Burden Tables

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Overview

Cover
Inputs
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Responses
Respondents

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Sheet 1: Cover

ATTACHMENT 1

SUPPORTING STATEMENT

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)

TABLES 1, 2, and 3

Annual Respondent Burden and Cost of the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule) – (a) Publicly Owned and (b) Privately Owned; Years 1-3

TABLE 4

Summary of Annual Respondent Burden and Cost of the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)

TABLES 5, 6, and 7

Annual Agency Burden and Cost of the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule) – Years 1-3

TABLE 8

Summary of Annual Agency Burden and Cost of the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)

TABLE 9

Burden Reduction due to e-reporting calculation

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Sheet 2: Inputs

Industry Wages*
May 2022 National Industry-Specific Occupational Employment and Wage Estimates
NAICS 562200 - Waste Treatment and Disposal
Category	Occupation Code	Mean hourly rate ($/hr)	Fringe Benefit Loading Rate	Overhead and Profit Rate	Loaded Rate ($/hr)
Technical	17-2112	49.94	1.5	1.4	104.87
Management	11-9041	78.91	1.5	1.4	165.71
Clerical	43-9061	19.32	1.5	1.4	40.57
https://www.bls.gov/oes/current/naics4_562200.htm
*Labor rates are assumed to be comparable between private and public sector.
EPA Wages
	Hourly Mean Wage	With Fringe & Overhead
(GS- 12, step 1) - Tech.	34.07	$54.51
(GS- 13, step 5) - Mgmt.	45.91	$73.46
(GS-6, step 3) - Cler.	18.44	$29.50
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/23Tables/html/GS_h.aspx
Facilities
	Number of Facilities	Number of Units
Existing	96	177
Proposed or unopened	0	4
Municipality Owned*	0	0
Privately Owned*	96	181
Number of sister units	23

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Sheet 3: Table 1

Table 1: Annual Privately Owned Respondent Burden and Cost Year One – National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)
					$104.87	$165.71	$40.57
Burden item a	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year b	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) c
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements	4	1	4	96	384	19.2	38.4	$45,011
B. Required activities
Initial performance test	N/A
Repeat performance test	N/A
CEMS demonstration	15	1	15	96	1440	72	144	$168,792
Annual performance test	N/A
C. Write report
Notifications (construction/modification, start-up, initial/repeat performance test, CEMS demonstration, CEMS start/stop, exemptions)	5	1	5	96	480	24	48	$56,264
Performance test reports (initial/repeat and annual compliance)	0.5	1	0.5	96	48	2.4	4.8	$5,626
CEMS demonstration report	N/A
Familiarize with CEDRI	4	1	4	96	384	19.2	38.4	$45,011
Electronic data submittal	0.5	3	1.5	96	144	7.2	14.4	$16,879
Subtotal for Reporting Requirements	29	8			3,312			$337,584
4. Recordkeeping requirements
Record startups, shutdowns, and malfunctions	N/A
Records of all emission rates, computations, tests	0	0	0	96	0	0	0	$0.00
Records of employee review of operations manual	4	3	12	96	1152	57.6	115.2	$135,034
Records of operating parameters for control devices	0	0	0	96	0	0	0	$0.00
Subtotal for Recordkeeping Requirements	4	3			1,325			$135,034
TOTAL LABOR BURDEN AND COST (rounded)	33	11			4,637			$472,600
TOTAL CAPITAL AND O&M COST (rounded)
GRAND TOTAL (rounded)								$472,600
Assumptions:
a These burden estimates are intended to be incremental. Requirements already established for existing HWCs are indicated as N/A in column (A) and already accounted for in the current HWC rule's ICR.
b There are 173 HWC units at 94 facilities, all of which are privately owned. We have assumed that there will be 1 new respondent each year over the three-year period of this ICR.
c Refer to Inputs for sources for wage data

