2164ss03(revised)

14

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal), EPA ICR Number 2164.03, OPM Control Number 2060-0562

1(b) Short Characterization/Abstract

NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF), was promulgated on December 16, 2005 (70 FR 74892) and amended on November 24, 2006 (71 FR 67806). This standard applies to any air quality program in a state or United States protectorate with one or more existing other solid waste incineration (OSWI) units or air curtain incinerators that commenced construction on or before December 9, 2004. This subpart does not directly affect incineration unit owners and operators; however, they must comply with the state’s plan that was developed by the air quality program administrator to implement the emission guidelines. If a state does not develop, adopt, and submit an approvable state plan, the Environmental Protection Agency must develop a Federal plan. The regulated OSWI units include two subcategories: very small municipal waste combustion (VSMWC) units that combust less that 35 tons per day of waste, and institutional waste incineration (IWI) units.

In general, all New Source Performance Standards (NSPS) require initial notifications, performance tests, one-time and periodic reports. For this Information Collection Request (ICR), other activities, such as emissions testing operator training, monitoring of operating parameters, annual operator training, and annual reporting do not occur until five years after promulgation. In addition, they are required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports and records are essential in determining compliance, and are required of all affected facilities subject to the NSPS.

Any owners or operators of OSWI facilities are required to maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority. In the event that there is no such delegated authority, the reports are sent directly to the United States Environmental Protection Agency (EPA) regional office.

Approximately 248 respondents are subject to the regulation. This standard applies to OSWI units that commenced construction on or before December 9, 2004. Therefore, there will be no new units constructed during the period covered by this ICR.

The experience of EPA with the Clean Air Act (CAA) section 129 regulations has shown that sources sometimes respond to the emission guidelines by choosing to shutdown existing waste incineration units and utilize alternative waste disposal options rather that incur the costs of compliance. Based on the information gathered including the results of our consultations, we have concluded that to date, alternative work disposal options have not been pursued by the facilities subject to this subpart. Therefore, the number of respondents remains at 248.

All of the other solid waste incineration (OSWI) units in the United States are owned and operated by the solid waste incineration industry (the “Affected Public”). However, this ICR applies directly to the emission guidelines with most of the units regulated by either, state, local, tribal or the Federal government. They are considered not-for-profit businesses. The burden to the “Affected Public” is listed in Table 1: Annual Industry Burden and Cost - NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal). The Federal government burden associated with the review of reports submitted by the respondent is shown in Table 2: Average Annual EPA Burden – NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 111(d)(1) of the Clean Air Act (CAA), as amended, to:

. . . prescribe regulations which shall establish a procedure similar to that provided by section 110 under which each State shall submit to the Administrator a plan which (A) establishes standards of performance for any existing source for any air pollutant (i) for which air quality criteria have not been issued or which is not included on a list published under section 108(a) . . . but (ii) to which a standard of performance under this section would apply if such existing source were a new source, and (B) provides for the implementation and enforcement of such standards of performance.

The EPA is required under section 129 of the Act, to establish guidelines for existing stationary sources that reflect the maximum achievable control technology (MACT) for achieving continuous emission reductions:

Section 129(a)(1)(A) states:

The Administrator shall establish performance standards and other requirements pursuant to section 111 and this section for each category of solid waste incineration units. Such standards shall include emissions limitations and other requirements applicable to new units and guidelines (under section 111(d) and this section) and other requirements applicable to existing units.

Section 129(a)(2) states:

Standards applicable to solid waste incineration units promulgated under section 111 and this section shall reflect the maximum degree of reduction in emissions of air pollutants listed under section (a)(4) that the Administrator, taking into consideration the cost of achieving such emission reduction, and any non-air quality health and environmental impacts and energy requirements, determines is achievable for new or existing units in each category.

Section 129(b)(1) states:

Performance standards under this section and section 111 for solid waste incineration units shall include guidelines promulgated pursuant to section 111(d) and this section applicable to existing units. Such guidelines shall include, as provided in this section, each of the elements required by subsection (a) (emissions limitations, notwithstanding any restriction in section 111(d) regarding issuance of such limitations), subsection (c) (monitoring), subsection (d) (operator training), subsection (e) (permits), and subsection (h)(4) (residual risk).

