Burden Tables

2164t09.xlsx

Emission Guidelines for Existing Other Solid Waste Incineration (OSWI) Units (40 CFR part 60, subpart FFFF) (Final Rule)

Burden Tables

OMB: 2060-0562

Document [xlsx]
Download: xlsx | pdf

Overview

ROCIS Summary
YR1
YR2
YR3
Respondent Summary
EPA_Yr1
EPA_Yr2
EPA_Yr3
EPA_Summary
O&M
Respondents
Responses


Sheet 1: ROCIS Summary

ICR Summary Information
Hours Per Response 31
Number of Respondents 54
Total Estimated Burden Hours 2,390
Total Estimated Costs $424,000
Annualized Capital O&M $87,000
Form Number 5900-560 and 5900-561






Burden Change Table

Inventory as of this Action Previously Approved
Respondents 54 155
Responses 110 407
Time Burden (Hours) 2,390 91,600
Cost Burden (Dollars) 87,000 630,000

Sheet 2: YR1

Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule) - Year 1 Burden


















145.99 177.98
74.28 Updated to 2024 labor rates






Person-hours per year



Burden item (A)
Person hours per occurrence
(B)
Non-Labor Costs Per Occurrence
(C)
No. of occurrences per respondent per year
(D)
Person hours per respondent per year
(C=AxB)
(E)
Respondents per yeara
(F)
Technical person- hours per year
(E=CxD)
(G)
Management person hours per year
(Ex0.05)
(H)
Clerical person hours per year
(Ex0.1)
(I)
Total Hours per Year
(F + G + H)
(J)
Total Labor Cost per yearb
(K)
Total Non-Labor Costs Per Year
(B x C x E)
(L)
Total Number of Responses per Year
(C X E)
1. Applications N/A










2. Survey and Studies N/A










3. Reporting requirements











A. Familiarize with rule requirementsc











1) Initial review and familiarization with final revisions (new sources) 18 $0 1 18 25 450 22.5 45 517.5 $73,043 $0 0
2) Familiarize with rule (existing burden) 4 $0 1 4 29 116 5.8 11.6 133.4 $18,829 $0 0
B. Required activities











1) Initial performance test and reports











a) Initial performance tests (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c 24 $76,667 1 24 0 0 0 0 0 $0 $0 0
b) Repeat of initial performance tests c,d 24 $15,333 1 24 0 0 0 0 0 $0 $0 0
c) Initial performance tests - Air Curtain Incinerators (opacity) c 3 $3,000 1 3 0 0 0 0 0 $0 $0 0
d) Repeat of initial performance tests - Air Curtain Incinerators c,d 3 $600 1 3 0 0 0 0 0 $0 $0 0
2) CEMS demonstration (CO, O2)









$0 0
a) Initial demonstration e 229 $395,000 1 229 0 0 0 0 0 $0 $0 0
b) Annual Costs See 3.B.5








$0 0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)f 24 $76,667 1 24 0 0 0 0 0 $0 $0 0
4) Annual performance tests and test reports - Air Curtain Incinerators (opacity)f 3 $3,000 1 3 29 87 4.35 8.7 100.05 $14,122 $87,000 0
5) Quarterly Appendix F audits of CEMS (CO)











a) RATA audit (one per year) e,f 16 $0 1 16 0 0 0 0 0 $0 $0 0
b) RAA audit (three per year) e,f 16 $0 3 48 0 0 0 0 0 $0 $0 0
c) Daily calibration and operation e,f 0.25 $73,700 250 62.5 0 0 0 0 0 $0 $0 0
6) Waste management plan c 20 $0 1 20 25 500 25 50 575 $81,159 $0 25
7) Notification of intent to use substitute
means of compliance c
4 $0 1 4 0 0 0 0 0 $0 $0 0
C. Create information See 3B










