Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	254
Number of Respondents	28
Total Estimated Burden Hours	19,200
Total Estimated Costs	$2,430,000
Annualized Capital O&M	$239,000
Total Annual Responses	76
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal)
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 year a	(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 year b
1. Applications	N/A									State/Federal Govt. Labor Rates:
2. Survey and Studies	N/A									Management	70.56
3. Reporting Requirements (States)										Technical	52.37
A. Familiarize with Regulatory Requirements c	1	1	1	10	10	0.5	1	$1,380.73		Clerical	28.34
B. Required activities d
- Development of State Plan/Inventory	2,080	1	2,080	0	0	0	0	$0		Private Industry Labor Rates:
- Annual update of State Plan Inventory	20	1	20	10	200	10	20	$27,614.50		Management	157.61
- Public hearing on State Plan	8	1	8	0	0	0	0	$0		Technical	123.94
C. Create information	See 3B									Clerical	62.52
D. Gather information	See 3B
E. Write report
- State Plan/Inventory	See 3B
- Annual update of State Plan Inventory	See 3B
- Notification of public hearing on State Plan	8	1	8	0	0	0	0	$0
- Certification that public hearing on State Plan conducted according to Subpart B State procedures	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements (States)					242			$28,995
4. Reporting requirements (privately-owned HMIWI)											1899.09	1899.10
A. Familiarize with Regulatory Requirements c	1	1	1	16	16	0.8	1.6	$2,209.16		Private	31	16
B. Required activities e										Federal	5	1
Annual update of operating information f	20	1	20	16	320	16	32	$44,183.20		State/Local	0	1
Review operating information with each operator g	8	2	16	16	256	12.8	25.6	$35,346.56		State Plan Inventory	22	10
Annual equipment inspection (small rural HMIWI)	20	1	20	1	20	1	2	$2,761.45		Total	58	28
Annual equipment inspection (all other HMIWI)	20	1	20	15	300	15	30	$41,421.75
C. Create information	See 4B
D. Gather information	See 4B
E. Write report e
Annual report
CMS operating parameters	32	1	32	16	512	25.6	51.2	$70,693.12
Emissions/parameter exceedances and periods when emission/parameter data not obtained j
- Small rural HMIWI	16	1	16	0.2	3.2	0.16	0.32	$441.83
- All other HMIWI	64	1	64	3	192	9.6	19.2	$26,509.92
Report of annual performance test
- Small rural HMIWI	20	1	20	1	20	1	2	$2,761.45
- All other HMIWI	280	1	280	15	4,200	210	420	$579,904.50
Report of no exceedances
- Small rural HMIWI	8	1	8	0.8	6.4	0.32	0.64	$883.66
- All other HMIWI	32	1	32	12	384	19.2	38.4	$53,019.84
Report of annual equipment inspection	See 4B
Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained (small non-rural, medium, and large HMIWI) j	32	2	64	3	192	9.6	19.2	$26,509.92
Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained (small rural HMIWI) j	8	2	16	0.2	3.2	0.16	0.32	$441.83
Subtotal for Reporting Requirements (Privately-owned HMIWI)					7,389			$887,088
5. Reporting requirements (Federally-owned HMIWI)
A. Familiarize with Regulatory Requirements c	1	1	1	1	1	0.05	0.1	$58.73
B. Required activities
Annual update of operating information f	20	1	20	1	20	1	2	$1,174.64
Review operating information with each operator g	8	2	16	1	16	0.8	1.6	$939.71
Annual control equipment inspection	20	1	20	1	20	1	2	$1,174.64
C. Create information	NA
D. Gather existing information	See 5B
E. Write report
Annual report
CMS operating parameters	32	1	32	1	32	1.6	3.2	$1,879.42
Emissions/parameter exceedances and periods when emission/parameter data not obtained j	64	1	64	0.2	12.8	0.64	1.28	$751.77
Report of annual performance test	40	1	40	1	40	2	4	$2,349.28
Report of no exceedances	32	1	32	0.8	25.6	1.28	2.56	$1,503.54
Report of annual equipment inspection	See 5B
Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained j	32	2	64	0.2	12.8	0.64	1.28	$751.77
