Burden Calculation Table

2385t08.xlsx

Emission Guidelines for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR part 60, subpart DDDD) (Renewal)

Burden Calculation Table

OMB: 2060-0664

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Overview

Table 1 Summary
Table 1a_Incinerators
Table 1b_ERU-Solid
Table 1c_Small Remote
Table 1d_ERU-Liq Yr
Table 1e_ Kilns
Table 2
Labor Rates
VE Testing
Stack Testing
Monitoring
Subcat Inputs


Sheet 1: Table 1 Summary

Table 1. Annual Respondent Burden and Cost Summary – Emission Guidelines for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal)



CISWI Unit Type Number of Respondents Per Year Number of Units Number of Responses Reporting Hours Recordkeeping Hours Total Labor Hours Total Labor Costs Annualized Capital/O&M Costs Total Costs

Number of Responses/ Respondent
Incinerator 22 27 38 1,922 688 2,610 $309,000 $2,070,000 $2,379,000

1.73
ERU, solid 13 22 31 1,447 407 1,855 $220,000 $2,400,000 $2,620,000

2.38
Small, remote incinerator 26 30 42 2,174 812 2,986 $354,000 $2,070,000 $2,424,000

1.62
ERU, liquid/gas 4 6 8 406 125 531 $62,900 $443,000 $505,900

2.00
Waste-burning kilns 13 23 32 1,499 408 1,907 $226,000 $4,040,000 $4,266,000

2.46
Subtotals (all types) 78 108 151 7,448 2,441 9,888 $1,171,900 $11,023,000 $12,194,900



GRAND TOTAL (rounded)1




9,890 $1,170,000 $11,000,000 $12,200,000

65 Hrs/Response












127 Hrs/Respondent
1 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.


























Agency Total Burden Hours Total Costs










1,870 $93,400





















































# of Responses







CISWI Unit Type Results of performance tests conducted during the year Status report for operators that are off-site for more than 2 weeks Corrective action summary for operators that are off-site for more than 2 weeks Semiannual report of emissions/parameter exceedances TOTAL







Incinerator 27 2.7 5.4 2.7 37.8







ERU, solid 22 2.2 4.4 2.2 30.8







Small, remote incinerator 30 3.0 6.0 3.0 42







ERU, liquid/gas 6 0.6 1.2 0.6 8.4







Waste-burning kilns 23 2.3 4.6 2.3 32.2







Totals 108 10.8 21.6 10.8 151








Sheet 2: Table 1a_Incinerators

Table 1a - Annual Respondent Burden and Cost - Emissions Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal) - Incinerators

















Testing, Operation, and Maintenance Costs
Burden item (A)
Person hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Person hours per respondent per year
(C = A x B)
(D)
Respondents per year a
(E)
Technical person- hours per year
(E = C x D)
(F)
Management person hours per year
(E x 0.05)
(G)
Clerical person hours per year
(E x 0.1)
(H)
Total Cost Per year b


Emission Testing Contractor Hours Per Occurrence Non-Labor Costs Per Occurrence Emission Testing Contractor Hours Per Year Total Non-Labor Costs Per Year Total Responses Per Year
1. Applications N/A













2. Surveys and Studies N/A













3. Reporting Requirements














A. Familiarization with Rule Requirements c 1 1 1 22 22 1 2 $2,997.28

0 $0 0 $0 0
B. Required Activities














1) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2 (as required)) d See 3.E.








varies $62,933 0 $0 0
2) Annual stack test and test report (PM, HCl, Opacity, and Fugitive Ash) e See 3.E.10








790 $63,223 0 $1,707,030 0
3) Operator training and qualification














a) Establish and teach operator qualification course f 64 1 64 0 0 0 0 $0

0 $0 0 $0 0
b) Obtain operator qualification f 72 1 72 0 0 0 0 $0

0 $0 0 $0 0
c) Annual refresher course g 12 1 12 22 264 13.2 26.4 $35,967.36


$0 0 $0 0
d) Initial review of site-specific information See 3.B.3.a.








e) Annual review of site-specific information g 8 1 8 22 176 8.8 17.6 $23,978.24

0 $0 0 $0 0
4) Establish operating parameters (maximum and minimum) d 40 1 40 0 0 0 0 $0

Included in 3.B.1. $0 0 $0 0
5) Continuous parameter monitoring (including CEMS)














a) Initial costs f 17 1 17 0 0 0 0 $0

0 $0 0 $0 0
b) Annual costs g 17 1 17 0 0 0 0 $0

0 $13,456 0 $363,319 0
C. Create Information See 3.B













D. Gather Information See 3.E













E. Report Preparation














1) Notification of initial performance test h














a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0

0 $0 0 $0 0
2) Notification of initial CMS Demonstration h 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
3) Report of initial performance test h














a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0

0 $7.50 0 $0 0
b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
4) Report of initial CMS demonstration h See 3.B.5













5) Report prior to construction (includes siting analysis) h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0
6) Report prior to initial start-up h, i


a) Without site specific parameter petition 6 1 6 0 0 0 0 $0

0 $0 0 $0 0
b) With site specific parameter petition 14 1 14 0 0 0 0 $0

0 $0 0 $0 0
7) Report of initial stack test h See 3.B.1


8) Report established values for site-specific operating parameters h See 3.B








0 $0 0 $0 0
9) Waste management plan h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0
10) Report of results of annual performance test e 40 1 40 27 1,080 54 108 $147,139.20

0 $7.50 0 $203 27
11) Status report for operators that are off-site for more than 2 weeks j 8 1 8 2.7 21.6 1.08 2.16 $2,942.78

0 $0 0 $0 2.7
12) Corrective action summary for operators that are off-site for more than 2 weeks j 8 2 16 2.7 43.2 2.16 4.32 $5,885.57

0 $0 0 $0 5.4
13) Semiannual report of emissions/parameter exceedances k 24 1 24 2.7 64.8 3.24 6.48 $8,828.35

0 $7.50 0 $20 2.7
Subtotal for Reporting Requirements



1,922 $227,739






4. Recordkeeping Requirements


A. Familiarization with Rule Requirements See 3.A


B. Plan Activities N/A


C. Implement Activities N/A













D. Develop Record System N/A













E. Record Information














1) Records of operating parameters See 3.B.5.b








0 $0 0 $0 0
2) Records of periods for which minimum amount of data on operating parameters were not obtained l 0.5 52 26 0 0 0 0 $0

0 $0 0 $0 0
3) Records of malfunction of the unit l 1.5 1 1.5 0 0 0 0 $0

0 $0 0 $0 0
4) Records of exceedances of the operating parameters k 1.5 1 1.5 2.7 4.05 0.20 0.41 $551.77

0 $0 0 $0 0
5) Records of stack tests See 3.E













6) Records of siting analysis See 3.E













7) Records of persons who have reviewed operating procedures 1 1 1 22 22 1.10 2.2 $2,997.28