D. Gather existing information See 3E










E. Write Report











1) Preconstruction reportc 8 $0 1 8 0 0 0 0 0 $0 $0 0
2) Startup notificationc 2 $0 1 2 0 0 0 0 0 $0 $0 0
3) Initial test report c











a) Initial test report (non-ACI) c 40 $0 1 40 0 0 0 0 0 $0 $0 0
b) Initial test report (ACI) c 10 $0 1 10 0 0 0 0 0 $0 $0 0
4) Annual compliance reports











a) Annual compliance report (non-ACI, for units using stack tests) f 28 $0 1 28 25 700 35 70 805 $113,622 $0 25
b) Annual compliance report (non-ACI, for units using the SMOC or AWC) f 28 $0 1 28 0 0 0 0 0 $0 $0 0
c) Annual compliance report (ACI) g 10 $0 1 10 29 290 14.5 29 333.5 $47,072 $0 29
5) Semiannual deviation reports i 24 $0 2 48 3 144 7.2 14.4 165.6 $23,374 $0 6
6) Notification of final compliance 1 $0 1 1 25 25 1.25 2.5 28.75 $4,058 $0 25
Subtotal for Reporting Requirements 2,312 116 231 2,659 $375,277 $87,000 110
4. Recordkeeping requirements











A. Familiarize with rule requirementsc See 3A










B. Plan activities See 3B










C. Implement activities See 3B










D. Develop record system N/A










E. Record information











1) Records of malfunctions h 1.5 $0 52 78 0 0 0 0 0 $0 $0 0
2) Records of emission rate computations, all emission exceedances and periods when there is no data i,k 1.5 $0 52 78 0 0 0 0 0 $0 $0 0
3) Records of employee review of operations manual 4 $0 1 4 25 100 5 10 115 $16,232 $0 0
4) Record of control devices operating parameters k,f 1.5 $2,500 52 78 0 0 0 0 0 $0 $0 0
5) Initial Records of waste burned and information on representative test (weekly) 0.5 $0 52 26 0 0 0 0 0 $0 $0 0
6) Copy of representative performance test and documention 4 $0 1 4 0 0 0 0 0 $0 $0 0
7) Records of quarterly waste burned and operating information 1 $0 4 4 25 100 5 10 115 $16,232 $0 0
8) Quarterly records of waste characterization, including % of each waste category 1 $0 4 4 25 100 5 10 115 $16,232 $0 0
9) Records of deviations 0.5 $0 4 2 25 50 2.5 5 57.5 $8,116 $0 0
F. Perform Audits N/A










Subtotal for Recordkeeping Requirements 350 18 35 403 $56,811 $0 0
TOTAL (rounded) j 2,660 133 266 3,060 $432,000 $87,000 110













Assumptions:











a EPA estimates that there are 54 existing facilities subject to 40 CFR 60, Subpart FFFF. This includes 29 ACI units and 25 VSMWC with capacity less than or equal to 10 TPD.

b This ICR uses the following labor rates: $145.99 (technical), $177.98 (managerial), and $74.28 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2024, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

c This estimate includes additional burden for a one-time only cost for new respondents from revisions to the final rule. Note that the waste management plan is submitted as part of the preconstruction report.

d We have assumed that no respondents would be required to repeat a performance test.











e We have assumed that none of the existing units subject to FFFF have CEMS, all units are less than 10 TPD and have already conducted initial testing; therefore no facilities will submit an initial demonstration report.











f We have assumed that ACI units will conduct annual testing; no other respondents are expected to conduct annual performance tests or record daily calibration and operation or control devices operating parameters. Units using the alternative waste characterization methods for continuous compliance submit annual reports which consist of a statement that there were no deviations from the percentage of waste burned in each category and the OSWI unit has been operated within the established operating parameter limits. We have assumed the 25 SRI units have already conducted initial testing in the first year and will use the alternative waste characterization option in subsequent years.

g The requirement to submit an annual compliance report is not new, therefore there are no incremental costs associated with this requirement.

h We have assumed that each respondent will record information 52 times per year.











i We have assumed that 10 percent of the respondents will report exceedances.











j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.











k We have assumed that each respondent will record information 52 times per year. The non-labor costs shown for control device operating parameters are total cost for the entire year, not the cost per occurrence.












