Burden Calculations Table

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents
Stack testing

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Sheet 1: Summary

ICR Summary Information
Hours per Response	90
Number of Respondents	11
Total Estimated Burden Hours	1,800
Total Estimated Costs	$1,950,000
Annualized Capital O&M	$1,850,000
Total Annual Responses	20
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Sewage Sludge Incineration Units (40 CFR Part 60, Subpart LLLL) (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) Cost, $ b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$73.46
3. Reporting Requirements										Technical	$54.51
A. Familiarize with regulation requirements										Clerical	$29.50
1) New sources c	40	1	40	1	40	2	4	$2,445.42
2) Existing sources d	4	1	4	10	40	2	4	$2,445.42
B. Required activities
1) Initial stack test and report (new sources) c	40	1	40	1	40	2	4	$2,445.42
2) Annual stack test and test report (existing sources) d, e	40	0.33	13.2	3.3	43.56	2.18	4.36	$2,663.06
3) Operator training and qualification
a) Establish and teach operator qualification course c, f	64	1	64	1	64	3	6	$3,912.67
b) Obtain operator qualification c, f	10	1	10	1	10	0.5	1	$611.35
c) Annual refresher course d	2	1	2	10	20	1	2.0	$1,222.71
d) Initial review of site-specific information	See 3A
e) Annual review of site-specific information (existing sources) d	8	1	8	10	80	4	8	$4,890.83
4) Establish maximum and minimum operating parameters (new sources) c	40	1	40	1	40	2	4	$2,445.42
5) Continuous parameter monitoring (including CEMS) d	11	1	11	10	110	5.5	11	$6,724.89
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write report
1) Notification of construction (includes siting analysis) c	160	1	160	1	160	8	16	$9,781.66
2) Notification of start-up (includes monitoring plan) c	40	1	40	1	40	2	4	$2,445.42
3) Notification of initial performance test c	2	1	2	1	2	0.1	0.2	$122.27
4) Notification of initial CMS Demonstration c	2	1	2	1	2	0.1	0.2	$122.27
5) Initial Compliance Report	40	1	40	1	40	2	4	$2,445.42
6) Annual Compliance Report	40	1	40	10	400	20	40	$24,454.16
7) Status report for operators that are off-site for more than 2 weeks g	8	1	8	1	8	0.4	0.8	$489.08
8) Corrective action summary for operators that are off-site for more than 2 weeks g	8	2	16	1	16	0.8	1.6	$978.17
9) Semiannual Deviation Report h	24	2	48	1	48	2.4	4.8	$2,934.50
Subtotal for Reporting Requirements					1,384			$73,580
4. Recordkeeping Requirements
A. Familiarize with regulation requirements
B. Plan activities	See 3A
C. Implement activities:	N/A
D. Develop record system	N/A
E. Record Information	N/A
1) Records of operating parameters	2	52	104	0	0	0	0	$0
2) Records of exceedances of the operating parameters h	2	1	2	1	2	0.1	0.2	$122.27
3) Records of stack tests	2	1	2	10	20	1	2	$1,222.71
4) Records of siting analysis	2	1	2	10	20	1	2	$1,222.71
5) Records of persons who have reviewed operating procedures	2	1	2	10	20	1	2	$1,222.71
6) Records of persons who have completed operator training	2	1	2	10	20	1	2	$1,222.71
7) Records of persons who meet operator qualification criteria	2	1	2	10	20	1	2	$1,222.71
8) Records of monitoring device calibration	2	1	2	10	20	1	2	$1,222.71
9) Records of site-specific documentation	24	1		10
F. Time to train personnel	24	1	24	10	240	12	24	$14,672.50
G. Time for audits	See 3B
	N/A
Subtotal for Recordkeeping Requirements					416			$22,131		90	hr/response
Total Labor Burden and Costs (rounded) i					1,800			$95,700
Total Capital and O&M Cost (rounded) i								$1,850,000
GRAND TOTAL (rounded) i								$1,950,000
Assumptions:
a We assume there are 10 existing facilities with 6 incineration units each. Burden estimates are based on a "per respondent" basis, not a "per unit" basis. We assume that there will be a total of 2 new sources and 1 modified source over the next three-year period, averaging to 1 new respondent per year. Estimates are based on EPA's 2016 SSI Inventory.
b These rates are based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 One-time only costs for new sources.
d Annual Costs for existing sources. Annual costs are not incurred until the second year of operation.
e Existing facilities may test every three years if certain requirements are met, and it is assumed that all facilities would meet the requirements. Thus, on average 3.3 existing sources per year (10 x 0.33 = 3.3) perform annual testing following the initial performance test.
f Costs incurred by a facility regardless of the number of affected units at the plant.
g We assume that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. We further assume that this would require only two corrective action summaries.
h We assume that 10 percent of the facilities would have an exceedance during the year.
i Totals are 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 Sewage Sludge Incineration Units (40 CFR Part 60, Subpart LLLL) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Cost, $ b
1. Applications	N/A									Labor Rates
2. Required Activities										Management	$73.46
A. Observe stack tests c	48	1	48	0.65	30.96	1.55	3.10	$2,450.05		Technical	$54.51