0 $0 0 $0 0
8) Records of persons who have completed operator training 1 1 1 22 22 1.10 2.2 $2,997.28

0 $0 0 $0 0
9) Records of persons whe meet operator qualification criteria 1 1 1 22 22 1.10 2.2 $2,997.28

0 $0 0 $0 0
10) Records of monitoring device calibration See 3.B


11) Records of site-specific documentation 24 1 24 22 528 26.4 52.8 $71,934.72

0 $0 0 $0 0
F. Personnel Training See 3.B










G. Time for Audits N/A













Subtotal for Recordkeeping Requirements



688 $81,478






Total Labor Burden and Costs (rounded) m
2,610 $309,000






Total Capital and O&M Cost (rounded) m
$2,070,000




$2,070,000
GRAND TOTAL (rounded) m
$2,380,000






















Assumptions






a We assume an average of 108 CISWI units at 78 existing respondents per year over the next three years. No new units or respondents are anticipated over the next three years. This consists of 27 incinerator units located at 22 incinerator facilities, 22 energy recovery units - solids located at 13 energy recovery - solids facilities, 30 small, remote incinerators located at 26 small, remote facilities, 6 energy recovery units - liquids located at 4 energy recovery - liquids facilities, and 23 waste burning kilns located at 13 waste burning facilities.






b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 We assume that each respondent will re-familiarize with the requirements each year.






d Initial stack testing is performed when a new unit is completed. No new units are expected over the next three years. Operating parameters are established during the initial stack test for a unit.






e Annual stack testing is performed each year. Labor costs are accounted in the Reporting section. Testing costs are due to contractor labor and are accounted for in Capital and O&M Cost section.






f These operator qualification requirements and compliance costs are associated with the startup of a new unit. We assume that all facilities have completed initial monitoring requirements.






g The refresher course and annual review requirements occur each year. CEMS maintenance is performed each year. Annual reporting costs for the CEMS are calculated under the operation and maintenance (O&M) cost section.






h These notifications, reports, and waste management plan are required for newly constructed units. No new units are expected over the next three years.






i We assume that one-third of the facilities will petition for site-specific parameters.






j We assume that 10 percent of the CISWI units at facilities would not have a qualified operator available for more than two weeks at least once a year. We also assume that this required only two corrective action summaries.






k We assume that 10 percent of the CISWI units at facilities would have one exceedance during the year. The rule requires the semiannual report be submitted only in the event of an exceedance. Therefore, only 1 semiannual report is submitted for each emissions/parameter exceedance.






l The standards apply at all times under this regulation. Therefore, no periods of unobtained data or malfunction periods are expected.






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







Sheet 3: Table 1b_ERU-Solid

Table 1b - Annual Respondent Burden and Cost - Emissions Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal) - Energy Recovery Units (Solids)



















Testing, Operation, and Maintenance Costs

Burden item (A)
Person hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Person hours per respondent per year
(C = A x B)
(D)
Respondents per year a
(E)
Technical person- hours per year
(E = C x D)
(F)
Management person hours per year
(E x 0.05)
(G)
Clerical person hours per year
(E x 0.1)
(H)
Total Cost Per year b


Emission Testing Contractor Hours Per Occurrence Non-Labor Costs Per Occurrence Emission Testing Contractor Hours Per Year Total Non-Labor Costs Per Year Total Responses Per Year

1. Applications N/A















2. Surveys and Studies N/A















3. Reporting Requirements
















A. Familiarization with Rule Requirements c 1 1 1 13 13 1 1 $1,771.12

0 $0 0 $0 0

B. Required Activities
















1) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2 (as required)) d See 3.E.








varies $62,933 0 $0 0

2) Annual stack test and test report (PM, HCl, Opacity, and Fugitive Ash) e See 3.E.10








790 $63,223 0 $1,390,913 0

3) Operator training and qualification
















a) Establish and teach operator qualification course f 64 1 64 0 0 0 0 $0

0 $0 0 $0 0

b) Obtain operator qualification f 72 1 72 0 0 0 0 $0

0 $0 0 $0 0

c) Annual refresher course g 12 1 12 13 156 7.8 15.6 $21,253.44


$0 0 $0 0

d) Initial review of site-specific information See 3.B.3.a.










e) Annual review of site-specific information g 8 1 8 13 104 5.2 10.4 $14,168.96

0 $0 0 $0 0

4) Establish operating parameters (maximum and minimum) d 40 1 40 0 0 0 0 $0

Included in 3.B.1. $0 0 $0 0

5) Continuous parameter monitoring (including CEMS)
















a) Initial costs f 17 1 17 0 0 0 0 $0

0 $0 0 $0 0

b) Annual costs g 17 1 17 0 0 0 0 $0

0 $46,078 0 $1,013,723 0

C. Create Information See 3.B















D. Gather Information See 3.E















E. Report Preparation
















1) Notification of initial performance test h
















a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0

b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0

0 $0 0 $0 0

2) Notification of initial CMS Demonstration h 2 1 2 0 0 0 0 $0

0 $0 0 $0 0

3) Report of initial performance test h
















a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0

0 $7.50 0 $0 0

b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0

4) Report of initial CMS demonstration h See 3.B.5















5) Report prior to construction (includes siting analysis) h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0

6) Report prior to initial start-up h, i




a) Without site specific parameter petition 6 1 6 0 0 0 0 $0

0 $0 0 $0 0

b) With site specific parameter petition 14 1 14 0 0 0 0 $0

0 $0 0 $0 0

7) Report of initial stack test h See 3.B.1




8) Report established values for site-specific operating parameters h See 3.B 1 #VALUE! 0 #VALUE! #VALUE! #VALUE! $0

0 $0 0 $0 0

9) Waste management plan h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0

10) Report of results of annual performance test e 40 1 40 22 880 44 88 $119,891.20

0 $7.50 0 $165 22

11) Status report for operators that are off-site for more than 2 weeks j 8 1 8 2.2 17.6 0.88 1.76 $2,397.82

0 $0 0 $0 2.2

12) Corrective action summary for operators that are off-site for more than 2 weeks j 8 2 16 2.2 35.2 1.76 3.52 $4,795.65

0 $0 0 $0 4.4

13) Semiannual report of emissions/parameter exceedances k 24 1 24 2.2 52.8 2.64 5.28 $7,193.47

0 $7.50 0 $17 2.2

Subtotal for Reporting Requirements



1,447 $171,472








4. Recordkeeping Requirements




A. Familiarization with Rule Requirements See 3.A




B. Plan Activities N/A




C. Implement Activities N/A















D. Develop Record System N/A















E. Record Information
















1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0

0 $0 0 $0 0

2) Records of periods for which minimum amount of data on operating parameters were not obtained l 0.5 52 26 0 0 0 0 $0