Sheet 3: YR2

Table 2: Annual Respondent Burden and Cost – Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule) - Year 2 Burden




















145.99 177.98
74.28 Updated to 2024 labor rates








Person-hours per year





Burden item (A)
Person hours per occurrence
(B)
Non-Labor Costs Per Occurrence
(C)
No. of occurrences per respondent per year
(D)
Person hours per respondent per year
(C=AxB)
(E)
Respondents per yeara
(F)
Technical person- hours per year
(E=CxD)
(G)
Management person hours per year
(Ex0.05)
(H)
Clerical person hours per year
(Ex0.1)
(I)
Total Hours per Year
(F + G + H)
(J)
Total Labor Cost per yearb
(K)
Total Non-Labor Costs Per Year
(B x C x E)
(L)
Total Number of Responses per Year
(C X E)


1. Applications N/A












2. Survey and Studies N/A












3. Reporting requirements













A. Familiarize with rule requirementsc













1) Initial review and familiarization with final revisions (new sources) 18 $0 1 18 0 0 0 0 0 $0 $0 0

2) Familiarize with rule (existing burden) 4 $0 1 4 54 216 10.8 21.6 248.4 $35,060 $0 0

B. Required activities













1) Initial performance test and reports













a) Initial performance tests (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c 24 $76,667 1 24 0 0 0 0 0 $0 $0 0

b) Repeat of initial performance tests c,d 24 $15,333 1 24 0 0 0 0 0 $0 $0 0

c) Initial performance tests - Air Curtain Incinerators (opacity) c 3 $3,000 1 3 0 0 0 0 0 $0 $0 0

d) Repeat of initial performance tests - Air Curtain Incinerators c,d 3 $600 1 3 0 0 0 0 0 $0 $0 0

2) CEMS demonstration (CO, O2)









$0 0

a) Initial demonstration e 229 $395,000 1 229 0 0 0 0 0 $0 $0 0

b) Annual Costs See 3.B.5








$0 0

3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)f 24 $76,667 1 24 0 0 0 0 0 $0 $0 0

4) Annual performance tests and test reports - Air Curtain Incinerators (opacity)f 3 $3,000 1 3 29 87 4.35 8.7 100.05 $14,122 $87,000 0

5) Quarterly Appendix F audits of CEMS (CO)













a) RATA audit (one per year) e,f 16 $0 1 16 0 0 0 0 0 $0 $0 0

b) RAA audit (three per year) e,f 16 $0 3 48 0 0 0 0 0 $0 $0 0

c) Daily calibration and operation e,f 0.25 $73,700 250 62.5 0 0 0 0 0 $0 $0 0

6) Waste management plan c 20 $0 1 20 0 0 0 0 0 $0 $0 0

7) Notification of intent to use substitute
means of compliance c
4 $0 1 4 0 0 0 0 0 $0 $0 0

C. Create information See 3B












D. Gather existing information See 3E












E. Write Report













1) Preconstruction reportc 8 $0 1 8 0 0 0 0 0 $0 $0 0

2) Startup notificationc 2 $0 1 2 0 0 0 0 0 $0 $0 0

3) Initial test report c













a) Initial test report (non-ACI) c 40 $0 1 40 0 0 0 0 0 $0 $0 0

b) Initial test report (ACI) c 10 $0 1 10 0 0 0 0 0 $0 $0 0

4) Annual compliance reports













a) Annual compliance report (non-ACI, for units using stack tests) f 28 $0 1 28 0 0 0 0 0 $0 $0 0

b) Annual compliance report (non-ACI, for units using the SMOC or AWC) f 28 $0 1 28 25 700 35 70 805 $113,622 $0 25

c) Annual compliance report (ACI) g 10 $0 1 10 29 290 14.5 29 333.5 $47,072 $0 29

5) Semiannual deviation reports i 24 $0 2 48 3 144 7.2 14.4 165.6 $23,374 $0 6

6) Notification of final compliance 1 $0 1 1 0 0 0 0 0 $0 $0 0

Subtotal for Reporting Requirements 1,437 72 144 1,653 $233,250 $87,000 60

4. Recordkeeping requirements













A. Familiarize with rule requirementsc See 3A












B. Plan activities See 3B












C. Implement activities See 3B












D. Develop record system N/A












E. Record information













1) Records of malfunctions h 1.5 $0 52 78 0 0 0 0 0 $0 $0 0

2) Records of emission rate computations, all emission exceedances and periods when there is no data i,k 1.5 $0 52 78 0 0 0 0 0 $0 $0 0

