Burden Calculation Tables

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Overview

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

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Sheet 1: Summary

ICR Summary Information
Hours per Response	52
Number of Respondents	36
Total Estimated Burden Hours	3,730
Total Estimated Costs	$462,000
Annualized Capital O&M	$127,000
Total Annual Responses	72
Form Number	Not Applicable

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Sheet 2: Table 1a

Table 1a: Annual Respondent Burden and Cost for Privately-Owned Incinerators – NSPS for Incinerators (40 CFR Part 60, Subpart E) (Renewal)
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total cost per year ($) b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$157.61
3. Reporting Requirements										Technical	$123.94
A. Familiarize with regulatory requirements c	1	1	1	20	20	1	2	$2,761.48		Clerical	$62.52
B. Required activities
Initial performance test d, e	200	1	200	0	0	0	0	$0
C. Create information on performance test	See 3B
D. Gather existing information	See 3E
E. Write Report
Notification of construction/ reconstruction d	2	1	2	0	0	0	0	$0
Notification of actual startup d	2	1	2	0	0	0	0	$0
Notification of physical and operational changes which may increase emission rates of any regulated pollutants	2	1	2	0	0	0	0	$0
Notification of initial performance test d	2	1	2	0	0	0	0	$0
Report of initial performance test results d	4	1	4	0	0	0	0	$0
Compliance status reports f	4	1	4	0	0	0	0	$0
Subtotal for Reporting Requirements					23			$2,761
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 4E
B. Plan activities	See 4E
C. Implement activities	See 4E
D. Develop record system	N/A
E. Time to enter information
Record of occurrence and duration of startup, shutdown, or malfunction; emissions monitoring system; and initial performance test results	1.5	1	1.5	20	30	1.5	3.0	$4,142.22
Records of daily charging rates and hours of operation g	0.25	350	87.5	20	1,750	87.5	175	$241,629.41
F. Time to train personnel	N/A
G. Time for audits	N/A										Summary
Subtotal for Recordkeeping Requirements					2,047			$245,772			3,730	total labor hours
Total Labor Burden and Costs (rounded) h					2,070			$249,000			$334,000	total labor cost
Total Capital and O&M Cost (rounded) h								$72,100			52	hr/response
GRAND TOTAL (rounded) h								$321,000			$462,000	labor + O&M cost
Assumptions:
a We estimate that an average of 36 existing respondents per year will be subject to the rule, and that no new, modified, or reconstructed facilities will become subject over the three-year period of this ICR. We estimate 20 (55.5 percent) respondents are privately owned and 16 (44.4 percent) are publicly owned.
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.
c We assume that all sources will have to familiarize themselves with regulatory requirements each year.
d We assume this is a one-time-only cost.
e We assume it takes 60 technical hours for pretests/test preparation, 60 technical hours for testing, and 80 technical hours for analysis and report preparation.
f This rule does not require semiannual reporting, just recordkeeping.
g We assume it will take 0.25 hours per day over 350 days per year to record daily charging rates.
h 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 Respondent Burden and Cost for Publicly-Owned Incinerators – NSPS for Incinerators (40 CFR Part 60, Subpart E) (Renewal)
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total cost per year ($) b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$70.56
3. Reporting Requirements										Technical	$52.37
A. Familiarize with regulatory requirements c	1	1	1	16	16	0.8	1.6	$939.71		Clerical	$28.34
B. Required activities
Initial performance test d, e	200	1	200	0	0	0	0	$0
C. Create information on performance test	See 3B
D. Gather existing information	See 3E
E. Write Report
Notification of construction/ reconstruction d	2	1	2	0	0	0	0	$0
Notification of actual startup d	2	1	2	0	0	0	0	$0
Notification of physical and operational changes which may increase emission rates of any regulated pollutants	2	1	2	0	0	0	0	$0
Notification of initial performance test d	2	1	2	0	0	0	0	$0
Report of initial performance test results d	4	1	4	0	0	0	0	$0
Compliance status reports f	4	1	4	0	0	0	0	$0
Subtotal for Reporting Requirements					18			$940
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 4E
B. Plan activities	See 4E
C. Implement activities	See 4E
D. Develop record system	N/A
E. Time to enter information
Record of occurrence and duration of startup, shutdown, or malfunction; emissions monitoring system; and initial performance test results	1.5	1	1.5	16	24	1.2	2.4	$1,409.57
Records of daily charging rates and hours of operation g	0.25	350	87.5	16	1,400	70	140	$82,224.80