Subpart B of 40 CFR part 60 requires state plans to include monitoring, recordkeeping, and reporting provisions consistent with the emission guidelines. In addition, section 114(a)(1) states that:

the Administrator may require any person who owns or operates any emission source, who manufactures emission control equipment or process equipment, who the Administrator believes may have information necessary for the purposes set forth in this subsection, or who is subject to any requirement of this Act (other than a manufacturer subject to the provisions of section 206(c) or 208 with respect to a provision of title II) on a one-time, periodic or continuous basis to -

(A) establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods and in such manner as the Administer shall prescribe);

(E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical;

(F) submit compliance certifications in accordance with section 114(a)(3); and (G) provide such other information, as the Administrator may reasonably require; . . . .

In the Administrator's judgment, emissions from other solid waste incineration units cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart FFFF.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. In addition, the collected information is used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart FFFF.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. If a state or local agency has adopted their own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (73 FR 31088) on May 30, 2008. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 248 respondents will be subject to the standard over the three-year period covered by this ICR.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. For this renewal, we contacted the National Solid Waste Management Association (NSWMA), Mr. Edward Repa at (202) 364-3773, and the Solid Waste Association of North America (SWANA), Mr. Chris Hurwitz at (240) 494-2253. Mr. Hurwitz consulted with a number of SWANA members for additional information on this industry.

It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the First Federal Register Notice.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance, and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond the five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are other solid waste incineration units. The North American Industry Classification System (NAICS) code, are listed below for source category description.

Standard (40 CFR, part 60, subpart FFFF)	NAICS Codes
Solid Waste Combustors and Incinerators	562213
Administration of Air and Waste Resource and Solid Waste Management Programs	92411
Nursing and Residential Care Facilities	623
Justice, Public Order, and Safety Activities	922
National Security and International Affairs	928
Elementary and Secondary Schools	6111
Junior Colleges	6112
Colleges, Universities, and Professional Schools	6113
Museums, Historical Sites, and Similar Institutions	7121
Religious Organizations	8131
Civic and Social Organizations	8134

4(b) Information Requested

None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i) Data Items

In this ICR, all the data recorded or reported is required by the Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF).

A source must make the following reports:

Notifications
Initial performance test and report	60.3049, 60.8(a)
Waste management plan	60.3010, 60.3011, 60.3012
Annual test report	60.3050, 60.3051
Notification of operating limit deviation report	60.3052 and 60.3053
Notification of deviation	60.3054(a)(1)
Notification of status report	60.3054(a)(2)
Notification of resumed operation	60.3054(b)

Reports
Annual compliance report	60.3050
Semiannual report of deviation	60.3052

A source must keep the following records:

Recordkeeping
Maintain records of all test reports	60.3068(a)
Records are required to be retained for five years	60.3068(e)
Maintain waste management plan records	60.3010

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.

Also, regulatory agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically. However, electronic reporting systems are not widely used. At this time, it is estimated that 10 per cent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate a coil coating line at their metal coil surface coating plants.

Perform initial performance test, Reference Methods, 3A, 3B, 26A tests, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.

Adjust the existing ways to comply with any previously applicable instructions and requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that provides parameter data in an automated way (e.g., continuous parameter monitoring system). Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping.

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the OTIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properly installed and operational. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.

Information contained in the reports is entered into OTIS which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses OTIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner or operator for five years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in Table 1: Annual Industry Burden - NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal), attached.

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 176,576 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $111.43 ($53.04 + 110%)

Technical $94.33 ($44.92 + 110%)

Clerical $45.28 ($21.56 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics March 2008 “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs, such as photocopying and postage.

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

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/ Startup Cost for One Respondent 1	(C) Number of New Respondents	(D) Total Capital/ Startup Cost (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Continuous emission monitoring system	$14,815	248	$3,674,120	$5,000	248	$1,240,000
			$3,674,120			$1,240,000

1. The one-time-only capital cost for CEM equipment for each respondent is estimated to be $44,445. Therefore, the cost for each respondent over the three-year period of this ICR would be $14,815 ($44,445/3 years).