3) Records of employee review of operations manual 4 $0 1 4 25 100 5 10 115 $16,232 $0 0

4) Record of control devices operating parameters k,f 1.5 $2,500 52 78 0 0 0 0 0 $0 $0 0

5) Initial Records of waste burned and information on representative test (weekly) 0.5 $0 52 26 0 0 0 0 0 $0 $0 0

6) Copy of representative performance test and documention 4 $0 1 4 0 0 0 0 0 $0 $0 0

7) Records of quarterly waste burned and operating information 1 $0 4 4 25 100 5 10 115 $16,232 $0 0 287.5 $40,579
8) Quarterly records of waste characterization, including % of each waste category 1 $0 4 4 25 100 5 10 115 $16,232 $0 0

9) Records of deviations 0.5 $0 4 2 25 50 2.5 5 57.5 $8,116 $0 0

F. Perform Audits N/A












Subtotal for Recordkeeping Requirements 350 18 35 403 $56,811 $0 0

TOTAL (rounded)h 1,790 89 179 2,060 $290,000 $87,000 120































Assumptions:













a EPA estimates that there are 54 existing facilities subject to 40 CFR 60, Subpart FFFF. This includes 29 ACI units and 25 VSMWC with capacity less than or equal to 10 TPD.



b This ICR uses the following labor rates: $145.99 (technical), $177.98 (managerial), and $74.28 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2024, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.



c This estimate includes additional burden for a one-time only cost for new respondents from revisions to the final rule. Note that the waste management plan is submitted as part of the preconstruction report.



d We have assumed that no respondents would be required to repeat a performance test.













e We have assumed that none of the existing units subject to FFFF have CEMS, all units are less than 10 TPD and have already conducted initial testing; therefore no facilities will submit an initial demonstration report.













f We have assumed that ACI units will conduct annual testing; no other respondents are expected to conduct annual performance tests or record daily calibration and operation or control devices operating parameters. Units using the alternative waste characterization methods for continuous compliance submit annual reports which consist of a statement that there were no deviations from the percentage of waste burned in each category and the OSWI unit has been operated within the established operating parameter limits. We have assumed the 25 SRI units have already conducted initial testing in the first year and will use the alternative waste characterization option in subsequent years.



g The requirement to submit an annual compliance report is not new, therefore there are no incremental costs associated with this requirement.



h We have assumed that each respondent will record information 52 times per year.













i We have assumed that 10 percent of the respondents will report exceedances.













j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.













k We have assumed that each respondent will record information 52 times per year. The non-labor costs shown for control device operating parameters are total cost for the entire year, not the cost per occurrence.














Sheet 4: YR3

Table 3: Annual Respondent Burden and Cost – Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule) - Year 3 Burden


















145.99 177.98
74.28 Updated to 2024 labor rates






Person-hours per year



Burden item (A)
Person hours per occurrence
(B)
Non-Labor Costs Per Occurrence
(C)
No. of occurrences per respondent per year
(D)
Person hours per respondent per year
(C=AxB)
(E)
Respondents per yeara
(F)
Technical person- hours per year
(E=CxD)
(G)
Management person hours per year
(Ex0.05)
(H)
Clerical person hours per year
(Ex0.1)
(I)
Total Hours per Year
(F + G + H)
(J)
Total Labor Cost per yearb
(K)
Total Non-Labor Costs Per Year
(B x C x E)
(L)
Total Number of Responses per Year
(C X E)
1. Applications N/A










2. Survey and Studies N/A










3. Reporting requirements











A. Familiarize with rule requirementsc











1) Initial review and familiarization with final revisions (new sources) 18 $0 1 18 0 0 0 0 0 $0 $0 0
2) Familiarize with rule (existing burden) 4 $0 1 4 54 216 10.8 21.6 248.4 $35,060 $0 0
B. Required activities











