Burden Calculation Tables

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Overview

Summary
Table 1a
Table 1b
Table 1c
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	1,720
Number of Respondents	72
Total Estimated Burden Hours	353,000
Total Estimated Costs	$60,700,000
Annualized Capital O&M	$1,400,000
Total Annual Responses	206

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Sheet 2: Table 1a

Table 1a: Annual Privately-Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
						123.94	157.61	62.52	201.86
Burden Item	(A) Respondent Person Hours Per Occurrence	(B) Contractor Person Hours Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Hours Per Respondent Per Year (D=AxC)	(E) Number of Respondents Per Year a	(F) Technical Hours Per Year (F=DxE)	(G) Management Hours Per Year (G=Fx0.05)	(H) Clerical Hours Per Year (H=Fx0.1)	(I) Contractor Hours Per Year (I=BxCxE)	(J) Total Costs Per Year b
1.) Applications	N/A
2.) Surveys and Studies	N/A
3.) Reporting Requirements
A. Familiarize with Regulatory Requirements c
1) New Sources	40	0	1	40	0	0	0	0	0	$0
2) Existing Sources	4	0	1	4	38	152	8	15.2	0	$20,987
B. Required Activities
1) Initial performance tests and reports
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)	24	750	1	24	0	0	0	0	0	$0
b) Repeat of Initial performance tests d	24	750	1	24	0	0	0	0	0	$0
2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)
a) Installation of CEM units	24	200	1	24	0	0	0	0	0	$0
b) Initial demonstration	24	430	1	24	0	0	0	0	0	$0
c) Repeat of initial demonstration d	24	430	1	24	0	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) e
a) Plants that do not qualify for reduced D/F testing with 2 units	24	1,500	1	24	1	24	1.2	2.4	1,500	$306,103.74
b) Plants that do not qualify for reduced D/F testing with 3 units	24	2,250	1	24	3	72	3.6	7.2	6,750	$1,372,496.22
c) Plants that qualify for reduced D/F testing with 2 units	24	1,428	1	24	16	384	19.2	38.4	22,848	$4,665,117.12
d) Plants that qualify for reduced D/F testing with 3 units	24	2,106	1	24	18	432	21.6	43.2	37,908	$7,711,756.20
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a) RATA audit (one per year)f	8	350	1	8	102	816	40.8	81.6	35,700	$7,319,069.16
b) RAA audit (three per year)f	8	130	3	24	102	2,448	122.4	244.8	39,780	$8,367,992.28
c) Daily calibration and operation	1	0	365	365	102	37,230	1,862	3,723	0	$5,140,439.18
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Plant startup
a) Control plan	40	0	1	40	0	0	0	0	0	$0
b) Notification of contract awards	4	0	1	4	0	0	0	0	0	$0
c) Notification of on-site construction start	4	0	1	4	0	0	0	0	0	$0
d) Notification of construction completion	4	0	1	4	0	0	0	0	0	$0
e) Notification of final compliance	4	0	1	4	0	0	0	0	0	$0
2) Notification of initial performance tests	4	0	1	4	0	0	0	0	0	$0
3) Initial performance tests reports	40	0	1	40	0	0	0	0	0	$0
4) Notification of CEMS demonstration	4	0	1	4	0	0	0	0	0	$0
5) Initial CEMS demonstration report	90	0	1	90	0	0	0	0	0	$0
6) Notification of starting or stopping use of the CEMS	4	0	1	4	0	0	0	0	0	$0
7) Air Curtain incinerator initial performance tests	4	0	1	4	0	0	0	0	0	$0
8) Annual compliance reports	40	0	1	40	38	1,520	76	152	0	$209,870.20
9) Semi-annual excess emission reports g	40	0	2	80	8	608	30.4	60.8	0	$83,948.08
10) Notification of exemptions	4	0	1	4	0	0	0	0	0	$0
Subtotal for Reporting						194,725				$35,197,779
4.) Recordkeeping Requirements
A. Familiarize with Regulatory Requirementsc	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 h	4	0	47	188	102	19,176	958.8	1,918	0	$2,647,678.26
2) Records of all emission rates, computations, tests h	4	0	47	188	102	19,176	958.8	1,918	0	$2,647,678.26
3) Records of employee review of operations manual	4	0	1	4	38	152	7.6	15.2	0	$20,987.02
4) Record amount of sorbent used for Hg and dioxin/furan control i	4	0	4	16	102	1,632	81.6	163.2	0	$225,334.32
5) Records of emisssion exceedances and periods when emission data not obtained	See 3E
6) Records of CEMS drift tests and Appendix F accuracy assessments	See 4E 1-4
7) Records of initial performance test	See 3E
8) Records of annual performance tests	See 3E
9) Records of opacity limits for air curtain incinerators	See 3E
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping						46,156				$5,541,678
TOTAL LABOR BURDEN AND COST (Rounded)j						241,000				$40,700,000
Capital and O&M Cost j										$979,000
GRAND TOTAL j										$41,700,000
Assumptions:
a. There are 146 large MWC units located at 57 MWC plants. Of these, there are 102 large MWC units at 38 plants that are privately owned.
b. This ICR uses the following labor rates: $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 percent 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. The contractor rate was derived by taking the contractor rate used in the previous ICR and multiplying by the average increase in managerial, technical, and clerical rates since the previous ICR.
c. This ICR assumes all respondents will have to familiarize with regulatory requirements.
d. Assume 20 percent of reporting plants must repeat initial tests due to failure at one unit at the plant.
e. Values were adjusted based on the change in respondents since the previous ICR (values in #3 should add up to respondents submitting annual compliance reports)
f. 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.
g. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
h. Based on weekly recordkeeping, we assume 47 weeks of operation (90 percent availability) per year per MWC.
i. Based on quarterly calculation of sorbent use for entire plant, regardless of the number of affected facilities at the plant.
j. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 1b