Subtotal for Reporting Requirements (Federally-owned HMIWI)					207			$10,584
6. Reporting requirements (State/locally-owned HMIWI)
A. Familiarize with Regulatory Requirements c	1	1	1	1	1	0.05	0.1	$59
B. Required activities
Annual update of operating information	20	1	20	1	20	1	2	$1,175
Review operating information with each operator	8	2	16	1	16	0.8	1.6	$940
Annual control equipment inspection	20	1	20	1	20	1	2	$1,175
C. Create information	NA
D. Gather existing information	See 6B
E. Write report
Annual report
CMS operating parameters	32	1	32	1	32	1.6	3.2	$1,879
Emissions/parameter exceedances and periods when emission/parameter data not obtained j	64	1	64	0.2	12.8	0.64	1.28	$752
Report of annual performance test	40	1	40	1	40	2	4	$2,349
Report of no exceedances j	32	1	32	0.8	25.6	1.28	2.56	$1,504
Report of annual equipment inspection	See 6B
Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained j	32	2	64	0.2	12.8	0.64	1.28	$752
Subtotal for Reporting Requirements (State/locally-owned HMIWI)					207			$10,853
7. Reporting requirements (co-fired combustors and pathological/low-level radioactive/chemotherapeutic waste combustors)
A. Familiarize with Regulatory Requirements c, k	1	1	1	6.9	6.92	0.346	0.692	$955
B. Required activities	N/A
C. Create information	N/A
D. Gather existing information	N/A
E. Write report
Notification of exemption claim	2	1	2	0	0	0	0	$0
Notification of relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted (co-fired combustors only)	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements (Co-fired combustors and pathological/low-level radioactive/chemotherapeutic waste combustors)					8			$955
8. Recordkeeping requirements (States)
A. Familiarize with Regulatory Requirements	See 3A
B. Plan activities	NA
C. Implement activities	NA
D. Develop record system	NA
E. Time to enter information	NA
F. Time to train personnel	NA
G. Time for audits	NA
Subtotal for Recordkeeping Requirements (States)					0			$0
9. Recordkeeping requirements (privately-owned HMIWI)
A. Familiarize with Regulatory Requirements	See 4A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdown, malfunction	1.5	52	78	16	1,248	62.4	124.8	$172,314.48
Records of persons reviewing operating information	2	2	4	16	64	3.2	6.4	$8,836.64
Records of operators completing training requirements	2	1	2	0	0	0	0	$0
Records of operators that have been qualified	2	1	2	0	0	0	0	$0
Records of initial performance test	See 4E
Records of process and control device operating parameters
- Small rural HMIWI	0.5	52	26	1	26	1.3	2.6	$3,589.89
- All other HMIWI	1.5	52	78	15	1,170	58.5	117	$161,544.83
Records of CMS operation and maintenance
- Small rural HMIWI	0.5	250	125	1	125	6.25	12.5	$17,259.06
- All other HMIWI	1.5	250	375	15	5,625	281.25	562.5	$776,657.81
Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j
- Small rural HMIWI	0.5	52	26	0.2	5.2	0.26	0.52	$717.98
- All other HMIWI	1.5	52	78	3	234	11.7	23.4	$32,308.97
Records of annual and subsequent compliance tests	See 4E
Records of annual equipment inspection	See 4B
F. Time to train personnel	40	1	40	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements (Privately-owned HMIWI)					9,772			$1,173,230
10. Recordkeeping requirements (Federally-owned HMIWI)
A. Familiarize with Regulatory Requirements	See 5A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdown, malfunction	1.5	52	78	1	78	3.9	7.8	$4,581.10
Records of persons reviewing operating information	2	2	4	1	4	0.2	0.4	$234.93
Records of operators completing training requirements	2	1	2	0	0	0	0	$0
Records of operators that have been qualified	2	1	2	0	0	0	0	$0
Records of initial performance test	See 5E
Records of process and control device operating parameters	1.5	52	78	1	78	3.9	7.8	$4,581.10
Records of CMS operation and maintenance	1.5	250	375	1	375	18.75	37.5	$22,024.50
Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j	1.5	52	78	0.2	15.6	0.78	1.56	$916.22