1) Initial performance test and reports











a) Initial performance tests (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c 24 $76,667 1 24 0 0 0 0 0 $0 $0 0
b) Repeat of initial performance tests c,d 24 $15,333 1 24 0 0 0 0 0 $0 $0 0
c) Initial performance tests - Air Curtain Incinerators (opacity) c 3 $3,000 1 3 0 0 0 0 0 $0 $0 0
d) Repeat of initial performance tests - Air Curtain Incinerators c,d 3 $600 1 3 0 0 0 0 0 $0 $0 0
2) CEMS demonstration (CO, O2)









$0 0
a) Initial demonstration e 229 $395,000 1 229 0 0 0 0 0 $0 $0 0
b) Annual Costs See 3.B.5








$0 0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)f 24 $76,667 1 24 0 0 0 0 0 $0 $0 0
4) Annual performance tests and test reports - Air Curtain Incinerators (opacity)f 3 $3,000 1 3 29 87 4.35 8.7 100.05 $14,122 $87,000 0
5) Quarterly Appendix F audits of CEMS (CO)











a) RATA audit (one per year) e,f 16 $0 1 16 0 0 0 0 0 $0 $0 0
b) RAA audit (three per year) e,f 16 $0 3 48 0 0 0 0 0 $0 $0 0
c) Daily calibration and operation e,f 0.25 $73,700 250 62.5 0 0 0 0 0 $0 $0 0
6) Waste management plan c 20 $0 1 20 0 0 0 0 0 $0 $0 0
7) Notification of intent to use substitute
means of compliance c
4 $0 1 4 0 0 0 0 0 $0 $0 0
C. Create information See 3B










D. Gather existing information See 3E










E. Write Report











1) Preconstruction reportc 8 $0 1 8 0 0 0 0 0 $0 $0 0
2) Startup notificationc 2 $0 1 2 0 0 0 0 0 $0 $0 0
3) Initial test report c











a) Initial test report (non-ACI) c 40 $0 1 40 0 0 0 0 0 $0 $0 0
b) Initial test report (ACI) c 10 $0 1 10 0 0 0 0 0 $0 $0 0
4) Annual compliance reports











a) Annual compliance report (non-ACI, for units using stack tests) f 28 $0 1 28 0 0 0 0 0 $0 $0 0
b) Annual compliance report (non-ACI, for units using the SMOC or AWC) f 28 $0 1 28 25 700 35 70 805 $113,622 $0 25
c) Annual compliance report (ACI) g 10 $0 1 10 29 290 14.5 29 333.5 $47,072 $0 29
5) Semiannual deviation reports i 24 $0 2 48 3 144 7.2 14.4 165.6 $23,374 $0 6
6) Notification of final compliance 1 $0 1 1 0 0 0 0 0 $0 $0 0
Subtotal for Reporting Requirements 1,437 72 144 1,653 $233,250 $87,000 60
4. Recordkeeping requirements











A. Familiarize with rule requirementsc See 3A










B. Plan activities See 3B










C. Implement activities See 3B










D. Develop record system N/A










E. Record information











1) Records of malfunctions h 1.5 $0 52 78 0 0 0 0 0 $0 $0 0
2) Records of emission rate computations, all emission exceedances and periods when there is no data i,k 1.5 $0 52 78 0 0 0 0 0 $0 $0 0
3) Records of employee review of operations manual 4 $0 1 4 25 100 5 10 115 $16,232 $0 0
4) Record of control devices operating parameters k,f 1.5 $2,500 52 78 0 0 0 0 0 $0 $0 0
5) Initial Records of waste burned and information on representative test (weekly) 0.5 $0 52 26 0 0 0 0 0 $0 $0 0
6) Copy of representative performance test and documention 4 $0 1 4 0 0 0 0 0 $0 $0 0
7) Records of quarterly waste burned and operating information 1 $0 4 4 25 100 5 10 115 $16,232 $0 0
8) Quarterly records of waste characterization, including % of each waste category 1 $0 4 4 25 100 5 10 115 $16,232 $0 0
9) Records of deviations 0.5 $0 4 2 25 50 2.5 5 57.5 $8,116 $0 0
F. Perform Audits N/A