Table 1b: Annual Publicly-Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
						123.94	157.61	62.52	201.86
Burden Item	(A) Respondent Person Hours Per Occurrence	(B) Contractor Person Hours Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Hours Per Respondent Per Year (D=AxC)	(E) Number of Respondents Per Year a	(F) Technical Hours Per Year (F=DxE)	(G) Management Hours Per Year (G=Fx0.05)	(H) Clerical Hours Per Year (H=Fx0.1)	(I) Contractor Hours Per Year (I=BxCxE)	(J) Total Costs Per Year b
1.) Applications	N/A
2.) Surveys and Studies	N/A
3.) Reporting Requirements
A. Familiarize with Regulatory Requirements c
1) New Sources	40	0	1	40	0	0	0	0	0	$0
2) Existing Sources	4	0	1	4	19	76	3.8	7.6	0	$10,493.51
B. Required Activities
1) Initial performance tests and reports
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)	24	750	1	24	0	0	0	0	0	$0
b) Repeat of Initial performance tests d	24	750	1	24	0	0	0	0	0	$0
2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)
a) Installation of CEM units	24	200	1	24	0	0	0	0	0	$0
b) Initial demonstration	24	430	1	24	0	0	0	0	0	$0
c) Repeat of initial demonstration d	24	430	1	24	0	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) e
a) Plants that do not qualify for reduced D/F testing with 2 units	24	1,500	1	24	1	24	1.2	2.4	1,500	$306,103.74
b) Plants that do not qualify for reduced D/F testing with 3 units	24	2,250	1	24	1	24	1.2	2.4	2,250	$457,498.74
c) Plants that qualify for reduced D/F testing with 2 units	24	1,428	1	24	8	192	9.6	19.2	11,424	$2,332,558.56
d) Plants that qualify for reduced D/F testing with 3 units	24	2,106	1	24	9	216	10.8	21.6	18,954	$3,855,878.10
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a) RATA audit (one per year)f	8	350	1	8	44	352	17.6	35.2	15,400	$3,157,245.52
b) RAA audit (three per year)f	8	130	3	24	44	1,056	52.8	105.6	17,160	$3,609,722.16
c) Daily calibration and operation	1	0	365	365	44	16,060	803.0	1,606	0	$2,217,444.35
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Plant startup
a) Control plan	40	0	1	40	0	0	0	0	0	$0
b) Notification of contract awards	4	0	1	4	0	0	0	0	0	$0
c) Notification of on-site construction start	4	0	1	4	0	0	0	0	0	$0
d) Notification of construction completion	4	0	1	4	0	0	0	0	0	$0
e) Notification of final compliance	4	0	1	4	0	0	0	0	0	$0
2) Notification of initial performance tests	4	0	1	4	0	0	0	0	0	$0
3) Initial compliance reports	40	0	1	40	0	0	0	0	0	$0
4) Notification of CEMS demonstration	4	0	1	4	0	0	0	0	0	$0
5) Initial CEMS demonstration report	90	0	1	90	0	0	0	0	0	$0
6) Notification of starting or stopping use of the CEMS	4	0	1	4	0	0	0	0	0	$0
7) Air Curtain incinerator initial performance tests	4	0	1	4	0	0	0	0	0	$0
8) Annual compliance reports	40	0	1	40	19	760	38	76	0	$104,935.10
9) Semi-annual excess emission reports g	40	0	2	80	4	304	15.2	30.4	0	$41,974.04
10) Notification of exemptions	4	0	1	4	0	0	0	0	0	$0
Subtotal for Reporting						88,612				$16,093,854
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) Record startups, shutdowns, and malfunctions h	4	0	47	188	44	8272	413.6	827.2	0	$1,142,135.72
2) Records of all emission rates, computations, tests h	4	0	47	188	44	8272	413.6	827.2	0	$1,142,135.72
3) Records of employee review of operations manual	4	0	1	4	19	76	3.8	7.6	0	$10,493.51
4) Record amount of sorbent used for Hg and dioxin/furan control i	4	0	4	16	44	704	35.2	70.4	0	$97,203.04
5) Records of emisssion exceedances and periods when emission data not obtained g	See 3E
6) Records of CEMS drift tests and Appendix F accuracy assessments	See 4E 1-4
7) Records of initial performance test	See 3E
8) Records of annual performance tests	See 3E
9) Records of opacity limits for air curtain incinerators	See 3E
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping						19,923				$2,391,968
TOTAL LABOR BURDEN AND COST (Rounded)j						109,000				$18,500,000
Capital and O&M Cost j										$422,000
GRAND TOTAL j										$18,900,000
Assumptions:
a. There are 146 large MWC units located at 57 MWC plants. Of these, there are 44 large MWC units at 19 plants that are publicly owned.
b. This ICR uses the following labor rates: $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 percent 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. The contractor rate was derived by taking the contractor rate used in the previous ICR and multiplying by the average increase in managerial, technical, and clerical rates since the previous ICR.
c. This ICR assumes all respondents will have to familiarize with regulatory requirements
d. Assume 20 percent of reporting plants must repeat initial tests due to failure at one unit at the plant.
e. Values were adjusted based on the change in respondents since the previous ICR (values in #3 should add up to respondents submitting annual compliance reports)
f. 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.
g. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
h. Based on weekly recordkeeping, we assume 47 weeks of operation (90 percent availability) per year per MWC.
i. Based on quarterly calculation of sorbent use for entire plant, regardless of the number of affected facilities at the plant.
j. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 1c