0 $0 0 $0 0

3) Records of malfunction of the unit l 1.5 1 1.5 0 0 0 0 $0

0 $0 0 $0 0

4) Records of exceedances of the operating parameters k 1.5 1 1.5 2.2 3.3 0.17 0.33 $449.59

0 $0 0 $0 0

5) Records of stack tests See 3.E















6) Records of siting analysis See 3.E















7) Records of persons who have reviewed operating procedures 1 1 1 13 13 0.65 1.3 $1,771.12

0 $0 0 $0 0

8) Records of persons who have completed operator training 1 1 1 13 13 0.65 1.3 $1,771.12

0 $0 0 $0 0

9) Records of persons whe meet operator qualification criteria 1 1 1 13 13 0.65 1.3 $1,771.12

0 $0 0 $0 0

10) Records of monitoring device calibration See 3.B




11) Records of site-specific documentation 24 1 24 13 312 15.6 31.2 $42,506.88

0 $0 0 $0 0

F. Personnel Training See 3.B












G. Time for Audits N/A















Subtotal for Recordkeeping Requirements



407 $48,270








Total Labor Burden and Costs (rounded) m
1,855 $220,000








Total Capital and O&M Cost (rounded) m
$2,400,000




$2,400,000


GRAND TOTAL (rounded) m
$2,620,000


























Assumptions








a We assume an average of 108 CISWI units at 78 existing respondents per year over the next three years. No new units or respondents are anticipated over the next three years. This consists of 27 incinerator units located at 22 incinerator facilities, 22 energy recovery units - solids located at 13 energy recovery - solids facilities, 30 small, remote incinerators located at 26 small, remote facilities, 6 energy recovery units - liquids located at 4 energy recovery - liquids facilities, and 23 waste burning kilns located at 13 waste burning facilities.








b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 We assume that each respondent will re-familiarize with the requirements each year.








d Initial stack testing is performed when a new unit is completed. No new units are expected over the next three years. Operating parameters are established during the initial stack test for a unit.








e Annual stack testing is performed each year. Labor costs are accounted in the Reporting section. Testing costs are due to contractor labor and are accounted for in Capital and O&M Cost section.








f These operator qualification requirements and compliance costs are associated with the startup of a new unit. We assume that all facilities have completed initial monitoring requirements.








g The refresher course and annual review requirements occur each year. CEMS maintenance is performed each year. Annual reporting costs for the CEMS are calculated under the operation and maintenance (O&M) cost section.








h These notifications, reports, and waste management plan are required for newly constructed units. No new units are expected over the next three years.








i We assume that one-third of the facilities will petition for site-specific parameters.








j We assume that 10 percent of the CISWI units at facilities would not have a qualified operator available for more than two weeks at least once a year. We also assume that this required only two corrective action summaries.








k We assume that 10 percent of the CISWI units at facilities would have one exceedance during the year. The rule requires the semiannual report be submitted only in the event of an exceedance. Therefore, only 1 semiannual report is submitted for each emissions/parameter exceedance.








l The standards apply at all times under this regulation. Therefore, no periods of unobtained data or malfunction periods are expected.








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









Sheet 4: Table 1c_Small Remote

Table 1c - Annual Respondent Burden and Cost - Emissions Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal) - Small Remote Incinerators

















Testing, Operation, and Maintenance Costs
Burden item (A)
Person hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Person hours per respondent per year
(C = A x B)
(D)
Respondents per year a
(E)
Technical person- hours per year
(E = C x D)
(F)
Management person hours per year
(E x 0.05)
(G)
Clerical person hours per year
(E x 0.1)
(H)
Total Cost Per year b


Emission Testing Contractor Hours Per Occurrence Non-Labor Costs Per Occurrence Emission Testing Contractor Hours Per Year Total Non-Labor Costs Per Year Total Responses Per Year
1. Applications N/A













2. Surveys and Studies N/A













3. Reporting Requirements














A. Familiarization with Rule Requirements c 1 1 1 26 26 1 3 $3,542.24

0 $0 0 $0 0
B. Required Activities














1) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2 (as required)) d See 3.E.








varies $62,933 0 $0 0
2) Annual stack test and test report (PM, HCl, Opacity, and Fugitive Ash) e See 3.E.10








790 $63,223 0 $1,896,700 0
3) Operator training and qualification














a) Establish and teach operator qualification course f 64 1 64 0 0 0 0 $0

0 $0 0 $0 0
b) Obtain operator qualification f 72 1 72 0 0 0 0 $0

0 $0 0 $0 0
c) Annual refresher course g 12 1 12 26 312 15.6 31.2 $42,506.88


$0 0 $0 0
d) Initial review of site-specific information See 3.B.3.a.








e) Annual review of site-specific information g 8 1 8 26 208 10.4 20.8 $28,337.92

0 $0 0 $0 0
4) Establish operating parameters (maximum and minimum) d 40 1 40 0 0 0 0 $0

Included in 3.B.1. $0 0 $0 0
5) Continuous parameter monitoring (including CEMS)














a) Initial costs f 17 1 17 0 0 0 0 $0

0 $0 0 $0 0
b) Annual costs g 17 1 17 0 0 0 0 $0

0 $5,871 0 $176,121 0
C. Create Information See 3.B













D. Gather Information See 3.E













E. Report Preparation














1) Notification of initial performance test h














a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0

0 $0 0 $0 0
2) Notification of initial CMS Demonstration h 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
3) Report of initial performance test h














a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0

0 $7.50 0 $0 0
b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
4) Report of initial CMS demonstration h See 3.B.5













5) Report prior to construction (includes siting analysis) h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0
6) Report prior to initial start-up h, i


a) Without site specific parameter petition 6 1 6 0 0 0 0 $0

0 $0 0 $0 0
b) With site specific parameter petition 14 1 14 0 0 0 0 $0

0 $0 0 $0 0
7) Report of initial stack test h See 3.B.1


8) Report established values for site-specific operating parameters h See 3.B 1 #VALUE! 0 #VALUE! #VALUE! #VALUE! $0

0 $0 0 $0 0
9) Waste management plan h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0
10) Report of results of annual performance test e 40 1 40 30 1,200 60 120 $163,488.00

0 $7.50 0 $225 30
11) Status report for operators that are off-site for more than 2 weeks j 8 1 8 3 24.0 1.20 2.40 $3,269.76

0 $0 0 $0 3.0
12) Corrective action summary for operators that are off-site for more than 2 weeks j 8 2 16 3 48.0 2.40 4.80 $6,539.52

0 $0 0 $0 6.0
13) Semiannual report of emissions/parameter exceedances k 24 1 24 3 72.0 3.60 7.20 $9,809.28

0 $7.50 0 $23 3.0
Subtotal for Reporting Requirements



2,174 $257,494






4. Recordkeeping Requirements


A. Familiarization with Rule Requirements See 3.A


B. Plan Activities N/A


C. Implement Activities N/A













D. Develop Record System N/A













E. Record Information














1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0

0 $0 0 $0 0
2) Records of periods for which minimum amount of data on operating parameters were not obtained l 0.5 52 26 0 0 0 0 $0

