Burden Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours Per Response	165
Number of Respondents	100
Total Estimated Burden Hours	16,500
Total Estimated Costs	$2,260,000
Annualized Capital O&M	$0
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)
Burden Item	(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 a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarization with regulatory requirements c	1	1	1	100	100	5	10	$15,750.65
B. Required activities for New Sources											Labor Rates
Initial performance test d	24	1	24	0	0	0	0	$0			Technical	$141.75
Repeat performance test e	24	0.2	4.8	0	0	0	0	$0			Management	$172.41
C. Create information	See 3B										Clerical	$71.36
D. Gather existing information	See 3B
E. Write reports
New Sources
Notification of construction/reconstruction f	2	1	2	0	0	0	0	$0
Notification of initial startup g	2	1	2	0	0	0	0	$0
Notification of actual startup g	2	1	2	0	0	0	0	$0
Report of initial performance test
Notification of initial performance test	2	1	2	0	0	0	0	$0
Existing Sources
Report of annual emission test h	12	1	12	100	1200	60	120	$189,007.80
Submit semiannual report i	2	1	2	0	0	0	0	$0
Notification of parameter excursions j	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements					1,495			$204,758
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system
Record operating parameters k	0.25	365	91.25	100	9,125	456.25	912.5	$1,437,246.81
Record mercury leaks l	0.25	365	91.25	0	0	0	0	$0
Record monitored parameters l	0.5	365	182.5	0	0	0	0	$0
Compile data for semiannual reports m	8	2	16	0	0	0	0	$0
Maintain data on mercury leaks n	0.5	52	26	0	0	0	0	$0
Maintain data on monitored parameters n	0.5	52	26	0	0	0	0	$0
E. Time to enter information
Records of startup, shutdown, and malfunction o	1.5	52	78	50	3900	195	390	$614,275.35
F. Audits
Subtotal for Recordkeeping Requirements					14,979			$2,051,522		Responses	Hr/Response
TOTAL LABOR BURDEN AND COST (rounded) p					16,500			$2,260,000		100	165
TOTAL CAPITAL AND O&M COSTS (rounded) p								$0
GRAND TOTAL (rounded) p								$2,260,000
Assumptions:
a We have assumed that there are approximately 100 (100 wastewater sludge incineration and drying plants) existing sources currently subject to this rule. There will be no additional new source that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are 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 have assumed that it will take 1 hour for existing respondents to refamiliarize themselves with rule requirements.
d We have assumed that it will take each new respondent 24 hours to complete initial performance test. Since there are no new respondents estimated, this requirement does not apply.
e We have assumed that 20 percent of new respondents will repeat the performance test due to failure. Since there are no new respondents estimated, this requirement does not apply.
f We have assumed that each new respondent will take two hours to write notification reports on construction/reconstruction. Since there are no new respondents estimated, this requirement does not apply.
g We have assumed that it will take each new respondent two hours each to write notification reports on initial startup and actual startup. Since there are no new respondents estimated, this requirement does not apply.
h We have assumed that 100 of the existing respondents will take 12 hours to write reports on the annual emission tests.
i We have assumed that none of the existing respondents will have to submit semiannual reports.
j We have assumed that none of the existing respondents will write notification reports on parameter excursions two times per year.
k We have assumed that all respondents will record operating parameters 365 days per year.
l We have assumed that no respondents will have to record mercury leaks and monitored parameters.
m We have assumed that no respondents will compile data for semiannual reports.
n We have assumed that no respondents will have to maintain data on mercury leaks and monitored parameters.
o We have assumed that 50 percent of the respondents will each take 1.5 hours to record information of startup, shutdown, and malfunctions.
p Totals have been 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 – NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)
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-year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
Required activities										Labor Rates
New Plants										Managerial	$76.91
Initial performance test c	24	1	24	0	0	0	0	$0		Technical	$57.07
Repeat initial performance test c, d	24	0.2	4.8	0	0	0	0	$0		Clerical	$30.88
Report Review
New Plants
Notification of construction e	0.5	1	0.5	0	0	0	0	$0
Notification of initial startup e	0.5	1	0.5	0	0	0	0	$0
Notification of actual startup e	0.5	1	0.5	0	0	0	0	$0
Notification of initial test e	0.5	1	0.5	0	0	0	0	$0
Review test results f	8	1.2	9.6	0	0	0	0	$0
Existing Plants
Annual emission test	4	1	4	100	400	20	40	$25,602
Review semiannual reports g	8	2	16	0	0	0	0	$0
Review notification on monitored parameters h	8	2	16	0	0	0	0	$0
TOTAL (rounded) i					460			$25,600
Assumptions:
a We have assumed that there are approximately 100 (100 wastewater sludge incineration and drying plants) existing sources currently subject to this rule. There will be no additional new source that will become subject to the rule over the three-year period of this ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 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), 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 the Agency will take 24 hours to participate in the performance tests. It is assumed that all initial performance tests have been completed by existing respondents. Since there are no new respondents estimated, this requirement does not apply.
d We have assumed that 20 percent of new respondents will have to repeat the performance tests due to failure. Since there are no new respondents estimated, this requirement does not apply.
e We have assumed that it will take 0.5 hours for the Agency to review notification reports for each respondent. Since there are no new respondents estimated, this requirement does not apply.
f We have assumed that it will take 8 hours for the Agency to review test results for each respondent. Since there are no new respondents estimated, this requirement does not apply.
g We have assumed that none of the existing respondents will have to submit semiannual reports.
h We have assumed that no respondents will have to record mercury leaks and monitored parameters.
i 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

The only costs to the regulated industry resulting from information collection activities required by the subject standard(s) are labor costs. There are no capital/startup or operation and maintenance costs.

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Sheet 5: 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	100	0	0	100
2	0	100	0	0	100
3	0	100	0	0	100
Average	0	100	0	0	100
1 New respondents include sources with constructed, reconstructed and modified affected facilities.

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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
Notification of construction/reconstruction	0	1	0	0
Notification of initial startup	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of initial performance test	0	1	0	0
Report of annual emission monitoring	100	1	0	100
Submit semiannual report	0	2	0	0
Notification of parameter excursions	0	2	0	0
		Total (rounded)		100