Subtotal for Recordkeeping Requirements 350 18 35 403 $56,811 $0 0
TOTAL (rounded)h 1,790 89 179 2,060 $290,000 $87,000 120













Assumptions:











a EPA estimates that there are 54 existing facilities subject to 40 CFR 60, Subpart FFFF. This includes 29 ACI units and 25 VSMWC with capacity less than or equal to 10 TPD.

b This ICR uses the following labor rates: $145.99 (technical), $177.98 (managerial), and $74.28 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2024, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

c This estimate includes additional burden for a one-time only cost for new respondents from revisions to the final rule. Note that the waste management plan is submitted as part of the preconstruction report.

d We have assumed that no respondents would be required to repeat a performance test.











e We have assumed that none of the existing units subject to FFFF have CEMS, all units are less than 10 TPD and have already conducted initial testing; therefore no facilities will submit an initial demonstration report.











f We have assumed that ACI units will conduct annual testing; no other respondents are expected to conduct annual performance tests or record daily calibration and operation or control devices operating parameters. Units using the alternative waste characterization methods for continuous compliance submit annual reports which consist of a statement that there were no deviations from the percentage of waste burned in each category and the OSWI unit has been operated within the established operating parameter limits. We have assumed the 25 SRI units have already conducted initial testing in the first year and will use the alternative waste characterization option in subsequent years.

g The requirement to submit an annual compliance report is not new, therefore there are no incremental costs associated with this requirement.

h We have assumed that each respondent will record information 52 times per year.











i We have assumed that 10 percent of the respondents will report exceedances.











j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.











k We have assumed that each respondent will record information 52 times per year. The non-labor costs shown for control device operating parameters are total cost for the entire year, not the cost per occurrence.












Sheet 5: Respondent Summary

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements - Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule)










Year Technical Hours Clerical Hours Management Hours Total Labor Hours Labor Costs Non-Labor (Capital/Startup and O&M) Costs Total Costs


1 2,660 266 133 3,059 $432,000 $87,000 $519,000


2 1,790 179 89 2,058 $290,000 $87,000 $377,000


3 1,790 179 89 2,058 $290,000 $87,000 $377,000


Total 6,240 624 312 7,175 $1,012,000 $261,000 $1,273,000


Average 2,080 208 104 2,390 $337,000 $87,000 $424,000













Year Number of Respondents Number of Responses Reporting Hours Recordkeeping Hours Total Hours Hours per Response Hours Per Respondent


1 54 110 2,659 403 3,061 28 57


2 54 60 1,653 403 2,055 34 38


3 54 60 1,653 403 2,055 34 38


Total 54 230 5,964 1,208 7,171 31 133


Average 54 77 1,988 403 2,390 31 44























Table 5 - Summary of Incremental Respondent Burden and Cost of Recordkeeping and Reporting Requirements From Final Rule- Emission Guidelines for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule)










Year Technical Hours Clerical Hours Management Hours Total Labor Hours Labor Costs Non-Labor (Capital/Startup and O&M) Costs Total Costs


1 2,169 217 108 2,494 $352,066 $0 $352,066


2 1,294 129 65 1,488 $210,038 $0 $210,038


3 1,294 129 65 1,488 $210,038 $0 $210,038


Total 4,757 476 238 5,471 $772,142 $0 $772,142


Average 1,586 159 79 1,824 $257,000 $0 $257,000













Year Number of Respondents Number of Responses Reporting Hours Recordkeeping Hours Total Hours Hours per Response Hours Per Respondent


1 25 81 2,092 403 2,494 31 100


2 25 31 1,086 403 1,488 48 60


3 25 31 1,086 403 1,488 48 60


Total 25 143 4,263 1,208 5,471 38 219


Average 25 48 1,421 403 1,824 38 73


Sheet 6: EPA_Yr1

Table 6: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule) - Year 1 Burden