0 $0 0 $0 0
3) Records of malfunction of the unit l 1.5 1 1.5 0 0 0 0 $0

0 $0 0 $0 0
4) Records of exceedances of the operating parameters k 1.5 1 1.5 3 4.5 0.23 0.45 $613.08

0 $0 0 $0 0
5) Records of stack tests See 3.E













6) Records of siting analysis See 3.E













7) Records of persons who have reviewed operating procedures 1 1 1 26 26 1.3 2.6 $3,542.24

0 $0 0 $0 0
8) Records of persons who have completed operator training 1 1 1 26 26 1.3 2.6 $3,542.24

0 $0 0 $0 0
9) Records of persons whe meet operator qualification criteria 1 1 1 26 26 1.3 2.6 $3,542.24

0 $0 0 $0 0
10) Records of monitoring device calibration See 3.B


11) Records of site-specific documentation 24 1 24 26 624 31.2 62.4 $85,013.76

0 $0 0 $0 0
F. Personnel Training See 3.B










G. Time for Audits N/A













Subtotal for Recordkeeping Requirements



812 $96,254






Total Labor Burden and Costs (rounded) m
2,986 $354,000






Total Capital and O&M Cost (rounded) m
$2,070,000




$2,070,000
GRAND TOTAL (rounded) m
$2,420,000






















Assumptions






a We assume an average of 108 CISWI units at 78 existing respondents per year over the next three years. No new units or respondents are anticipated over the next three years. This consists of 27 incinerator units located at 22 incinerator facilities, 22 energy recovery units - solids located at 13 energy recovery - solids facilities, 30 small, remote incinerators located at 26 small, remote facilities, 6 energy recovery units - liquids located at 4 energy recovery - liquids facilities, and 23 waste burning kilns located at 13 waste burning facilities.






b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 We assume that each respondent will re-familiarize with the requirements each year.






d Initial stack testing is performed when a new unit is completed. No new units are expected over the next three years. Operating parameters are established during the initial stack test for a unit.






e Annual stack testing is performed each year. Labor costs are accounted in the Reporting section. Testing costs are due to contractor labor and are accounted for in Capital and O&M Cost section.






f These operator qualification requirements and compliance costs are associated with the startup of a new unit. We assume that all facilities have completed initial monitoring requirements.






g The refresher course and annual review requirements occur each year. CEMS maintenance is performed each year. Annual reporting costs for the CEMS are calculated under the operation and maintenance (O&M) cost section.






h These notifications, reports, and waste management plan are required for newly constructed units. No new units are expected over the next three years.






i We assume that one-third of the facilities will petition for site-specific parameters.






j We assume that 10 percent of the CISWI units at facilities would not have a qualified operator available for more than two weeks at least once a year. We also assume that this required only two corrective action summaries.






k We assume that 10 percent of the CISWI units at facilities would have one exceedance during the year. The rule requires the semiannual report be submitted only in the event of an exceedance. Therefore, only 1 semiannual report is submitted for each emissions/parameter exceedance.






l The standards apply at all times under this regulation. Therefore, no periods of unobtained data or malfunction periods are expected.






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







Sheet 5: Table 1d_ERU-Liq Yr

Table 1d- Annual Respondent Burden and Cost - Emissions Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal) - Energy Recovery Units (Liquid/Gas)

















Testing, Operation, and Maintenance Costs
Burden item (A)
Person hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Person hours per respondent per year
(C = A x B)
(D)
Respondents per year a
(E)
Technical person- hours per year
(E = C x D)
(F)
Management person hours per year
(E x 0.05)
(G)
Clerical person hours per year
(E x 0.1)
(H)
Total Cost Per year b


Emission Testing Contractor Hours Per Occurrence Non-Labor Costs Per Occurrence Emission Testing Contractor Hours Per Year Total Non-Labor Costs Per Year Total Responses Per Year
1. Applications N/A













2. Surveys and Studies N/A













3. Reporting Requirements














A. Familiarization with Rule Requirements c 1 1 1 4 4 0 0 $544.96

0 $0 0 $0 0
B. Required Activities














1) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2 (as required)) d See 3.E.








varies $62,933 0 $0 0
2) Annual stack test and test report (PM, HCl, Opacity, and Fugitive Ash) e See 3.E.10








790 $63,223 0 $379,340 0
3) Operator training and qualification














a) Establish and teach operator qualification course f 64 1 64 0 0 0 0 $0

0 $0 0 $0 0
b) Obtain operator qualification f 72 1 72 0 0 0 0 $0

0 $0 0 $0 0
c) Annual refresher course g 12 1 12 4 48 2.4 4.8 $6,539.52


$0 0 $0 0
d) Initial review of site-specific information See 3.B.3.a.








e) Annual review of site-specific information g 8 1 8 4 32 1.6 3.2 $4,359.68

0 $0 0 $0 0
4) Establish operating parameters (maximum and minimum) d 40 1 40 0 0 0 0 $0

Included in B.1. $0 0 $0 0
5) Continuous parameter monitoring (including CEMS)














a) Initial costs f 17 1 17 0 0 0 0 $0

0 $0 0 $0 0
b) Annual costs g 17 1 17 0 0 0 0 $0

0 $10,683 0 $64,100 0
C. Create Information See 3.B













D. Gather Information See 3.E













E. Report Preparation














1) Notification of initial performance test h














a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0

0 $0 0 $0 0
2) Notification of initial CMS Demonstration h 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
3) Report of initial performance test h














a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0

0 $7.50 0 $0 0
b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
4) Report of initial CMS demonstration h See 3.B.5













5) Report prior to construction (includes siting analysis) h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0
6) Report prior to initial start-up h, i


a) Without site specific parameter petition 6 1 6 0 0 0 0 $0

0 $0 0 $0 0
b) With site specific parameter petition 14 1 14 0 0 0 0 $0

0 $0 0 $0 0
7) Report of initial stack test h See 3.B.1


8) Report established values for site-specific operating parameters h See 3.B 1 #VALUE! 0 #VALUE! #VALUE! #VALUE! $0

0 $0 0 $0 0
9) Waste management plan h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0
10) Report of results of annual performance test e 40 1 40 6 240 12 24 $32,697.60

0 $7.50 0 $45 6
11) Status report for operators that are off-site for more than 2 weeks j 8 1 8 0.6 4.8 0.24 0.48 $653.95

0 $0 0 $0 0.6
12) Corrective action summary for operators that are off-site for more than 2 weeks j 8 2 16 0.6 9.6 0.48 0.96 $1,307.90

0 $0 0 $0 1.2
13) Semiannual report of emissions/parameter exceedances k 24 1 24 0.6 14.4 0.72 1.44 $1,961.86

