Burden Calculation Tables

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Overview

Summary
Breakdown
Industry (Private) Table 1a
Industry (Public) Table 1b
StateLocal Burden Table 1c
Federal Agency Burden 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours Per Response	1788
Number of Respondents	14
Total Estimated Burden Hours	55,600
Total Estimated Costs	$5,321,000
Annualized Capital O&M	$411,000
Form Number	Not Applicable

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Sheet 2: Breakdown

Category	Number of Respondents	Reporting Hours	Recordkeeping Hours	Total Respondent Labor Hours	Respondent Labor Cost	Capital & O&M Cost	Number of Responses
Privately-Owned	5	20,004	2,277	22,300	$3,050,000	$147,000	13
State & Local Government-Owned MWCs	9	29,243	4,099	33,300	$1,860,000	$264,000	18
Total (Rounded)a	14	49,200	6,380	55,600	$4,910,000	$411,000	31
							1,788	hrs/response
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Industry (Private) Table 1a

Table 1a: Annual Respondent Burden and Cost for Private Industry – NSPS for Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or before August 30, 1999 (40 CFR part 60, Subpart BBBB) (Renewal)
Burden item	(A) Person-hours per occurrence	(B) No. of occurrence per respondent per year	(C) Person-hours per respondent per year (C=AxB)	(D) Respondents per yeara, b	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (F=E x 0.05)	(G) Clerical person hours per year (G = E x 0.1)	(H) Cost $ c
										Labor Rates:
1. Applications	N/A									Tech.	$141.75
2. Survey and Studies	N/A									Mgmt.	$172.41
3. Reporting Requirements										Cler.	$71.36
A. Familiarization with Regulatory Requirements	4	1	4	5	20	1	2	$3,150.13
B. Required Activities
i.  Initial performance tests and reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	0	0	0	0	$0
ii. CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)								$0
a. Installation of CEM units	225	1	225	0	0	0	0	$0
b. Initial demonstration	450	1	450	0	0	0	0	$0
iii. Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	5	3,875.00	193.75	387.5	$610,337.69
iv. Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a. RATA audit (one per year) d	350	2.4	840	5	4,200.00	210	420.0	$661,527.30
b. RAA audit (three per year) e	130	7.2	936	5	4,680.00	234.00	468.0	$737,130.42
c. Daily calibration and operation f	1	876	876	5	4,380.00	219	438	$689,878.47
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
i. Plant startup
a. Plant Control Plan	40	1	40	0	0	0	0	$0
b. Notification of Contract Awards	4	1	4	0	0	0	0	$0
c. Notification of on-site construction start	4	1	4	0	0	0	0	$0
d. Notification of construction completion	4	1	4	0	0	0	0	$0
e. Notification of final completion	4	1	4	0	0	0	0	$0
ii. Notification of initial performance tests	4	1	4	0	0	0	0	$0
iii. Initial compliance reports	40	1	40	0	0	0	0	$0
iv. Notification of CEMS demonstration	4	1	4	0	0	0	0	$0
v. Initial CEMS demonstration report	90	1	90	0	0	0	0	$0
vi. Annual compliance reports	40	1	40	5	200	10.0	20.0	$31,501.30
vii. Semiannual excess emission reports g	40	2	80	0.5	40	2	4	$6,300.26
Reporting Subtotal					20,004			$2,739,826
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record information
i. Record startups, shutdowns, and malfunctions h	4	47	188	5	940	47	94	$148,056.11
ii. Records of all emission rates, computations, tests h	4	47	188	5	940	47	94	$148,056.11
iii. Records of employee review of operations manual	4	1	4	5	20	1	2	$3,150.13
iv. Record amount of sorbent used for Hg and dioxin/furan control	4	4	16	5	80	4	8	$12,600.52
F. Personnel Training	N/A
G. Time for audits	N/A
Recordkeeping subtotal					2,277			$311,863
TOTAL LABOR BURDEN AND COST (Rounded):i					22,300			$3,050,000
Capital and O&M Cost (Rounded):i								$115,000
GRAND TOTAL (Rounded):i								$3,170,000
Assumptions:
a Assumes an average of 5 private respondents and 2.4 affected facilities (i.e., sources or units) per respondent [12 facilities at 5 plants; 12/5 = 2.4].
b No additional facilities will become subject to the standard over the next three years.
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.
d Relative accuracy test audits (RATA) occur once per year for each affected facility (1 x 2.4 = 2.4). RATA are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
e Relative accuracy audits (RAA) occur three times per year for each affected facility (3 x 2.4 = 7.2).
f Daily calibration and operation data occurs daily [365 x 2.4 = 876 (Rounded)].
g Assumes 10 percent of private sources (0.5) have affected facilities with excess emissions and must submit two semiannual reports.
h Assumes 47 weeks of operation (90 percent availability) per year per facility.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Industry (Public) Table 1b