57.07 76.91 30.88
Updated to 2024 dollars
Activity (A) (B) (C) (D) (E) (F) (G) (H)
EPA person- hours per occurrence No. of occurrences per plant per year EPA person- hours per plant per year (C=AxB) Plants per year a Technical person- hours per year (E=CxD) Management person-hours per year (Ex0.05) Clerical person-hours per year (Ex0.1) Cost, $ b
1. Applications N/A







2. Familiarization with rule requirements N/A







3. Required activities








A. Create information N/A







B. Gather information See 3A







C. Report reviews








1) Review Notifications








a) Preconstruction report 1 1 1 0 0 0 0 $0
b) Startup notification 0.5 1 0.5 0 0 0 0 $0
c) Notification of intent to use substitute means of compliance 0.5 1 0.5 0 0 0 0 $0
d) Notification of final compliance c 1.5 1 1.5 25 37.5 1.875 3.75 $2,400
2) Review initial compliance test report








a) Initial test report (non-ACI) c 40 1 40 0 0 0 0 $0
b) Initial test report (ACI) c 10 1 10 0 0 0 0 $0
3) Review annual compliance report








a) Annual compliance report (non-ACI, for units using stack tests) 40 1 40 25 1000 50 100 $64,004
b) Annual compliance report (non-ACI, for units using the SMOC) 10 1 10 0 0 0 0 $0
c) Annual compliance report (ACI) 10 1 10 29 290 14.5 29 $18,561
4) Review semiannual deviation reports 16 2 32 3 96 4.8 9.6 $6,144
5) Review waste management plan c 16 1 16 25 400 20 40 $25,601
TOTAL ANNUAL BURDEN AND COST (rounded)d



1,824 91 182 $117,000










Assumptions:








a EPA estimates that there are no existing facilities subject to 40 CFR 60, Subpart FFFF.
b This ICR uses the following labor rates: $57.07 (technical), $76.91 (managerial), and $30.88 (clerical). These rates are from the Office of Personnel Management (OPM), 2024 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 have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.









Sheet 7: EPA_Yr2

Table 7: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule) - Year 2 Burden













57.07 76.91 30.88
Updated to 2024 dollars
Activity (A) (B) (C) (D) (E) (F) (G) (H)
EPA person- hours per occurrence No. of occurrences per plant per year EPA person- hours per plant per year (C=AxB) Plants per year a Technical person- hours per year (E=CxD) Management person-hours per year (Ex0.05) Clerical person-hours per year (Ex0.1) Cost, $ b
1. Applications N/A







2. Familiarization with rule requirements N/A







3. Required activities








A. Create information N/A







B. Gather information See 3A







C. Report reviews








1) Review Notifications








a) Preconstruction report 1 1 1 0 0 0 0 $0
b) Startup notification 0.5 1 0.5 0 0 0 0 $0
c) Notification of intent to use substitute means of compliance 0.5 1 0.5 0 0 0 0 $0
d) Notification of final compliance c 1.5 1 1.5 0 0 0 0 $0
2) Review initial compliance test report








a) Initial test report (non-ACI) c 40 1 40 0 0 0 0 $0
b) Initial test report (ACI) c 10 1 10 0 0 0 0 $0
3) Review annual compliance report








a) Annual compliance report (non-ACI, for units using stack tests) 40 1 40 0 0 0 0 $0
b) Annual compliance report (non-ACI, for units using the SMOC) 10 1 10 25 250 12.5 25 $16,001
c) Annual compliance report (ACI) 10 1 10 29 290 14.5 29 $18,561
4) Review semiannual deviation reports 16 2 32 3 96 4.8 9.6 $6,144
5) Review waste management plan c 16 1 16 0 0 0 0 $0
TOTAL ANNUAL BURDEN AND COST (rounded)d



636 32 64 $41,000










Assumptions:








a EPA estimates that there are no existing facilities subject to 40 CFR 60, Subpart FFFF.
b This ICR uses the following labor rates: $57.07 (technical), $76.91 (managerial), and $30.88 (clerical). These rates are from the Office of Personnel Management (OPM), 2024 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 have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.