0 $7.50 0 $5 0.6
Subtotal for Reporting Requirements



406 $48,065






4. Recordkeeping Requirements


A. Familiarization with Rule Requirements See 3.A


B. Plan Activities N/A


C. Implement Activities N/A













D. Develop Record System N/A













E. Record Information














1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0

0 $0 0 $0 0
2) Records of periods for which minimum amount of data on operating parameters were not obtained l 0.5 52 26 0 0 0 0 $0

0 $0 0 $0 0
3) Records of malfunction of the unit l 1.5 1 1.5 0 0 0 0 $0

0 $0 0 $0 0
4) Records of exceedances of the operating parameters k 1.5 1 1.5 0.6 0.9 0.05 0.09 $122.62

0 $0 0 $0 0
5) Records of stack tests See 3.E













6) Records of siting analysis See 3.E













7) Records of persons who have reviewed operating procedures 1 1 1 4 4 0.2 0.4 $544.96

0 $0 0 $0 0
8) Records of persons who have completed operator training 1 1 1 4 4 0.2 0.4 $544.96

0 $0 0 $0 0
9) Records of persons whe meet operator qualification criteria 1 1 1 4 4 0.2 0.4 $544.96

0 $0 0 $0 0
10) Records of monitoring device calibration See 3.B


11) Records of site-specific documentation 24 1 24 4 96 4.8 9.6 $13,079.04

0 $0 0 $0 0
F. Personnel Training See 3.B










G. Time for Audits N/A













Subtotal for Recordkeeping Requirements



125 $14,837






Total Labor Burden and Costs (rounded) m
531 $62,900






Total Capital and O&M Cost (rounded) m
$443,000




$443,000
GRAND TOTAL (rounded) m
$506,000






















Assumptions






a We assume an average of 108 CISWI units at 78 existing respondents per year over the next three years. No new units or respondents are anticipated over the next three years. This consists of 27 incinerator units located at 22 incinerator facilities, 22 energy recovery units - solids located at 13 energy recovery - solids facilities, 30 small, remote incinerators located at 26 small, remote facilities, 6 energy recovery units - liquids located at 4 energy recovery - liquids facilities, and 23 waste burning kilns located at 13 waste burning facilities.






b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 We assume that each respondent will re-familiarize with the requirements each year.






d Initial stack testing is performed when a new unit is completed. No new units are expected over the next three years. Operating parameters are established during the initial stack test for a unit.






e Annual stack testing is performed each year. Labor costs are accounted in the Reporting section. Testing costs are due to contractor labor and are accounted for in Capital and O&M Cost section.






f These operator qualification requirements and compliance costs are associated with the startup of a new unit. We assume that all facilities have completed initial monitoring requirements.






g The refresher course and annual review requirements occur each year. CEMS maintenance is performed each year. Annual reporting costs for the CEMS are calculated under the operation and maintenance (O&M) cost section.






h These notifications, reports, and waste management plan are required for newly constructed units. No new units are expected over the next three years.






i We assume that one-third of the facilities will petition for site-specific parameters.






j We assume that 10 percent of the CISWI units at facilities would not have a qualified operator available for more than two weeks at least once a year. We also assume that this required only two corrective action summaries.






k We assume that 10 percent of the CISWI units at facilities would have one exceedance during the year. The rule requires the semiannual report be submitted only in the event of an exceedance. Therefore, only 1 semiannual report is submitted for each emissions/parameter exceedance.






l The standards apply at all times under this regulation. Therefore, no periods of unobtained data or malfunction periods are expected.






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







Sheet 6: Table 1e_ Kilns

Table 1e- Annual Respondent Burden and Cost - Emissions Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal) - Waste-burning Kilns

















Testing, Operation, and Maintenance Costs
Burden item (A)
Person hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Person hours per respondent per year
(C = A x B)
(D)
Respondents per year a
(E)
Technical person- hours per year
(E = C x D)
(F)
Management person hours per year
(E x 0.05)
(G)
Clerical person hours per year
(E x 0.1)
(H)
Total Cost Per year b


Emission Testing Contractor Hours Per Occurrence Non-Labor Costs Per Occurrence Emission Testing Contractor Hours Per Year Total Non-Labor Costs Per Year Total Responses Per Year
1. Applications N/A













2. Surveys and Studies N/A













3. Reporting Requirements














A. Familiarization with Rule Requirements c 1 1 1 13 13 1 1 $1,771.12

0 $0 0 $0 0
B. Required Activities














1) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2 (as required)) d See 3.E.








varies $46,400 0 $0 0
2) Annual stack test and test report (PM, HCl, Opacity, and Fugitive Ash) e See 3.E.10








584 $46,690 0 $1,073,870 0
3) Operator training and qualification














a) Establish and teach operator qualification course f 64 1 64 0 0 0 0 $0

0 $0 0 $0 0
b) Obtain operator qualification f 72 1 72 0 0 0 0 $0

0 $0 0 $0 0
c) Annual refresher course g 12 1 12 13 156 7.8 15.6 $21,253.44


$0 0 $0 0
d) Initial review of site-specific information See 3.B.3.a.








e) Annual review of site-specific information g 8 1 8 13 104 5.2 10.4 $14,168.96

0 $0 0 $0 0
4) Establish operating parameters (maximum and minimum) d 40 1 40 0 0 0 0 $0

Included in B.1. $0 0 $0 0
5) Continuous parameter monitoring (including CEMS)














a) Initial costs f 17 1 17 0 0 0 0 $0

0 $0 0 $0 0
b) Annual costs g 17 1 17 0 0 0 0 $0

0 $128,806 0 $2,962,545 0
C. Create Information See 3.B













D. Gather Information See 3.E













E. Report Preparation














1) Notification of initial performance test h














a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0

0 $0 0 $0 0
2) Notification of initial CMS Demonstration h 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
3) Report of initial performance test h














a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0

0 $7.50 0 $0 0
b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0

0 $0 0 $0 0
4) Report of initial CMS demonstration h See 3.B.5













5) Report prior to construction (includes siting analysis) h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0
6) Report prior to initial start-up h, i


a) Without site specific parameter petition 6 1 6 0 0 0 0 $0

0 $0 0 $0 0
b) With site specific parameter petition 14 1 14 0 0 0 0 $0

0 $0 0 $0 0
7) Report of initial stack test h See 3.B.1


8) Report established values for site-specific operating parameters h See 3.B 1 #VALUE! 0 #VALUE! #VALUE! #VALUE! $0

0 $0 0 $0 0
9) Waste management plan h 160 1 160 0 0 0 0 $0

0 $0 0 $0 0
10) Report of results of annual performance test e 40 1 40 23 920 46 92 $125,340.80

0 $7.50 0 $173 23
11) Status report for operators that are off-site for more than 2 weeks j 8 1 8 2.3 18.4 0.92 1.84 $2,506.82

0 $0 0 $0 2.3
12) Corrective action summary for operators that are off-site for more than 2 weeks j 8 2 16 2.3 36.8 1.84 3.68 $5,013.63