Table 1b: Annual Respondent Burden and Cost for Publicly-Owned Entities – NSPS for Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or before August 30, 1999 (40 CFR part 60, Subpart BBBB) (Renewal)
Burden item	(A) Person-hours per occurrence	(B) No. of occurrence per respondent per year	(C) Person-hours per respondent per year (C=AxB)	(D) Respondents per yeara, b	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (F=E x 0.05)	(G) Clerical person hours per year (G = E x 0.1)	(H) Cost $ c
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Technical	$57.07
3. Reporting Requirements										Managerial	$76.91
A. Familiarization with Regulatory Requirements	4	1	4	9	36	1.8	3.6	$2,304.20		Clerical	$30.88
B. Required Activities
i.  Initial performance tests and reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	0	0	0	0	$0.00
ii. CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)								$0.00
a. Installation of CEM units	225	1	225	0	0	0	0	$0.00
b. Initial demonstration	450	1	450	0	0	0	0	$0.00
iii. Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	9	6,975.00	348.75	697.5	$446,439.06
iv. Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a. RATA audit (one per year) d	350	1.78	623	9	5,607.00	280.35	560.7	$358,879.40
b. RAA audit (three per year) e	130	5.34	694.2	9	6,247.80	312.39	624.8	$399,894.19
c. Daily calibration and operation f	1	650	650	9	5,850.00	292.5	585	$374,432.76
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
i. Plant startup
a. Plant Control Plan	40	1	40	0	0	0	0	$0.00
b. Notification of Contract Awards	4	1	4	0	0	0	0	$0.00
c. Notification of on-site construction start	4	1	4	0	0	0	0	$0.00
d. Notification of construction completion	4	1	4	0	0	0	0	$0.00
e. Notification of final completion	4	1	4	0	0	0	0	$0.00
ii. Notification of initial performance tests	4	1	4	0	0	0	0	$0.00
iii. Initial compliance reports	40	1	40	0	0	0	0	$0.00
iv. Notification of CEMS demonstration	4	1	4	0	0	0	0	$0.00
v. Initial CEMS demonstration report	90	1	90	0	0	0	0	$0.00
vi. Annual compliance reports	40	1.78	71.2	9	641	32.04	64.08	$41,014.79
vii. Semiannual excess emission reportsg	40	2	80	0.9	72	3.6	7.2	$4,608.40
Reporting Subtotal					29,243			$1,627,573
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record information
i. Record startups, shutdowns, and malfunctions h	4	47	188	9	1,692	84.6	169.2	$108,297.48
ii. Records of all emission rates, computations, tests h	4	47	188	9	1,692	84.6	169.2	$108,297.48
iii. Records of employee review of operations manual	4	1	4	9	36	1.8	3.6	$2,304.20
iv. Record amount of sorbent used for Hg and dioxin/furan control	4	4	16	9	144	7.2	14.4	$9,216.81
F. Personnel Training	N/A
G. Time for audits	N/A
Recordkeeping subtotal					4,099			$228,116
TOTAL LABOR BURDEN AND COST (Rounded):					33,300			$1,860,000
Capital and O&M Cost (see Section 6(b)(iii)):								$307,000
TOTAL COST:								$2,170,000
Assumptions:
a Assumes an average of 9 public respondents and 1.78 affected facilities (i.e., sources or units) per respondent [16 facilities at 9 plants; 16/9 = 1.78].
b No additional facilities will become subject to the standard over the next three years.
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.
d Relative accuracy test audits (RATA) occur once per year for each affected facility (1 x 1.78 = 1.78). RATA are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
e Relative accuracy audits (RAA) occur three times per year for each affected facility (3 x 1.78 = 5.34).
f Daily calibration and operation data occurs daily [365 x 1.78 = 650 (Rounded)].
g Assumes 10 percent of public sources (1.6) have affected facilities with excess emissions and must submit two semiannual reports.
h Assumes 47 weeks of operation (90 percent availability) per year per facility.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: StateLocal Burden Table 1c