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					1,638			$83,634
Total Labor Burden and Costs (rounded) h					1,660			$85,000
Total Capital and O&M Cost (rounded) h								$56,000
GRAND TOTAL (rounded) h								$141,000
Assumptions:
a We estimate that an average of 36 existing respondents per year will be subject to the rule, and that no new, modified, or reconstructed facilities will become subject over the three-year period of this ICR. We estimate 20 (55.5 percent) respondents are privately owned and 16 (44.4 percent) are publicly owned.
b This cost is based on the average hourly labor rate as follows: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.17 + 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), 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 We assume that all sources will have to familiarize themselves with regulatory requirements each year.
d We assume this is a one-time-only cost.
e We assume it takes 60 technical hours for pretests/test preparation, 60 technical hours for testing, and 80 technical hours for analysis and report preparation.
f This rule does not require semiannual reporting, just recordkeeping.
g We assume it will take 0.25 hours per day over 350 days per year to record daily charging rates.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Incinerators (40 CFR Part 60, Subpart E) (Renewal)
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.10)	(H) Total cost per year ($) b
Notification of construction/ reconstruction c, d	2	1	2	0	0	0	0	$0		Labor Rates
Notification of actual startup c, d	2	1	2	0	0	0	0	$0		Management	$70.56
Notification of physical and operational changes which may increase emission rates of any regulated pollutant	2	1	2	0	0	0	0	$0		Technical	$52.37
Compliance status report e	4	1	4	0	0	0	0	$0		Clerical	$28.34
Test results e, f	8	1	8	0	0	0	0	$0
Audit and review facility records g	6	1	6	4	24	1.2	2.4	$1,410
TOTAL (rounded) h					28			$1,410
Assumptions:
a We estimate that an average of 36 existing respondents per year will be subject to the rule, and that no new, modified, or reconstructed facilities will become subject over the three-year period of this ICR. We estimate 21 (58.6 percent) respondents are privately owned and 16 (43.2 percent) are publicly owned.
b This cost is based on the average hourly labor rate as follows: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.17 + 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), 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 We assume there will be no new, modified, or reconstructed facilities constructed over the next three years.
d We assume this is a one-time-only cost.
e This rule does not require semiannual or annual reporting, only recordkeeping.
f We assume it will take eight hours to review test results.
g Assumes EPA will audit records for approximately 10% of facilities.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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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 a	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent b	Number of Respondents with O&M	Total O&M, (E X F) c
Particulate matter	$6,738	0	$0	$3,532	36	$127,165		127,000
a Assume that annual captial/startup costs for the PM CMS are $6,738 (Docket Document Number EPA-HQ-OECA-2006-0709, page 10). Costs have been increased from 2007 to 2021 $ using the CEPCI Equipment Cost Index.
b Assume that annual O&M costs for the PM CMS are $3,532 (Docket Document Number EPA-HQ-OECA-2006-0709, page 10). Costs have been increased from 2018 to 2021 $ using the CEPCI Equipment Cost Index.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: 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
Publicly-Owned
Notification reports	0	0	0	0
Compliance reports	0	0	0	0
Records of startup, shutdown, and malfunction (SSM), emissions monitoring system, and initial performance test results	0	0	20	20
Records of daily charging rates and hours of operation	0	0	20	20
			Total	40
Privately-Owned
Notification reports	0	0	0	0
Compliance reports	0	0	0	0
Records of startup, shutdown, and malfunction (SSM), emissions monitoring system, and initial performance test results	0	0	16	16
Records of daily charging rates and hours of operation	0	0	16	16
			Total	32
			Grand Total	72

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Sheet 7: 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 1	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)
Privately-Owned
1	0	20	0	0	20
2	0	20	0	0	20
3	0	20	0	0	20
Average	0	20	0	0	20
Publicly-Owned
1	0	16	0	0	16
2	0	16	0	0	16
3	0	16	0	0	16
Average	0	16	0	0	16
				Total	36
1 New respondents include sources with constructed, reconstructed and modified affected facilities.