0 $0 0 $0 4.6
13) Semiannual report of emissions/parameter exceedances k 24 1 24 2.3 55.2 2.76 5.52 $7,520.45

0 $7.50 0 $17 2.3
Subtotal for Reporting Requirements



1,499 $177,575






4. Recordkeeping Requirements


A. Familiarization with Rule Requirements See 3.A


B. Plan Activities N/A


C. Implement Activities N/A













D. Develop Record System N/A













E. Record Information














1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0

0 $0 0 $0 0
2) Records of periods for which minimum amount of data on operating parameters were not obtained l 0.5 52 26 0 0 0 0 $0

0 $0 0 $0 0
3) Records of malfunction of the unit l 1.5 1 1.5 0 0 0 0 $0

0 $0 0 $0 0
4) Records of exceedances of the operating parameters k 1.5 1 1.5 2.3 3.45 0.17 0.35 $470.03

0 $0 0 $0 0
5) Records of stack tests See 3.E













6) Records of siting analysis See 3.E













7) Records of persons who have reviewed operating procedures 1 1 1 13 13 0.65 1.3 $1,771.12

0 $0 0 $0 0
8) Records of persons who have completed operator training 1 1 1 13 13 0.65 1.3 $1,771.12

0 $0 0 $0 0
9) Records of persons whe meet operator qualification criteria 1 1 1 13 13 0.65 1.3 $1,771.12

0 $0 0 $0 0
10) Records of monitoring device calibration See 3.B


11) Records of site-specific documentation 24 1 24 13 312 15.6 31.2 $42,506.88

0 $0 0 $0 0
F. Personnel Training See 3.B










G. Time for Audits N/A













Subtotal for Recordkeeping Requirements



408 $48,290






Total Labor Burden and Costs (rounded) m
1,907 $226,000






Total Capital and O&M Cost (rounded) m
$4,040,000




$4,040,000
GRAND TOTAL (rounded) m
$4,270,000






















Assumptions






a We assume an average of 108 CISWI units at 78 existing respondents per year over the next three years. No new units or respondents are anticipated over the next three years. This consists of 27 incinerator units located at 22 incinerator facilities, 22 energy recovery units - solids located at 13 energy recovery - solids facilities, 30 small, remote incinerators located at 26 small, remote facilities, 6 energy recovery units - liquids located at 4 energy recovery - liquids facilities, and 23 waste burning kilns located at 13 waste burning facilities.






b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 We assume that each respondent will re-familiarize with the requirements each year.






d Initial stack testing is performed when a new unit is completed. No new units are expected over the next three years. Operating parameters are established during the initial stack test for a unit.






e Annual stack testing is performed each year. Labor costs are accounted in the Reporting section. Testing costs are due to contractor labor and are accounted for in Capital and O&M Cost section.






f These operator qualification requirements and compliance costs are associated with the startup of a new unit. We assume that all facilities have completed initial monitoring requirements.






g The refresher course and annual review requirements occur each year. CEMS maintenance is performed each year. Annual reporting costs for the CEMS are calculated under the operation and maintenance (O&M) cost section.






h These notifications, reports, and waste management plan are required for newly constructed units. No new units are expected over the next three years.






i We assume that one-third of the facilities will petition for site-specific parameters.






j We assume that 10 percent of the CISWI units at facilities would not have a qualified operator available for more than two weeks at least once a year. We also assume that this required only two corrective action summaries.






k We assume that 10 percent of the CISWI units at facilities would have one exceedance during the year. The rule requires the semiannual report be submitted only in the event of an exceedance. Therefore, only 1 semiannual report is submitted for each emissions/parameter exceedance.






l The standards apply at all times under this regulation. Therefore, no periods of unobtained data or malfunction periods are expected.






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







Sheet 7: Table 2

Table 2 - Average Annual EPA Burden and Cost - Emission Guidelines for Existing Stationary Sources: Emission Guidelines for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal)

(A) (B) (C) (D) (C) (D) (E) (F)
Burden Item EPA person- hours per occurrence Number of Occurrences Per Plant Per Year EPA person- hours per plant per year (C=AxB) Plants per year a Tech Hours Per Year (C=AxB) Management Hours Per Year (D=Cx0.05) Clerical Hours Per Year (E=Cx0.1) EPA Cost Per Year b
Required Activities







A. Observe initial stack tests (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2) c, d 48 0.2 10 0 0 0 0 $0
B. Excess emissions -- Enforcement Activities e 24 0.1 2 108 259 13 26 $14,892.34
C. Report Reviews







1) Review waste management plan and siting analysis c 8 0 0 0 0 0 0 $0
2) Review report submitted prior to initial startup c 2 0 0 0 0 0 0 $0
3) Review initial stack test report c 40 1 40 0 0 0 0 $0
4) Review annual compliance report 8 1 8 108 864 43 86.4 $49,641.12
5) Review semi-annual excess emission and parameter exceedance report e 16 1 16.0 10.8 173 8.6 17.3 $9,928.22
6) Review status reports and corrective action summary for operators off-site f 4 3 12.0 10.8 130 6.5 13 $7,446.17
D. Prepare annual summary report g 200 1 200 1 200 10 20 $11,491.00
TOTAL (rounded) h



1,870 $93,400









Assumptions







a We have assumed an average of 108 CISWI units at 78 facilities over the three-year period of this ICR. We also assume that no new units will become subject during the three-year period of this ICR.
b This ICR uses the following labor rates: $51.23 (technical), $69.04 (managerial), and $27.73 (clerical). These rates are from the Office of Personnel Management (OPM), 2021 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 These are one-time only costs associated with the startup of a new CISWI unit. We assume that no new units will become subject during the three-year period of this ICR.
d We assume that EPA personnel will attend 20 percent of the initial stack tests.
e We assume that 10 percent of the 108 CISWI units have an exceedance during the year.
f We assume that 10 percent of the 108 facilities would not have a qualified operator for more than two weeks at least once a year. We assume that 1 status report and 2 corrective action summaries are submitted and that it takes 4 hours to review each report.
g Once each year, EPA prepares an annual summary report for all of the CISWI units subject to Subpart DDDD.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 8: Labor Rates

Labor Rates:






















INDUSTRY Loaded





























1. Technical - Engineering Technicians, except drafters $122.66





2. Management - General and Operations Managers $149.84





3. Clerical - Office Clerks, General $60.88





4. Contractor - Maintenance $80.00













b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), $60.88 (clerical), and $80.00 (contractor - maintenance). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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.














EPA







With Fringe & Overhead





(GS-12, Step 1, $30.05 + 60%) - Tech. $51.23





(GS-13, Step 5, $40.50 + 60%) - Mgmt. $69.04





(GS-6, Step 3, $16.26 + 60%) - Cler. $27.73





These rates are from the Office of Personnel Management (OPM), 2021 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.