Table 1c: Average State/Local Burden and Cost – NSPS for Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or before August 30, 1999 (40 CFR part 60, Subpart BBBB) (Renewal)
Activity	(A) No. occurrence per year	(B) Person-hours per occurrence	(C) Technical person-hours per year (C = A x B)	(D) Management person-hours per year (D = C x 0.05)	(E) Clerical person-hours per year (E = C x 0.1)	(H) Costa $
1. Applications	N/A							Labor Rates:
2. Report Reviews b, c								Technical	$57.07
i.  Review preliminary and final material separation plans and siting analysis	0	8	0	0	0	$0		Managerial	$76.91
ii. Review notification of construction	0	2	0	0	0	$0		Clerical	$30.88
iii. Review notification of startup	0	2	0	0	0	$0
iv. Review notification of initial performance test	0	8	0	0	0	$0
v. Review notification of initial CEMS demonstration	0	4	0	0	0	$0
vi. Review initial performance test report	0	40	0	0	0	$0
vii. Review initial CEMS demonstration report	0	40	0	0	0	$0
viii. Review annual compliance report d	6	24	144	7.2	14.4	$9,217
ix. Review semi-annual excess emission report e	2.8	16	44.8	2.24	4.48	$2,867
3. Prepare annual summary report	1	200	200	10	20	$12,801
TOTAL ANNUAL COST (rounded) f			447			$24,900
Assumptions:
a 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.
b No additional sources will become subject to the standard over the next three years. We also assume affected air quality program administrator in States and U.S. territories have already submitted a State Plan and/or negative declaration.
c Assumes 14 affected units at 6 plants.
d Assumes four hours to review the annual compliance report for each plant (4 x 6 = 24).
e Assumes submission of semiannual excess emission reports will be required for 10 percent of units (14 x 0.10 = 1.4); (2 x 1.4 = 2.8).
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: Federal Agency Burden 2

Table 2: AverageEPA Burden and Cost – NSPS for Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or before August 30, 1999 (40 CFR part 60, Subpart BBBB) (Renewal)
Activity	(A) No. occurrence per year	(B) Person-hours per occurrence	(C) Technical person-hours per year (C = A x B)	(D) Management person-hours per year (D = C x 0.05)	(E) Clerical person-hours per year (E = C x 0.1)	(H) Costa $
1. Applications	N/A							Labor Rates:
2. Report Reviews b, c								Technical	$57.07
i.  Review preliminary and final material separation plans and siting analysis	0	8	0	0	0	$0		Managerial	$76.91
ii. Review notification of construction	0	2	0	0	0	$0		Clerical	$30.88
iii. Review notification of startup	0	2	0	0	0	$0
iv. Review notification of initial performance test	0	8	0	0	0	$0
v. Review notification of initial CEMS demonstration	0	4	0	0	0	$0
vi. Review initial performance test report	0	40	0	0	0	$0
vii. Review initial CEMS demonstration report	0	40	0	0	0	$0
viii. Review annual compliance report d	8	32	256	12.8	25.6	$16,385
ix. Review semi-annual excess emission report e	2.8	16	44.8	2.24	4.48	$2,867
3. Prepare annual summary report	1	200	200	10	20	$12,801
TOTAL ANNUAL COST (rounded) f			576			$32,100
Assumptions:
a 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.
b No additional sources will become subject to the standard over the next three years. We also assume affected air quality program administrator in States and U.S. territories have already submitted a State Plan and/or negative declaration.
c Assumes 14 affected units at 8 plants are subject to the Federal Plan.
d Assumes four hours to review the annual compliance report for each plant (4 x 8 = 32).
e Assumes submission of semiannual excess emission reports will be required for 10 percent of units (1.4); (2 x 1.4= 2.8).
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 7: 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	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)			CEPCI Index 2009:	521.9
Load monitors, temperature monitors, and carbon federate monitors (Sections 60.1315 thru 60.1335) a	$305,767	0	$0	$29,354	14	$411,000			CEPCI Index 2023:	797.9
a Costs have been updated from 2009 dollars to 2023 dollars using the CEPCI CE Index. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 8: Respondents

Number of States Implementing State Plans
	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	6	0	0	6
2	0	6	0	0	6
3	0	6	0	0	6
Average	0	6	0	0	6
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	14	0	0	14
2	0	14	0	0	14
3	0	14	0	0	14
Average	0	14	0	0	14
1 New respondents include sources with constructed, reconstructed and modified affected facilities.

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Sheet 9: 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
State plan	6	0	0	0
Negative Declaration	0	0	0	0
Plant Startup (Plant Control Plan, notifications, etc.)	0	1	0	0
Notifications (Performance Test, CEMS Demonstration, etc.)	0	1	0	0
Annual Reports (Private)	5	2.4	0	12
Annual Reports (Public)	9	1.78	0	16.02
Semiannual Excess Emission Reports	1.4	2	0	2.8
		Total (rounded)		31