The total capital/startup costs for this ICR are $3,674,120. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs consists of photocopying, postage, and the CEM monitor with the major cost going towards the maintenance of the CEM monitors are $1,240,000. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $4,914,120.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. The EPA compliance and enforcement program includes activities such as: the examination of records maintained by the respondents; periodic inspection of sources of emissions; and the publication and distribution of collected information.

The term Agency in the ICR refers to the designated Administrator of each state plan or to the U.S.EPA Administrator in the event that a State plan is not approved.

The average annual Agency cost during the three years of the ICR is estimated to be $935,153.

This cost is based on the average hourly labor rate as follows:

Managerial $59.63 (GS-13, Step 5, $37.27 + 60%)

Technical $44.24 (GS-12, Step 1, $27.65 + 60%)

Clerical $23.94 (GS-6, Step 3, $14.96 + 60%)

These rates are from the Office of Personnel Management (OPM) “2008 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. Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden, Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal), attached.

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately 248 respondents will be subject to the standard the next three years. It is estimated that no additional sources per year will become subject to the standard. The average number of respondents, as shown in the table below, is 248 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR.

Number of Respondents
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	248	0	0	248
2	0	248	0	0	248
3	0	248	0	0	248
Average	0	248	0	0	248

¹ New respondents include sources with constructed, reconstructed and modified affected facilities.

To avoid double-counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three-year period of this ICR is 248.

The total number of annual responses per year is calculated using the following table:

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of final compliance	82.7	0	0	0
Initial compliance report	82.7	0	0	0
Waste management plan	82.7	0	0	0
Annual compliance reports	248	2	0	496
Semiannual deviation reports	248	1	0	248
			Total	744

The number of Total Annual Responses is 744.

The total annual labor costs are $15,941,351. Details regarding these estimates may be found in Table 1: Annual Industry Burden and Cost - NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal), attached.

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor costs are $15,941,351. Details regarding these estimates may be found in Table 1: Annual Respondent Burden and Cost - NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal), attached. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 237 hours (rounded) per response.

The total annual capital/startup and O&M costs to the regulated entity are $4,914,120.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 21,675 labor hours at a cost of $935,153. See Table 2: Annual Agency Burden and Cost - NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal), attached.

6(f) Reasons for Change in Burden

There is an adjustment increase in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes. The change in the burden and cost estimates occurred because the compliance date for this ICR is five years after the emission guidelines are promulgated, therefore, most of the testing, monitoring, reporting and recordkeeping activities were not included in the first three years covered by the previous ICR.

There are capital/startup and operating and maintenance (O&M) costs of $4,914,120 associated with this ICR, as compared with zero costs in the previous ICR. This is attributed to the fact that the compliance date for this ICR is five years after the promulgation date, thus, creating the increase.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 237 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OECA-2008-0291. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the content of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Enforcement and Compliance Docket and Information Center Docket is (202) 566-1927. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2008-0291 and OMB Control Number 2060-0562 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.

Table 1: Annual Respondent Burden and Cost – NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)

Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Read instructions c	40	1	40	0	0	0	0	$0
B. Required activities
1) Initial performance test and reports
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) c, d	24	1	24	0	0	0	0	$0
b) Repeat of initial performance tests d, e	24	1	24	0	0	0	0	$0
2) CEMS demonstration (CO, 02)
a) Repeat of initial demonstration e	229	1	229	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)	24	1	24	248	5,952	297.6	595.2	$621,564.39
4) Quarterly Appendix F audits of CEMS (CO)
a) RATA audit (one per year) f	4	1	4	248	992	49.6	99.2	$103,594.07
b) RAA audit (three per year) f	4	3	12	248	2,976	148.8	297.6	$298,647.15
c) Daily calibration and operation f, g	1	250	250	248	62,000	3,100	6,200	$6,474,629.00
C. Create information	See 3B
D. Gather information	See 3E
E. Report preparation
1) Contract or secure alternative means of disposal d	40	1	40	0	0	0	0	$0
2) Notification of final compliance c, d	1.5	1	1.5	0	0	0	0	$0
3) Initial compliance report c, d	40	1	40	0	0	0	0	$0
4) Waste management plan c, d	40	1	40	0	0	0	0	$0
5) Annual compliance reports	40	1	40	248	9,920	496	992	$1,035,940.64
6) Semiannual deviation reports	24	2	48	248	11,904	595.2	1,190.4	$1,243,128.77
Subtotal for Reporting Requirements						107,805.6
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities	See 3B
C. Implement Activities	See 3B
D. Develop record system	N/A
E. Record information
1) Records of SSM h	1.5	52	78	248	19,344	967.2	1,934.4	$2,020,084.25
2) Records of emission rate computations, all emission exceedances and periods when there is no data h	1.5	52	78	248	19,344	967.2	1,934.4	$2,020,084.25
3) Records of employee review of operations manual	4	1	4	248	992	49.6	99.2	$103,594.07
4) Record of control devices operating parameters h	1.5	52	78	248	19,344	967.2	1,934.4	$2,020,084.25
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements						68,770.04
								$15,941,350.84
TOTAL LABOR BURDEN AND COST (rounded)						176,576		$15,941,351

Assumptions:

^a We have assumed that there are approximately 248 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. ^b This ICR uses the following labor rates: $111.43 per hour for Executive, Administrative, and Managerial labor; $94.33 per hour for Technical labor, and $45.28 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2008 “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

^c We have assumed that this is a one-time only cost.

^d This is the fifth year when a respondent will have reached the compliant date for the emission guidelines.

^e We have assumed that 20 percent of respondents will repeat initial tests due to failure.

^f We have assumed that RATA audits are performed for one of the four quarterly audits, and RAA tests are performed for three of the four quarterly audits.

^g We have assumed that each operation day requires a CEMS calibration; Combustor models 2, 3, and 4 assume 250 days of operation per year, Model 1 = 121 days/yr. For consistency, 250 operating days are assumed for all models. Emission testing hours (0.25 hr/occurrence) accounts for periodic contractor operation and maintenance support. Annual hours averaged to a daily basis.

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

Table 2: Average Annual Designated Administrator Burden – NSPS for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)

Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
1. Applications	N/A
2. Read and understand rule requirements	16	1	16	0	0	0	0	$0
3. Required activities
A. Create information	N/A
B. Gather information	See 3A & 3F
C. Report reviews
1) Notification of final compliance d	1.5	1	1.5	0	0	0	0	$0
2) Review initial compliance test report d	40	1	40	0	0	0	0	$0
3) Review annual compliance report	40	1	40	248	9,920	496	992	$492,185.76
4) Review semiannual deviation reports	16	2	32	248	7,936	396.8	793.6	$393,748.60
5) Review waste management plan d	16	1	16	0	0	0	0	$0
D. Annual summary report e	4	1	4	248	992	49.6	99.2	$49,218.58
Subtotals Labor Burden and cost					18,848	942.4	1,884.8	$935,152.94
TOTAL ANNUAL BURDEN AND COST (rounded)					21,675.2 21,675 (rounded)			$935,153

Assumptions:

^a Designated Administrator refers to the person indicated by each State plan as the compliance authority or to the USEPA Administrator in the event that a Federal

plan must be developed.

^b We have assumed that there are approximately 248 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. For the purpose of the burden calculation, we are averaging the number of respondents over the three years period of this ICR. In year two and three of this ICR all respondents will have reached the compliant date for the emission guidelines, which is five years after promulgation.

^c This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $59.63 for Managerial (GS-13, Step 5, $37.27 x 1.6), $44.24 for Technical (GS-12, Step 1, $27.65 x 1.6) and $23.94 Clerical (GS-6, Step 3, $14.96 x 1.6). These rates are from the Office of Personnel Management (OPM) “2008 General Schedule” which excludes locality rates of pay.

^d We have assumed that this is a one-time only cost.

^e We have assumed that all affected facilities in the states will be required to prepare an annual summary plan.