Records of annual and subsequent compliance tests	See 5E
Records of annual equipment inspection	See 5B
F. Time to train personnel	40	1	40	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements (Federally-owned HMIWI)					633			$32,338
11. Recordkeeping requirements (State/locally-owned HMIWI)
A. Familiarize with Regulatory Requirements	See 6A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdown, malfunction	1.5	52	78	1	78	3.9	7.8	$4,581
Records of persons reviewing operating information r	2	2	4	1	4	0.2	0.4	$235
Records of operators completing training requirements	2	1	2	0	0	0	0	$0
Records of operators that have been qualified	2	1	2	0	0	0	0	$0
Records of initial performance test	See 6E
Records of process and control device operating parameters	1.5	52	78	1	78	3.9	7.8	$4,581
Records of CMS operation and maintenance	1.5	250	375	1	375	18.75	37.5	$22,025
Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j	1.5	52	78	0.2	15.6	0.78	1.56	$916
Records of annual and subsequent compliance tests	See 6E
Records of annual equipment inspection	See 6B
F. Time to train personnel	40	1	40	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements (State/Locally-owned HMIWI)					633			$32,338
12. Recordkeeping requirements (co-fired and pathological/low-level radioactive/ chemotherapeutic combustors)
A. Familiarize with Regulatory Requirements	See 7A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Quarterly records of periods when only pathological, low-level radioactive, chemotherapeutic waste burned k	2	4	8	6.9	55.36	2.768	5.536	$7,643.69
Quarterly records of weight of hospital waste and medical/infectious waste combusted, and weight of all other fuels and waste combusted (co-fired only) k	2	4	8	2.6	20.64	1.032	2.064	$2,849.82
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements (Co-fired and pathological/low level radioactive / chemotherapeutic combustors)					87			$10,494
TOTAL REPORTING REQUIREMENTS (FROM SUBTOTALS)					8,052			$938,475
TOTAL RECORDKEEPING REQUIREMENTS (FROM SUBTOTALS)					11,126			$1,248,399		242	State burden
TOTAL LABOR BURDEN AND COST (rounded) l,m					19,200			$2,190,000		840	Federally owned burden			19,178	QA/QC of total burden
TOTAL CAPITAL AND O&M COST (rounded) l								$239,000		17,256	Privately-owned burden
GRAND TOTAL (rounded) l								$2,430,000		840	State/locally-owned burden
										254	hr/response
Note: States and tribes may choose to impose requirements that are more stringent. However, the burden estimates provided in this ICR assume that the state and tribal plans mirror the federal Emission Guidelines.
Assumptions:
a We have assumed that there are approximately 28 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. The breakdown is as follows: 16 privately-owned HMIWI (including 1 small rural HMIWI), 1 Federally-owned HMIWI, and 1 State/locally-owned HMIWI. Additionally, there are 10 States that require annual State Plan Inventory.
b This ICR uses the following labor rates: Managerial $157.61 ($75.05+ 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). 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. In addition, this ICR uses the following labor rates for Federal and State government: expenses: 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, $17.71 + 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 State government employees and government overhead expenses.
c We have assumed all respondents will have to familiarize with regulatory requirements.
d Assume all 10 states with HMIWI have approved State Plan by the first year of this ICR. However, the State Plan/Inventory is updated on an annual basis.
e The zero value for number of respondents indicates that burden was incurred prior to the time period covered by this supporting statement or for new respondents.