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Sheet 4: Table 2

Table 2: Annual Privately Owned Respondent Burden and Cost Year Two – National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)
					$104.87	$165.71	$40.57
Burden item a	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year b	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) c
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements	N/A
B. Required activities
Initial performance test	N/A
Repeat performance test	N/A
CEMS demonstration	N/A
Annual performance test	N/A
C. Write report
Notifications (construction/modification, start-up, initial/repeat performance test, CEMS demonstration, CEMS start/stop, exemptions)	5	1	5	97	485	24.25	48.5	$56,850
Performance test reports (initial/repeat and annual compliance)	0.5	1	0.5	1	0.5	0.025	0.05	$59
CEMS demonstration report
Familiarize with CEDRI	1	1	1	97	97	4.85	9.7	$11,370.02
Electronic data submittal	0.5	3	1.5	97	145.5	7.275	14.55	$17,055
Subtotal for Reporting Requirements	7	6			837			$85,334
4. Recordkeeping requirements
Record startups, shutdowns, and malfunctions	N/A
Records of all emission rates, computations, tests	0	0	0	97	0	0	0	$0.00
Records of employee review of operations manual	2	3	6	97	582	29.1	58.2	$68,220
Records of operating parameters for control devices	0	0	0	97	0	0	0	$0.00
Subtotal for Recordkeeping Requirements	2	3			669			$68,220
TOTAL LABOR BURDEN AND COST (rounded)	9	9			1,507			$153,600
TOTAL CAPITAL AND O&M COST (rounded)
GRAND TOTAL (rounded)								$153,600
Assumptions:
a These burden estimates are intended to be incremental. Requirements already established for existing HWCs are indicated as N/A in column (A) and already accounted for in the current HWC rule's ICR.
b There are 173 HWC units at 94 facilities, all of which are privately owned. We have assumed that there will be 1 new respondent each year over the three-year period of this ICR.
c Refer to Inputs for sources for wage data

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Sheet 5: Table 3

Table 3: Annual Privately Owned Respondent Burden and Cost Year Three – National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)
					$104.87	$165.71	$40.57
Burden item a	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year b	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) c
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements	N/A
B. Required activities
Initial performance test	N/A
Repeat performance test	N/A
CEMS demonstration	N/A
Annual performance test	N/A
C. Write report
Notifications (construction/modification, start-up, initial/repeat performance test, CEMS demonstration, CEMS start/stop, exemptions)	5	1	5	98	490	24.5	49	$57,436
Performance test reports (initial/repeat and annual compliance)	0.5	1	0.5	1	0.5	0.025	0.05	$59
CEMS demonstration report
Familiarize with CEDRI	1	1	1	98	98	4.9	9.8	$11,487.24
Electronic data submittal	0.5	3	1.5	98	147	7.35	14.7	$17,231
Subtotal for Reporting Requirements	7	6			846			$86,213
4. Recordkeeping requirements
Record startups, shutdowns, and malfunctions	N/A
Records of all emission rates, computations, tests	0	0	0	98	0	0	0	$0.00
Records of employee review of operations manual	2	3	6	98	588	29.4	58.8	$68,923
Records of operating parameters for control devices	0	0	0	98	0	0	0	$0.00
Subtotal for Recordkeeping Requirements	2	3			676			$68,923
TOTAL LABOR BURDEN AND COST (rounded)	9	9			1,522			$155,100
TOTAL CAPITAL AND O&M COST (rounded)
GRAND TOTAL (rounded)								$155,100
Assumptions:
a These burden estimates are intended to be incremental. Requirements already established for existing HWCs are indicated as N/A in column (A) and already accounted for in the current HWC rule's ICR.
b There are 173 HWC units at 94 facilities, all of which are privately owned. We have assumed that there will be 1 new respondent each year over the three-year period of this ICR.
c Refer to Inputs for sources for wage data

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Sheet 6: Table 4

Table 4 - Summary of Annual Respondent Burden and Cost - National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)
Year	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs (includes annual burden reduction)
1	4,637	$472,618	$0	$468,728
2	1,507	$153,554	$0	$149,664
3	1,522	$155,136	$0	$151,246
Annual Burden Reduction due to e-reporting	$3,890
Total (rounded)	7,670	$781,000	$0	$770,000
Average (rounded)	2,560	$260,000	$0	$257,000