Sheet 9: VE Testing

Visible Emissions Testing Costs



Parameters/Costs
Equation Values Footnotes





A. Parameters




1. Operating labor rate, $/hr (LR)
$45.85 3

2. Capital recovery factor, 5-yr equipment life, 7% interest (CRF) = [i x (1 + i)a] / [(1 + i)a - 1], where i = interest rate, a = equipment life 0.24389





B. Total Capital Investment, $ (TCI)
= Combination light meter/anemometer ($200) + digital stopwatches (2 each at $25) $259 1, 2, 4





C. Direct Annual Costs, $/yr




1. Operating labor = (1 hr/reading) x (3 readings/test) x (1 test/yr) x LR $138





D. Indirect Annual Costs, $/yr




1. Overhead = 0.6 x (operating labor) $83

2. Property taxes, insurance, and administration = 0.04 x TCI $10

3. Capital recovery = CRF x TCI $63





E. Total Annual Cost, $/yr (rounded)
= Direct Annual Costs + Indirect Annual Costs $290





Footnotes



1. Professional Equipment. 2008. Light Meters Industrial and Professional: Digital Light Meter. Website: http://www.professionalequipment.com.



Accessed July 24, 2008.



2. Cole-Parmer. 2008. Digital Stopwatches -Cole Parmer Instrument Catalog. Website: http://www.coleparmer.com. Accessed July 24, 2008.



3. Operating labor rate is updated from 2008 to 4th quarter 2020 using the Bureau of Labor Statistics "Wages and salaries for Private industry workers in All industries and occupations, Index". Source: https://beta.bls.gov/dataViewer/view/timeseries/CIU2020000000000I;jsessionid=9E40EBBD04EA12CF2D755147748CC492



4. Cost of equipment is updated from $2008 to $2020 using the CEPCI Index.




Sheet 10: Stack Testing

Stack Testing Costs







Parameters/Costs
Equation Values













A. Parameters








1. Cost index







a. 2020
596.2





b. 2008
575.4





c. 1992
358.2













B. Testing Costs, $




Annual everything except PM, Hg, HCl, and opacity $46,400 Waste-burning kilns

1. Method 5 (PM) = $8,000 x (596.2/358.2) $13,300

Annual everything: $62,933 Energy recovery units and incinerators

2. Method 9 (opacity) = $1,000 x (596.2/358.2) + $1,500 $3,200





3. Method 10 (CO) = $4,000 x (596.2/358.2) + $1,000 $7,700





4. Method 26 (HCl) = $5,000 x (596.2/358.2) $8,300





5. Method 29 (metals) = $8,000 x (596.2/358.2) + $2,000 $15,300





6. Method 23 (CDD/CDF) = $21,000 x (596.2/358.2) - $5,000 $30,000





7. Method 7E (NOX) = $5,000 x (596.2/358.2) $8,300





8. Method 6C (SO2) = $5,000 x (596.2/358.2) $8,300













Note:







1. Initial testing costs to be annualized over 15 years at 7% interest.







2. Testing costs have been rounded to the nearest $1,000 (except for opacity) to be







consistent with level of rounding in original costs; costs also adjusted based on







additional information from EPA.







3. Multiple test costs adjusted by 2/3 in nationwide cost estimates to account for travel,







accommodations, methods/sampling trains, etc. common to the tests.







4 Stack testing costs have been updatd to $2020 using the CEPCI Index.















Sources:







1. Memorandum from R. Segall, EPA/EMB, to R. Copland, EPA/SDB. October 14, 1992.







Medical Waste Incinerator Study: Emission Measurement and Continuous Monitoring.







(II-B-89)







2. E-mail from Jason Dewees, EPA, to Peter Westlin, EPA. August 20, 2008.







Monitoring Options for SNCR & Test Cost Questions.







3. E-mail from Jason Dewees, EPA, to Mary Johnson, EPA. August 20, 2008.







Re: Monitoring Options for SNCR & Test Cost Questions.












































CRF (15 yr, 7%): 0.10979






Sheet 11: Monitoring

Monitoring Costs

















All model sizes

Parameters/Costs
Equation FF WS SNCR Bag leak detector DIFF CO CEMS HCl CEMS PM CEMS Hg CEMS Multi-metal CEMS Dioxin or Hg sorbent trap biweekly monitoring ACI
















A. Parameters















1. Recording lime/carbon flow, min/4-hr period




5





5

2. Annual operating hours, hr/yr (H)




Author: Used average hours for units requiring DIFF monitoring 8100





6,000 fill in unit-specific annual operating hours here

3. Cost index (CEPCI)














a. 2020
596.2 596.2 596.2 596.2 596.2 596.2 596.2 596.2 596.2 596.2 596.2 596.2

b. 2014
576.1 576.1 576.1 576.1 576.1 576.1 576.1 576.1 576.1 576.1 576.1 576.1

c. 2008
575.4 575.4 575.4 575.4 575.4 575.4 575.4 575.4 575.4 575.4 575.4 575.4

d. 2006
499.6 499.6 499.6 499.6 499.6 499.6 499.6 499.6 499.6 499.6 499.6 499.6

e. 1997
386.5 386.5 386.5 386.5 386.5 386.5 386.5 386.5 386.5 386.5 386.5 386.5

f. 1993
359.2 359.2 359.2 359.2 359.2 359.2 359.2 359.2 359.2 359.2 359.2 359.2

g. 1992
358.2 358.2 358.2 358.2 358.2 358.2 358.2 358.2 358.2 358.2 358.2 358.2

4. Operating labor wage rate, $/hr (LR)
$45.85 $45.85 $45.85 $45.85 Author: in DIFF Monitoring algorithm, labor rate of 51.26 used $45.85 $45.85 $45.85 $45.85 $45.85 $45.85 $45.85 $45.85

5. Capital recovery factor, 20-yr equipment life, 7% interest (CRF) = [i x (1 + i)a] / [(1 + i)a - 1], where i = interest rate, a = equipment life 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439
















B. Total Capital Investment, $ (TCI)















1. Planning
$800 $800 $800 $800 $800 $4,200 $3,500 $1,000 $3,500




2. Select type of equipment
$500 $500 $500 $4,700 $500 $10,400 $16,700 $12,600 $16,700




3. Provide support facilities
$1,500 $1,500 $1,500 $500 $1,500 $21,400 $21,400 $500 $21,400




4. Purchased equipment cost (PEC)
$13,400 $20,100 $5,300 $14,600 $13,400 $50,100 $53,800 $76,100 $113,800




5. Install and check equipment
$1,100 $1,100 $1,100 $5,000 $1,100 $18,900 $20,000 $20,200 $22,300




6. Perf. spec. tests (certif.)
$800 $800 $800 $0 $800 $16,200 $13,200 $36,800 $43,800




7. Prepare QA/QC plan
$800 $800 $800 $800 $800 $18,100 $18,100 $16,000 $18,100




8. Total capital cost = Planning + selecting equipment + support facilities + PEC + installation + perf. spec. tests + QA/QC plan $18,900 $25,600 $10,800 $26,400 $18,900 $139,000 $147,000 $163,000 $240,000 $239,000 $119,000

