f We have assumed that it would take each respondent 20 hours each to update the annual operating information.
g We have assumed that it would take each respondent 8 hours to review the operating information with each operator.
h We have assumed that each facility will take 160 hours to develop the operating information.
i We have assumed that each facility will take 40 hours to develop the waste management plan.
j Assume 20 percent of respondents report exceedances, and 80 percent report no exceedances.										1899.09	1899.10	1899.09 footnote k
k We have assumed that all co-fired and pathological/low-level radioactive/ chemotherapeutic combustors units would be owned by the private sector. We assume an average of 6.9 units per year (which includes 2.6 co-fired units) will need to re-familiarize themselves with regulatory requirements over the three-year period of this ICR.										13.4	6.9	k We have assumed that all co-fired and pathological/low-level radioactive/ chemotherapeutic combustors units would be owned by the private sector. We assume an average of 13.4 units per year (which includes 5 co-fired units) will need to re-familiarize themselves with regulatory requirements over the three-year period of this ICR.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.										5	2.6
m Total includes 4,200 hours from Federally-owned and operated facilities.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal)
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 year a	(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 year b
1. Initial performance test	32	1	32	0	0	0	0	$0		Labor Rates:
2. Repeat performance test										Management	70.56
A. Retesting preparation	12	1	12	0	0	0	0	$0		Technical	52.37
B. Attend retesting	32	1	32	0	0	0	0	$0		Clerical	28.34
3. Report review
A. Review reports for co-fired combustors
Review notification of exemption claim	2	1	2	0	0	0	0	$0
Review notification of relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted	2	1	2	0	0	0	0	$0
B. Review notification of exemption claim for pathological, low-level radioactive, chemotherapeutic combustors	2	1	2	0	0	0	0	$0
C. Review reports of increments of progress
Review control plan	4	1	4	0	0	0	0	$0
Review notification of construction contracts	2	1	2	0	0	0	0	$0
Review notification of construction commencement	2	1	2	0	0	0	0	$0
Review notification of construction completion	2	1	2	0	0	0	0	$0
Review notification of control plan completion	2	1	2	0	0	0	0	$0
D. Review request for extension for HMIWI planning to shut down late	4	1	4	0	0	0	0	$0
E. Review reports for small non-rural, medium and large HMIWI
Review waste management plan	8	1	8	0	0	0	0	$0
Review notification of initial performance test	8	1	8	0	0	0	0	$0
Review notification of initial CMS demonstration	5	1	5	0	0	0	0	$0
Review report of initial performance test	36	1	36	0	0	0	0	$0
Review report of initial CMS demonstration	24	1	24	0	0	0	0	$0
Review annual report
CMS operating parameters
- Small rural HMIWI	2	1	2	1	2	0.1	0.2	$117.46
- All other HMIWI	6	1	6	17	102	5.1	10.2	$5,990.66
Emissions/parameter exceedances and periods when emission/parameter data not obtained c
- Small rural HMIWI	4	1	4	0.2	0.8	0.04	0.08	$46.99
- All other HMIWI	16	1	16	3.4	54.4	2.72	5.44	$3,195.02
Results of annual performance test
- Small rural HMIWI	6	1	6	1	6	0.3	0.6	$352.39
- All other HMIWI	24	1	24	17	408	20	40.8	$23,962.66
Report of no exceedances
- Small rural HMIWI	2	1	2	0.8	1.6	0.08	0.16	$93.97
- All other HMIWI	8	1	8	13.6	109	5.4	10.9	$6,390.04
Review semiannual report of emissions/ parameter exceedances and periods when emission/parameter data not obtained c
- Small rural HMIWI	2	1	2	0.2	0.4	0.02	0.04	$23.49
- All other HMIWI	8	1	8	3.4	27.2	1.36	2.72	$1,597.51
Report of annual equipment inspection (Small rural HMIWI)	4	1	4	1	4	0.2	0.4	$234.93
Report of annual control equipment inspection (All other HMIWI)	4	1	4	0	0	0	0	$0
G. Review reports for States
Review annual update of State Plan Inventory d	8	1	8	10	80	4	8	$4,698.56
4. Prepare annual summary report e	1	1	1	18	18	0.9	1.8	$1,057.18
TOTAL (rounded) f					940			$48,000
Assumptions:
a We have assumed that there are approximately 28 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. The breakdown is as follows: 16 privately-owned HMIWI (including 1 small rural HMIWI), 1 Federally-owned HMIWI, and 1 State/locally-owned HMIWI. Additionally, there are 10 States that require annual State Plan Inventory.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 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, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
c Assume 20 percent of respondents report parameter exceedances, and 80 percent report no exceedances.