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Sheet 7: Table 5

Table 5: Average Annual EPA Burden and Cost Year One - National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)
					$54.51	$73.46	$29.50
Burden item a	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year b	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) c
Applications	N/A
Notification of construction/ modification	N/A
Notification of actual startup	N/A
New excessive exceedance reports received due to SSM change	4	1	4	96	384	19.2	38.4	$23,476
Notification of initial/repeat performance test	N/A
Notification of CEMS update	2	1	2	96	192	9.6	19.2	$11,738
Initial performance test	N/A
Repeat performance test	N/A
Semiannual report	N/A
TOTAL (rounded)					662			$35,210
Assumptions:
a These burden estimates are intended to be incremental. Requirements already established for existing HWCs are indicated as N/A in column (A) and already accounted for in the current HWC rule's ICR.
b There are 173 HWC units at 94 facilities, all of which are privately owned. We have assumed that there will be 1 new respondent each year over the three-year period of this ICR.
c Refer to Inputs for sources for wage data

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Sheet 8: Table 6

Table 6: Average Annual EPA Burden and Cost Year Two - National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)
					$54.51	$73.46	$29.50
Burden item a	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year b	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) c
Applications	N/A
Notification of construction/ modification	N/A
Notification of actual startup	N/A
New excessive exceedance reports received due to SSM change	4	1	4	97	388	19.4	38.8	$23,720
Notification of initial/repeat performance test	N/A
Notification of CEMS update	2	0	0	0	0	0	0	$0.00
Initial performance test	N/A
Repeat performance test	N/A
Semiannual report	N/A
TOTAL (rounded) d					446			$23,720
Assumptions:
a These burden estimates are intended to be incremental. Requirements already established for existing HWCs are indicated as N/A in column (A) and already accounted for in the current HWC rule's ICR.
b There are 173 HWC units at 94 facilities, all of which are privately owned. We have assumed that there will be 1 new respondent each year over the three-year period of this ICR.
c Refer to Inputs for sources for wage data

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Sheet 9: Table 7

Table 7: Average Annual EPA Burden and Cost Year Three - National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)
					$54.51	$73.46	$29.50
Burden item a	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year b	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) c
Applications	N/A
Notification of construction/ modification	N/A
Notification of actual startup	N/A
New excessive exceedance reports received due to SSM change	4	1	4	98	392	19.6	39.2	$23,965
Notification of initial/repeat performance test	N/A
Notification of CEMS update	2	0	0	0	0	0	0	$0.00
Initial performance test	N/A
Repeat performance test	N/A
Semiannual report	N/A
TOTAL (rounded) d					451			$23,960
Assumptions:
a These burden estimates are intended to be incremental. Requirements already established for existing HWCs are indicated as N/A in column (A) and already accounted for in the current HWC rule's ICR.
b There are 173 HWC units at 94 facilities, all of which are privately owned. We have assumed that there will be 1 new respondent each year over the three-year period of this ICR.
c Refer to Inputs for sources for wage data

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Sheet 10: Table 8

Table 8: Summary of Annual Agency Burden and Cost of the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Removal of Malfunction Exemptions and e-Reporting (40 CFR Part 63, Subpart EEE) (Proposed Rule)
Year	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	662	$35,210	$0	$35,210
2	446	$23,720	$0	$23,720
3	451	$23,960	$0	$23,960
Total (Rounded)	1,559	$82,890	$0	$82,890
Average (Rounded)	520	$27,630	$0	$27,630

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Sheet 11: Table 9

Total Other Direct Costs to respondents: Burden Reduction due to e-reporting
	Activity	Number of Respondents	Pages per report	Total Printing Costs	Total Shipping Costs	Time between submissions (years)	Total	Annual costs	Notes
	Comprehensive Performance Test	154	100	$1,540.00	$1,370.60	5	$2,910.00	$582.00	The number of respondents is the difference between the number of units and number of sister units
	Confirmatory Performance Test	154	50	$770.00	$1,370.60	5	$2,140.00	$428.00	Refer to above comment
	Excess Emission-CMS report	97	20	$194.00	$863.30	0.5	$1,060.00	$2,120.00	Assume these are grouped and sent on a per company and not a per unit basis.
	Notifications and infrequent reports	97	5	$40.50	$720.90	1	$760.00	$760.00	Assume these are grouped and sent on a per company and not a per unit basis.
	Cost of paper	$0.10	per page	From CrF supporting statement
	Shipping costs	$8.90	per package	From CrF supporting statement
	Time between tests	2.5	years
	Total	$3,890.00

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Sheet 12: Responses

Summary of 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
Electronic data submittal	97	3	0	291
			Subtotal (rounded)	291

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Sheet 13: 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	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	96	0	0	96
2	1	96	0	0	97
3	1	97	0	0	98
Average	1	96	0	0	97