B. Excess emissions - Enforcement activities	24	1	24	1	24	1.20	2.40	$1,467.25		Clerical	$29.50
C. Create Information	N/A
D. Gather Information	N/A
E. Report Reviews
1) Review initial notifications d	40	2	80	1	80	4	8	$4,890.83
2) Review initial compliance report	40	1	40	1	40	2	4	$2,445.42
3) Review annual compliance report	8	1	8	10	80	4	8	$4,890.83
4) Review semi-annual excess emission and parameter exceedance report	16	2	32	1	32	2	3.2	$1,956.33
5) Review status reports and corrective action summary for operators off-site	4	1	4	1	4	0.2	0.4	$244.54
F. Prepare annual summary report e	4	1	4	10	40	2.0	4	$2,445.42
TOTAL (rounded) h					381			$20,800
Assumptions:
a We assume there are 10 existing facilities with 6 incineration units each. Burden estimates are based on a "per respondent" basis, not a "per unit" basis. We assume that there will be a total of 2 new sources and 1 modified source over the next three-year period, averaging to 1 new respondent per year. Estimates are based on EPA's 2016 SSI Inventory.
b These rates are based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 EPA personnel attend 15 percent of the stack tests. New facilities do stack testing. Existing facilities may test every three years if certain requirements are met, and it is assumed that all facilities would meet the requirements. (((1 new facility + (10 existing facilities x 0.33)) x 0.15) = 0.65 tests observed per year)
d Includes notification of construction, notification of start-up for new units, notification of initial performance test, and notification of initial CMS demonstration.
e We assume four hours per state to write annual summary report.
f Totals rounded to 3 significant figures. Figures may not add exactly due to rounding.
g We assume that it will take the agency 15 hours to review the semiannual reports and that the agency will review summary reports twice per year.
h 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)
CEMS/CPMS b	$321,842	1	$321,842	$115,097	10	$1,150,966
Stack testing c	$87,000	1	$87,000	$87,000	3.3	$287,100
Filing cabinet d	$100	1	$100
Totals (rounded) c			$409,000			$1,440,000		$1,850,000
a We assume that there are 7 existing SSI facilities with an average of 6 incinerator units. Burden estimates are based on a "per respondent" basis, not a "per unit" basis. We assume that there will be a total of 2 new sources and 1 modified source over the next three-year period, averaging in an estimated growth rate of 1 new respondent per year. The estimate for the number of facilities subject to NSPS Subpart LLLL is based on EPA's 2016 SSI Inventory for the Federal Plan (See Appendix A at https://www.regulations.gov/document/EPA-HQ-OAR-2012-0319-0020) and adjusted to reflect the estimated growth rate.
b Based on estimated monitoring costs provided in Table 1 from the Supporting Statement for the Standards of Performance for New Stationary Sources: Sewage Sludge Incineration (SSI) Units (Subpart LLLL) from the March 21, 2011 final rule (see https://www.regulations.gov/document/EPA-HQ-OAR-2009-0559-0168). Monitoring costs have been updated from 2008 to 2022 values using the CEPCI CE Index.
c Total estimated cost for initial stack test, including Method 5 (PM), Method 9 (opacity), Method 10 (CO), Method 26 (HCl), Method 29 (metals), Method 23 (CDD/CDF), Method 7E (NOx), Method 6C (SO2), and visible emissions testing are from “Burden Estimate Tables - Standards of Performance for New Stationary Sources Sewage Sludge Incineration (SSI) Units (Subpart LLLL)” spreadsheet at https://www.regulations.gov/document/EPA-HQ-OAR-2009-0559-0168. Testing costs have been updated to 2022 dollars using the CEPCI CE Index. Existing facilities may test every three years if certain requirements are met, and it is assumed that all facilities would meet the requirements. Thus, on average 3.3 existing sources per year (10 x 0.33 = 3.3) perform annual testing following the initial performance test.
d Assumed $100 for purchase of filing cabinet to store copy of rule, records, and report copies.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: 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
Notification of Construction	1	1	0	1
Notification of Start-up	1	1	0	1
Notification of Initial Performance Test	1	1	0	1
Notification of Initial CMS Demonstration	1	1	0	1
Initial Compliance Report	1	1	0	1
Annual Compliance Report a	10	1	0	10
Status report for operators that are off-site for more than 2 weeks b	1	1	0	1
Corrective action summary for operators that are off-site for more than 2 weeks b	1	2	0	2
Semiannual Deviation Report c	1	2	0	2
			Total (rounded)	20
a Facilities may test every three years if certain requirements are met, and it is assumed most facilities would meet the requirements. However, all facilities must submit annual compliance reports.
b We assume that 10 percent of the existing facilities would not have a qualified operator available for more than two weeks at least once a year. We further assume this would require only two corrective action summaries.
c We assume that 10 percent of the existing facilities (10 * 0.1 = 0.9) have excess emissions and submit semiannual deviation reports.