C. Annual Costs, $/yr















1. Operating labor = (5 min to record lime/carbon flow/4-hr period) x (1 hr/60 min) x H x LR



$7,700





$5,700

2. Maintenance materials = 0.02 x TCI $400 $500 $200
$400








3. Operation & maintenance = Day-to-day activities + annual RATA + CGA + annual QA + O&M review and update


$6,000
$28,600 $25,500 $28,300 $80,900




4. Recordkeeping and reporting = $1,000 x (596.2/386.5) $1,500 $1,500 $1,500 $200 $1,500 $1,200 $1,700 $6,600 $1,700




5. Overhead = 0.6 x (labor + maintenance materials) $200 $300 $100
$4,900





$3,400

6. Property taxes, insurance, and administration = 0.04 x TCI $800 $1,000 $400
$800








7. Capital recovery = CRF x TCI $1,800 $2,400 $1,000 $3,600 $1,800 $13,100 $20,900 $23,300 $34,100




8. Total annual cost = Operating labor + maintenance materials + recordkeeping and reporting + overhead + property taxes, insurance, and administration + capital recovery $4,700 $5,700 $3,200 $9,800 $17,100 $42,900 $48,100 $58,200 $116,700 $65,600 $43,000 $9,100




all all all


ERUs (capacity > or = 250 mmBtu/hr) cement kilns

all
Notes:












1. Monitoring costs have been rounded to the nearest $100 to be consistent with level of rounding in original costs.














2. Costs to be replaced include: (a) bag leak detector replacing opacity test; (b) CO CEMS replacing CO test and secondary chamber temperature monitor;














(c) HCl CEMS replacing HCl test, HCl sorbent monitor (dry scrubbers) and scrubber liquor pH monitor (wet scrubbers); (d) PM CEMS replacing PM and














opacity tests and and pressure drop monitor (wet scrubbers); (e) multi-metal/Hg CEMS replacing flue gas temperature monitor (wet scrubbers); (f) dioxin














sorbent trap biweekly monitoring replacing fabric filter inlet temperature monitor; and (g) Hg sorbent trap biweekly monitoring replacing flue gas temperature














monitor (wet scrubbers).














3. Costs have been updated to $2020 using the CEPCI Index














4. Operating labor rate is updated from 2008 to 4th quarter 2020 using the Bureau of labor Statistics "Wages and salaries for Private industry workers in All industries and occupations, Index". Source: https://beta.bls.gov/dataViewer/view/timeseries/CIU2020000000000I;jsessionid=9E40EBBD04EA12CF2D755147748CC492 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Verify you are using 2020 Q4 - link I checked shows 142.6 as correct value. You appear to be using 144.6 for 2021 Q1






























Sources:














1. Hospital/Medical/Infectious Waste Incinerators (HMIWI) [EPA-HQ-OAR-2006-0534] Testing and Monitoring Options and Costs Memo (IV-B-66).














2. E-mail and attachment from Peter Westlin, EPA, to Mary Johnson, EPA. August 19, 2008. Monitoring Options for SNCR on Medical Waste Incinerators.














3. E-mail from Dan Bivins, EPA, to Mary Johnson, EPA. September 27, 2006. Cost of CO CEMS.














4. E-mail from Dan Bivins, EPA, to Mary Johnson, EPA. July 28, 2006. Some Preliminary Thoughts on the HWI Monitoring.















Sheet 12: Subcat Inputs

Existing Unit Inputs Incinerators Energy recovery units - Solids Small, remote incinerators Energy recovery units - Liquid/Gas Waste-burning kilns




Prior Values (from 2014 ICR) Incinerators Energy recovery units - Solids Small, remote incinerators Energy recovery units - Liquid/Gas Waste-burning kilns

Number of Units 27 22 30 6 23
108


Number of Units 3 22 28 6 23
82
Number of Facilities 22 13 26 4 13
78


Number of Facilities 3 13 24 4 13
57
Total Initial Stack Test Cost $1,699,200 $1,384,533 $1,888,000 $377,600 $1,067,200












Average Initial Stack Test Cost $62,933 $62,933 $62,933 $62,933 $46,400












Additional Monitoring Inputs












Number of Bag Leak Detectors: 18 4 24 4 5




Number of Bag Leak Detectors: 2 4 22 4 5

Number of DIFF Monitors 0 11 0 0 0




Number of DIFF Monitors 0 11 0 0 0

Number of PBS Parameter Monitors: 0 11 0 0 18




Number of PBS Parameter Monitors: 0 11 0 0 18

Number of SNCR Monitors: 9 0 0 2 1




Number of SNCR Monitors: 1 0 0 2 1

Number of CO CEMS: 0 0 0 0 0




Number of CO CEMS: 0 0 0 0 0

Number of PM CEMS or PM CPMS: 0 16 0 1 23




Number of PM CEMS or PM CPMS: 0 16 0 1 23

Number of Opacity Monitors: 0 0 0 5 0




Number of Opacity Monitors: 0 0 0 5 0

Number of Oxygen Monitors: 0 22 0 0 0




Number of Oxygen Monitors: 0 22 0 0 0

Number of Hg CEMS: 0 0 0 0 23




Number of Hg CEMS: 0 0 0 0 23

Number of ACI Monitors: 27 15 24 0 22




Number of ACI Monitors: 3 15 22 0 22

Average Cost of ACI Monitoring: $8,590 $13,702 $1,138 $0 $7,611




Average Cost of ACI Monitoring: $8,300 $13,240 $1,100 $0 $7,355

Note: Stack testing costs have been updated from $2008 to $2020 using the CEPCI Index.

















Note: ACI Monitoring costs have been updated from $2014 to $2020 using the CEPCI Index.























































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, (ExF)











Annual stack test











- Incinerator NA 0 0 $63,223 27 $1,707,030











- ERU, solid NA 0 0 $63,223 22 $1,390,913











- small remote incinerator NA 0 0 $63,223 30 $1,896,700











- ERU, liquid NA 0 0 $63,223 6 $379,340











- waste-burning kiln NA 0 0 $46,690 23 $1,073,870











CMS











- Incinerator NA 0 0 $13,456 27 $363,319











- ERU, solid NA 0 0 $46,078 22 $1,013,723











- small remote incinerator NA 0 0 $5,871 30 $176,121











- ERU, liquid NA 0 0 $10,683 6 $64,100











- waste-burning kiln NA 0 0 $128,806 23 $2,962,545











Photocopy and postage











- annual report NA 0 0 $8 108 $810











- semiannual report NA 0 0 $8 10.8 $81











TOTAL




$11,000,000











Note: Stack testing and CEMS costs have been updated from $2008 to $2020 using the CEPCI Index.

















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