Table 1c: Average Annual Designated Administrator Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
			52.37	70.56	28.34
Burden Item	(A) Number of Occurences Per Year a	(B) Administrator Hours Per Occurrence	(C) Technical Hours Per Year (C=AxB)	(D) Management Hours Per Year (D=Cx0.05)	(E) Clerical Hours Per Year (E=Cx0.1)	(F) Administrator Costs Per Year b
1.) Applications	N/A
2.) Familiarize with Regulatory Requirementsc	15	4	60	3	6	$3,523.92
3.) Required Activities
A. Develop a state plan	0	2,080	0	0	0	$0
B. Public Hearing on state plan	0	8	0	0	0	$0
A. Observe initial performance tests
1) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)d	0	48	0	0	0	$0
2) Repeat of initial performance tests e	0	10	0	0	0	$0
B. Excess emissions -- enforcement activities f	10	24	230.4	11.52	23.04	$13,531.85
C. Create Information
D. Gather Information
E. Report Reviews
1) Control plan	0	8	0	0	0	$0
2) Notification of contract awards	0	8	0	0	0	$0
3) Notification of on-site construction start	0	8	0	0	0	$0
4) Notification of construction completion	0	8	0	0	0	$0
5) Notification of final compliance	0	8	0	0	0	$0
6) Review notification of initial performance test	0	8	0	0	0	$0
7) Review notification of initial CEMS demonstration	0	4	0	0	0	$0
8) Review notification of starting or stopping use of the CEMS	0	8	0	0	0	$0
9) Review initial performance test report	0	40	0	0	0	$0
10) Review initial CEMS demonstration report	0	40	0	0	0	$0
11) Review annual compliance report g	48	40	1,920	96	192	$112,765.44
12) Review semi-annual excess emission report f	10	16	153.6	7.68	15.36	$9,021.24
13) Review of notifications of exemption	0	4	0	0	0	$0
F. Prepare annual summary report	0	200	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)h			2,720			$139,000
Assumptions:
a. Assume 124 affected units as 48 plants in 15 states.
b. This IRC uses the following labor rates: $70.56 Managerial rate (GS-13, Step 5, $44.10 + 60%), $52.37 Technical rate (GS-12, Step 1, $32.73 + 60%), and $28.34 Clerical rate (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. This ICR assumes all respondents will have to familiarize with regulatory requirements
d. Assume EPA personnel attend about 8 percent of tests.
e. Assume a 20 percent failure rate and that EPA personnel attend 10 percent of the retests.
f. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
g. Burden not incurred until second year of operation and later.
h. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 5: Table 2