Sheet 8: EPA_Yr3

Table 8: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule) - Year 3 Burden













57.07 76.91 30.88
Updated to 2024 dollars
Activity (A) (B) (C) (D) (E) (F) (G) (H)
EPA person- hours per occurrence No. of occurrences per plant per year EPA person- hours per plant per year (C=AxB) Plants per year a Technical person- hours per year (E=CxD) Management person-hours per year (Ex0.05) Clerical person-hours per year (Ex0.1) Cost, $ b
1. Applications N/A







2. Familiarization with rule requirements N/A







3. Required activities








A. Create information N/A







B. Gather information See 3A







C. Report reviews








1) Review Notifications








a) Preconstruction report 1 1 1 0 0 0 0 $0
b) Startup notification 0.5 1 0.5 0 0 0 0 $0
c) Notification of intent to use substitute means of compliance 0.5 1 0.5 0 0 0 0 $0
d) Notification of final compliance c 1.5 1 1.5 0 0 0 0 $0
2) Review initial compliance test report








a) Initial test report (non-ACI) c 40 1 40 0 0 0 0 $0
b) Initial test report (ACI) c 10 1 10 0 0 0 0 $0
3) Review annual compliance report








a) Annual compliance report (non-ACI, for units using stack tests) 40 1 40 0 0 0 0 $0
b) Annual compliance report (non-ACI, for units using the SMOC) 10 1 10 25 250 12.5 25 $16,001
c) Annual compliance report (ACI) 10 1 10 29 290 14.5 29 $18,561
4) Review semiannual deviation reports 16 2 32 3 96 4.8 9.6 $6,144
5) Review waste management plan c 16 1 16 0 0 0 0 $0
TOTAL ANNUAL BURDEN AND COST (rounded)d



636 32 64 $41,000










Assumptions:








a EPA estimates that there are no existing facilities subject to 40 CFR 60, Subpart FFFF.
b This ICR uses the following labor rates: $57.07 (technical), $76.91 (managerial), and $30.88 (clerical). These rates are from the Office of Personnel Management (OPM), 2024 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 have assumed that this is a one-time only cost for existing respondents with units greater than 10 TPD.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.









Sheet 9: EPA_Summary

Table 9 - Summary of Annual Agency Burden and Cost - Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Final Rule)








Year Technical Hours Management Hours Clerical Hours Total Hours Labor Costs Non-Labor Costs Total Costs

1 1,824 91 182 2,097 $117,000 $0 $117,000

2 636 32 64 731 $41,000 $0 $41,000

3 636 32 64 731 $41,000 $0 $41,000

Total 3,096 155 310 3,560 $199,000 $0 $199,000

Average 1,032 52 103 1,187 $66,333 $0 $66,333










Note: There are no incremental costs to the Agency associated with the rulemaking.







Sheet 10: O&M


Capital/Startup vs. Operation and Maintenance (O&M) Costs







(A) (B) (C) (D) (E) (F) (G)
Initial Stack Test 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 Total O&M, (E X F)
Performance Tests (Non-ACI) $76,667 0 $0 $76,667 0 $0
Performance Tests (ACI) $3,000 0 $0 $3,000 29 $87,000
CEMS (CO and O2) $395,000 0 $0 $73,700 0 $0
Control Device $33,800 0 $0 $2,500 0 $0
Total

$0

$87,000

Sheet 11: 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)
1 0 54 0 0 54
2 0 54 0 0 54
3 0 54 0 0 54
Average 0 54 0 0 54
1 New respondents include sources with constructed, reconstructed and modified affected facilities.

Sheet 12: 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
Preconstruction Report 0 1 N/A 0
Startup notification 0 1 N/A 0
Notification of intent to use substitute means of compliance 0 1 N/A 0
Notification of final compliance 25 1 N/A 25
Initial test report (non-ACI) 0 1 N/A 0
Initial test report (ACI) 0 1 N/A 0
Annual compliance reports (non-ACI, for units using stack tests) 0 1 N/A 0
Annual compliance reports (non-ACI, for units using the SMOC or AWC) 25 1 N/A 25
Annual compliance reports (ACI) 29 1 N/A 29
Waste Management Plan 25 1 N/A 25
Semiannual deviation report 3 2 N/A 6


Total (rounded) 110
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