Costs	$2,180,000
Annualized Capital O&M	$154,000
Total Annual Responses	10

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Small Municipal Waste Combustors (40 CFR Part 60, Subpart AAAA) (Renewal)										Category	# Respondents per year
					123.94	157.61	62.52	Private		Private (New)	0
					52.37	70.56	28.34	Public		Private (Existing)	5
										Private (Total)	5
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)		Public (Existing)	1
	Respondent Hours Per Occurrence	Number of Occurrences Per Respondent Per Year	Person Hours Per Respondent Per Year (AxB)	Number of Respondents Per Year a	Technical Hours Per Year (CxD)	Management Hours Per Year (Ex0.05)	Clerical Hours Per Year (Ex0.1)	Total Cost Per Year, $		Total	6
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements for Private Sources b
A. Familiarization with rule requirements
1) New Sources	40	1	40	0	0	0	0	$0
2) Existing Sources	1	1	1	5	5	0.25	0.5	$690.36
B. Required Activities
1) Initial performance tests and reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	0	0	0	0	$0
2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)
a) Installation of CEM units	225	1	225	0	0	0	0	$0
b) Initial demonstration	450	1	450	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	5	3875	193.75	387.50	$535,030.94
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a) RATA audit (one per year) d, e, h	350	1.33	466	5	2327.5	116.38	232.75	$321,363.74
b) RAA audit (three per year) f, h	130	4.00	520.0	5	2600.00	130.00	260.00	$358,988.50
c) Daily calibration and operation g	1	485.5	485.5	5	2427.50	121.38	242.75	$335,170.99
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Plant startup
a) Preliminary and final material separation plans and siting analysis	270	1	270	0	0	0	0	$0
b) Public meeting and comment response	140	1	140	0	0	0	0	$0
c) Notification of construction	2	1	2	0	0	0	0	$0
d) Notification of startup	2	1	2	0	0	0	0	$0
2) Notification of initial performance tests	4	1	4	0	0	0	0	$0
3) Initial compliance reports	40	1	40	0	0	0	0	$0
4) Notification of CEMS demonstration	4	1	4	0	0	0	0	$0
5) Initial CEMS demonstration report	40	1	40	0	0	0	0	$0
6) Annual compliance reports d	40	1.33	53.20	5	266.00	13.30	26.60	$36,727.29
7) Semi-annual excess emission reports i	40	2	80	0.5	40	2	4	$5,522.90
Subtotal Reporting Requirements (Private Sources)					13,272			$1,593,495
3. Reporting Requirements for State/Local Government Sources c
A. Familiarization with rule requirements
1) New Sources	40	1	40	0	0	0	0	$0.00
2) Existing Sources	1	1	1	1	1	0.05	0.1	$58.73
B. Required Activities
1) Initial performance tests and reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	0	0	0	0	$0
2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)
a) Installation of CEM units	225	1	225	0	0	0	0	$0
b) Initial demonstration	450	1	450	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	1	775	38.75	77.5	$45,517.30
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a) RATA audit (one per year) d, e, h	350	1.33	465.5	1	466	23.275	46.6	$27,339.75
b) RAA audit (three per year) f, h	130	4	520	1	520.0	26	52	$30,540.64
c) Daily calibration and operation g	1	485.5	485.5	1	485.5	24.28	48.55	$28,514.39
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Plant startup
a) Preliminary and final material separation plans and siting analysis	270	1	270	0	0	0	0	$0
b) Public meeting and comment response	140	1	140	0	0	0	0	$0
c) Notification of construction	2	1	2	0	0	0	0	$0
d) Notification of startup	2	1	2	0	0	0	0	$0
2) Notification of initial performance tests	4	1	4	0	0	0	0	$0
3) Initial compliance reports	40	1	40	0	0	0	0	$0
4) Notification of CEMS demonstration	4	1	4	0	0	0	0	$0
5) Initial CEMS demonstration report	40	1	40	0	0	0	0	$0
6) Annual compliance reports d	40	1.33	53.2	1	53.2	2.66	5.32	$3,124.54
7) Semi-annual excess emission reports i	40	2	80	0.5	40	2	4	$2,349.28
Subtotal Reporting Requirements (State/Local Government Sources)					2,691			$137,445
Total Reporting Requirements for Private and State/Local Government Sources					15,963			$1,730,939
4. Recordkeeping Requirements for Private Sources b
A. Familiarization with rule requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record information
1) Record startups, shutdowns, and malfunctions j	4	47	188	5	940	47.00	94.00	$129,788.15
2) Records of all emission rates, computations, tests j	4	47	188	5	940	47.00	94.00	$129,788.15
3) Records of employee review of operations manual	4	1	4	5	20	1.00	2.00	$2,761.45
4) Record amount of sorbent used for Hg and dioxin/furan control	4	4	16	5	80	4.00	8.00	$11,045.80
F. Personnel Training	N/A
G. Time for audits	N/A
Subtotal Recordkeeping Requirements (Private Sources)					2,277			$273,384
4. Recordkeeping Requirements for State/Local Government Sources c
A. Familiarization with rule requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record information
1) Record startups, shutdowns, and malfunctions j	4	47	188	1	188	9.4	18.8	$11,041.62
2) Records of all emission rates, computations, tests j	4	47	188	1	188	9.4	18.8	$11,041.62
3) Records of employee review of operations manual	4	1	4	1	4	0.2	0.4	$234.93
4) Record amount of sorbent used for Hg and dioxin/furan control	4	4	16	1	16	0.8	1.6	$939.71
F. Personnel Training	N/A
G. Time for audits	N/A
Subtotal Recordkeeping Requirements (State/Local Government Sources)					455			$23,258
Total Recordkeeping Requirements for Private and State/Local Government Sources					2732			$296,641
TOTAL LABOR BURDEN AND COST (rounded): k					18,700			$2,030,000			1870	hr/response
TOTAL CAPITAL AND O&M COST (rounded):k								$154,000
GRAND TOTAL (rounded):k								$2,180,000
ASSUMPTIONS
a We have assumed that the average number of existing respondents that will be subject to the rule will be 6. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates for private sources: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021 “Table 2. Civilian Workers, by Occupational and Industry Group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110% to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c This ICR uses the following labor rates for public sources: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.17 + 60%). These rates are from the Office of Personnel Management (OPM), “2022 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.
d There are an average of 1.33 affected facilities (i.e., sources or units) per respondent [8 facilities at 6 plants = 1.33 (Rounded)].
e Relative accuracy test audits (RATA) occur once per year for each affected facility (1 x 1.33 = 1.33).
f Relative accuracy audits (RAA) occur three times per year for each affected facility (3 x 1.33 = 4).
g Daily calibration and operation data occurs daily (365 x 1.33 = 485.5).
h RATA audits are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
i Assumes a total of 2 semiannual excess emission reports (1 report for a privately-owned source and 1 report for a state/local government-owned source).
j Assumes 47 weeks of operation (90 percent availability) per year per facility.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Small Municipal Waste Combustors (40 CFR Part 60, Subpart AAAA) (Renewal)
					52.37	70.56	28.34
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours Per Occurrence	Number of Occurrences Per Year	EPA Person Hours Per Year (AxB)	Respondents Per Year a	Tech Hours Per Year (CxD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	EPA Cost Per Year,$ b
1. Applications	N/A
2. Read and Understand Rule Requirements	40	0	0	0	0	0	0	$0
A. Create Information	0	0	0	0	0	0	0	$0
B. Gather Information	0	0	0	0	0	0	0	$0
C. Report Reviews
1) Review preliminary and final material separation plans and siting analysis	8	1	8	0	0	0	0	$0
2) Review notification of construction	2	1	2	0	0	0	0	$0
3) Review notification of startup	2	1	2	0	0	0	0	$0
4) Review notification of initial performance test	8	1	8	0	0	0	0	$0
5) Review notification of initial CEMS demonstration	4	1	4	0	0	0	0	$0
6) Review initial performance test report	40	1	40	0	0	0	0	$0
7) Review initial CEMS demonstration report	40	1	40	0	0	0	0	$0
8) Review annual compliance report	70	1	70	6	420	21.00	42	$24,667.44
9) Review semi-annual excess emission report c	16	2	32	2	64	3.2	6.4	$3,758.85
D. Prepare annual summary report	200	1	200	1	200	10	20	$11,746.40
TOTAL ANNUAL BURDEN AND COST (rounded) d					787			$40,200
ASSUMPTIONS
a We have assumed that the average number of respondents that will be subject to the rule will be 6. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
b This cost is based on the following labor rates: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.17 + 60%). These rates are from the Office of Personnel Management (OPM), “2022 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 a total of 2 excess emissions reports from all affected facilities.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Responses