d Assume all 10 States have approved State/Plan Inventory. All States are expected to update State Plan/Inventory annually.
e We have assumed that all respondents will have to prepare annual summary report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: 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)
Monitoring costs
- Privately-owned HMIWI	$3,751	0	$0	$11,957	16	$191,312
- Federally owned HMIWI	$3,700	0	$0	$8,317	1	$8,317
- State/locally-owned HMIWI	$3,700	0	$0	$6,275	1	$6,275
Testing 2	$21,000	0	$0	NA	0	$0
File Cabinets 3	$33.50	0	$0	NA	0	$0
Photocopying and postage
- States	N/A	0	$0	$16.27	10	$163
- Privately-owned HMIWI	N/A	0	$0	$50.28	16	$804
- Federally owned HMIWI	N/A	0	$0	$49.67	1	$50
- State/locally-owned HMIWI	N/A	0	$0	$49.50	1	$50
Temperature pressure, flow rate, change rate, voltage, and pH monitors 4
- Privately-owned HMIWI	N/A	0	$0	$1,800	16	$28,800
- Federally owned HMIWI	N/A	0	$0	$1,800	1	$1,800
- State/locally-owned HMIWI	N/A	0	$0	$1,800	1	$1,800
Subtotals
- States			$0			$163
- Privately-owned HMIWI			$0			$220,916
- Federally owned HMIWI			$0			$10,167
- State/locally-owned HMIWI			$0			$8,125
TOTAL			$0			$239,000
Notes: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. 1 This ICR assumes there are no new respondents that would be required to install monitoring and testing equipment. Therefore, there are no capital/startup costs associated with this ICR. 2 Average testing cost for all respondents. 3 Annualized cost with a capital recovery factor of 0.14238 based on a 10-year equipment life and a 7 percent interest rate, assuming each facility will purchase one standard four-drawer file cabinet ($235 per cabinet). 4 The average HMIWI operates approximately 6 continuous monitoring devices. The average cost per monitoring device is $300 per year. Therefore, the estimated O&M cost per respondent is estimated to be $1,800.

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Sheet 5: Responses

Total Annual Responses
Information Collection Activity	States	Privately-Owned HMIWI	Federally- Owned HMIWI	State/Locally Owned HMIWI	Total
State Plan/inventory 1	0	0	0	0	0
Annual update of State Plan inventory	10	0	0	0	0
Notification of initial performance test and CMS demonstration	N/A
Annual Reports 2
CMS emissions and operating parameters	0	16	1	1	18
Exceedances, malfunctions, and periods for which data not obtained	0	3.2	0.2	0.2	3.6
Results of performance tests conducted during the year	0	16	1	1	18
Report of no exceedances	0	12.8	0.8	0.8	14.4
Report of annual equipment or control device inspection	0	16	1	1	18
Semiannual report of exceedances, malfunctions, and periods for which data not obtained 3	0	3.2	0.2	0.2	3.6
Total 4	10	67.2	4.2	4.2	76

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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	28	0	0	28
2	0	28	0	0	28
3	0	28	0	0	28
Average	0	28	0	0	28
a New respondents include sources with constructed and reconstructed affected facilities.