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)
			52.37	70.56	28.34
Burden Item	(A) Number of Occurences Per Year a	(B) Administrator Hours Per Occurrence	(C) Technical Hours Per Year (C=AxB)	(D) Management Hours Per Year (D=Cx0.05)	(E) Clerical Hours Per Year (E=Cx0.1)	(F) Administrator Costs Per Year b
1.) Applications	N/A
2.) Familiarize with Regulatory Requirements	0	4	0	0	0	$0
3.) Required Activities
A. Observe initial performance tests
1) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)c	0	48	0	0	0	$0
2) Repeat of initial performance tests d	0	10	0	0	0	$0
B. Excess emissions -- enforcement activities e	1.8	24	43.2	2.16	4.32	$2,537.22
C. Create Information
D. Gather Information
E. Report Reviews
1) Control plan	0	8	0	0	0	$0
2) Notification of contract awards	0	8	0	0	0	$0
3) Notification of on-site construction start	0	8	0	0	0	$0
4) Notification of construction completion	0	8	0	0	0	$0
5) Notification of final compliance	0	8	0	0	0	$0
6) Review notification of initial performance test	0	8	0	0	0	$0
7) Review notification of initial CEMS demonstration	0	4	0	0	0	$0
8) Review notification of starting or stopping use of the CEMS	0	8	0	0	0	$0
9) Review initial performance test report	0	40	0	0	0	$0
10) Review initial CEMS demonstration report	0	40	0	0	0	$0
11) Review annual compliance report f	9	40	360	18	36	$21,143.52
12) Review semi-annual excess emission report e	1.8	16	28.8	1.44	2.88	$1,691.48
13) Review of notifications of exemption	0	4	0	0	0	$0
F. Prepare annual summary report	0	200	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)g			497			$25,400
Assumptions:
a. Assumes 22 affected units at 9 facilities in 4 states without State Plans and thus are subject to the Federal Plan.
b. This IRC uses the following labor rates: $70.56 Managerial rate (GS-13, Step 5, $44.10 + 60%), $52.37 Technical rate (GS-12, Step 1, $32.73 + 60%), and $28.34 Clerical rate (GS-6, Step 3, $17.71 + 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. Assume EPA personnel attend about 8 percent of tests.
d. Assume a 20 percent failure rate and that EPA personnel attend 10 percent of the retests.
e. Assumes 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
f. Burden not incurred until second year of operation and later.
g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: 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)
Private sector- Load monitors, temperature monitors, and carbon feed rate monitors.	$100,000	0	$0	$9,600	102	$979,200
Public sector -Load monitors, temperature monitors, and carbon feed rate monitors.	$100,000	0	$0	$9,600	44	$422,400
Totals (rounded) c		0	$0		146	$1,400,000		$1,400,000
a Since the Emission Guidelines only apply to sources that commenced construction on or before September 20, 1994, no additional MWC units will become subject to the standard over the next three years.
b Approximately 146 sources located at 57 plants are currently subject to the Emissions Guidelines and each source requires continuous monitoring. Of the 146 sources, 102 sources are within the private sector and 44 sources are publicly owned.
c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

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Sheet 7: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Privately owned large MWCs
Increments of Progress (Plant Control Plan, notifications, etc.)	0	3	0	0
Initial Testing Notifications and Reports (Performance Test, CEMS Demonstration, etc.	0	4	0	0
Annual Performance Tests and Reports	38	1	0	38
Annual Compliance Reports	38	1	0	38
Semiannual Excess Emission Reports	8	2	0	16
			Total	92
Publicly owned large MWCs
Increments of Progress (Plant Control Plan, notifications, etc.)	0	3	0	0
Initial Testing Notifications and Reports (Performance Test, CEMS Demonstration, etc.	0	4	0	0
Annual Performance Tests and Reports	19	1	0	19
Annual Compliance Reports	19	1	0	19
Semiannual Excess Emission Reports	4	2	0	8
			Total	46
Designated State Plan Administrators
Excess Emissions – Enforcement Activities	10	1	0	10
Review Annual Compliance Report	48	1	0	48
Review Semiannual Excess Emissions Report	10	1	0	10
			Total	68
a We assume 38 privately owned facilities, 19 privately owned facilities, and 48 facilties subject to designated state plans. We assume 20% of each of these facilities will have to submit or review excess emissions reports. This ICR assumes a facility's report includes information for all units they own/operate.

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Sheet 8: 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 b	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	72	0	0	72
2	0	72	0	0	72
3	0	72	0	0	72
Average	0	72	0	0	72
a New respondents include sources with constructed and reconstructed affected facilities.
b An average of 57 large MWC plants (respondents) will be subject to the standards over the next three years. Approximately 38 respondents are privately owned and 19 respondents are publicly owned. Additionally, it is estimated there will be 15 State Designated Administrators. Total number of respondents = (57 + 15) = 72.