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
Plant Startup (Waste Separation Plan, Notifications, etc.)a	0	4	0	0
Notifications (Performance Test, CEMS Demonstration, etc.)a	0	4	0	0
Annual Reportsb	6	1.33	0	8
Semiannual Excess Emission Reportsc	2	1	0	2
			Total	10
a New respondents include sources with constructed, reconstructed and modified affected facilities. We assume no new respondents will be subject to the rule in the next three years.
b There is an average of 1.33 affected facility (i.e. sources or units) per respondent (i.e. plant). 8 facilities / 6 plants = 1.33 facilities/plant (rounded).
c Assumes a total of 2 semiannual excess emission reports (1 report for a privately-owned source and 1 report for a state/local government-owned source).

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Sheet 5: Capital 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 a	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M b	Total O&M, (E X F)
Load monitors, temperature monitors, and carbon federate monitors (Sections 60.1315 thru 60.1335)	$200,000	0	$0	$19,200	8	$153,600
Totals (rounded) c			$0			$154,000		$154,000
a We estimate that no additional facilities will become subject to this subpart over the next three years.
b The estimated number of facilities with O&M costs includes the 8 existing small MWC units (at 6 plants).
c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	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	6	0	0	6
2	0	6	0	0	6
3	0	6	0	0	6
Average	0	6	0	0	6
a New respondents include sources with constructed and reconstructed affected facilities.