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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	1	9	0	0	10
2	1	10	0	0	11
3	1	11	0	0	12
Average	1	10	0	0	11
a New respondents include sources with constructed, reconstructed and modified affected facilities. We assume there will be 2 new sources and 1 modified source over the next three years, averaging to an estimated growth rate of 1 new respondent per year. This industry growth estimate is based on EPA's 2016 SSI Inventory for the Federal Plan (see Appendix A at https://regulations.gov/document/EPA-HQ-OAR-2012-0319-0020) and adjusted to reflect the estimated growth rate.
b Estimates of the number of existing sources are based on the previous ICR (2369.05) and EPA's 2016 SSI Inventory.

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Sheet 7: Stack testing

Stack Testing Costs
Source: “Burden Estimate Tables - Standards of Performance for New Stationary Sources Sewage Sludge Incineration (SSI) Units (Subpart LLLL)” spreadsheet at https://www.regulations.gov/document/EPA-HQ-OAR-2009-0559-0168 [see the hidden stack testing tab]
Parameters/Costs		Equation	Values
A. Parameters
	1. Cost index
	a. 2022		816.0
	b. 2008		575.4
	c. 1992		358.2
				Adjusted testing cost
B. Testing Costs, $			2008 Value	Adjusted per Footnote 3	Updated to 2022 CEPCI
	1. Method 5 (PM)	= $8,000 x (575.4/358.2)	$13,000	$8,667	$12,300
	2. Method 9 (opacity)	= $1,000 x (575.4/358.2) + $1,500	$3,500	$2,333	$3,310
	3. Method 10 (CO)	= $4,000 x (575.4/358.2) + $1,000	$7,000	$4,667	$6,620
	4. Method 26 (HCl)	= $5,000 x (575.4/358.2)	$8,000	$5,333	$7,560
	5. Method 29 (metals)	= $8,000 x (575.4/358.2) + $2,000	$15,000	$10,000	$14,200
	6. Method 23 (CDD/CDF)	= $21,000 x (575.4/358.2) - $5,000	$29,000	$19,333	$27,400
	7. Method 7E (NOX)	= $5,000 x (575.4/358.2)	$8,000	$5,333	$7,560
	8. Method 6C (SO2)	= $5,000 x (575.4/358.2)	$8,000	$5,333	$7,560
		Subtotal:	$91,500	$61,000	$86,500		Everything	$61,000
		plus visible emissions testing:		$350	$496		Annual	$20,333
		Total:		$61,350	$87,000
Notes:
1. Initial testing costs to be annualized over 15 years at 7% interest.
2. Testing costs have been rounded to the nearest $1,000 (except for opacity) to be consistent with level of rounding in original costs; costs also adjusted based on additional information from EPA.
3. Multiple test costs adjusted by 2/3 in nationwide cost estimates to account for travel, accommodations, methods/sampling trains, etc. common to the tests.
Sources:
1. Memorandum from R. Segall, EPA/EMB, to R. Copland, EPA/SDB. October 14, 1992. Medical Waste Incinerator Study: Emission Measurement and Continuous Monitoring. (II-B-89)
2. E-mail from Jason Dewees, EPA, to Peter Westlin, EPA. August 20, 2008. Monitoring Options for SNCR & Test Cost Questions.
3. E-mail from Jason Dewees, EPA, to Mary Johnson, EPA. August 20, 2008. Re: Monitoring Options for SNCR & Test Cost Questions. Re: Monitoring Options for SNCR & Test Cost Questions.