1847ss05

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SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR part 60, subpart Cb)

1. Identification of the Information Collection - Renewal

1(a) Title of the Information Collection

Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR part 60, subpart Cb), EPA ICR Number 1847.05, OMB Control Number 2060-0390.

1(b) Short Characterization/Abstract

The emission guidelines for large municipal waste combustors are published at 40 CFR part 60, subpart Cb. The rule was proposed on September 20, 1994 (59 FR 48198) and was promulgated on December 19, 1995 (60 FR 65382). The subpart Cb emission guidelines apply to all municipal waste combustion (MWC) units with a combustion capacity greater than 250 tons per day of municipal solid waste (large MWC units) for which construction of the unit was commenced on or before September 20, 1994.

Under the authority of Clean Air Act (CAA) sections 111 and 129, EPA required states to submit plans to the EPA, detailing how they would implement and enforce the CAA emission guidelines (40 CFR part 60, subpart Cb) for large MWCs. Because the subpart Cb emission guidelines are not directly federally enforceable, CAA section 129 also required EPA to develop and promulgate a Federal plan (40 CFR part 62, subpart FFF) to implement and enforce the emission guidelines in States that had not submitted an approvable plan to EPA. The State plans were due to be submitted to EPA by December 19, 1996. The reporting and recordkeeping requirements discussed below result from the emission guidelines that apply to large MWCs covered by EPA-approved and effective State plans and, where a State plan has not been approved, large MWCs covered by the Federal plan. Separate burden tables are provided for (1) large MWCs subject to State plans, (2) large MWCs subject to the Federal plan, and (3) combined burden of State and Federal plans. Separate burden tables are also provided for the “designated administrator” that reviews and analyzes the reported information.

The emission guidelines require initial notifications, performance tests, and periodic reports. Owners or operators of large MWCs also 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. Owners or operators of large MWCs must maintain all files for least five years.

Approximately 162 large MWCs located at 63 MWC plants in 22 States are subject to the emission guidelines through State plans or the Federal plan. Of the 63 large MWC plants, 55 are located in States with State plans and eight are located in States without State plans and thus are subject to the Federal plan. Forty-nine percent of large MWC plants are privately owned.

Terms of Clearance

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 CAA section 129, 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, CAA 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 section 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;. . . .

Section 129 of the CAA directs that the emissions guidelines for MWCs must include emissions limits for particulate matter, opacity, sulfur dioxide, hydrogen chloride, oxides of nitrogen, carbon monoxide, lead, cadmium, mercury, and dioxins and dibenzofurans. The 40 CFR part 60, subpart Cb emission guidelines address all of these pollutants.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure compliance with the applicable regulations that where promulgated in accordance with the CAA. The collected information is also 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 standards. Continuous emission monitors are used to ensure compliance with the standards at all times. During the performance test, 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 standards 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 check if the pollution control devices are properly installed and operated and the standards are being met. The performance test may also be observed.

The required reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and to determine compliance.

3. Nonduplication, Consultations, and Other Collection Criteria

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

3(a) Nonduplication

If an MWC is subject to an approved State plan, the information is sent directly to the State or local agency. If an MWC is subject to the Federal plan, the information is sent directly to EPA Regional Office. 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 (74 FR 36696, July 24, 2009). No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Office of Air Quality Planning and Standards (OAQPS) has maintained a facility inventory for large MWCs. This information is current as of May 2009. We are able to rely on the information from the facility to obtain information on the universe of sources subject to the standard in order to estimate the burden of the emission guidelines on industry.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that large MWCs 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

Subpart Cb requires annual reporting of information for MWCs experiencing normal operations and semiannual reporting for MWCs that experience non-compliance during a semiannual period. These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 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, to observe 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 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 (see 40 CFR part 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

The reporting or recordkeeping requirements in the standard do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are large municipal waste combustors. The SIC codes (and associated North American Industry Classification System (NAICS) codes) for possible respondents affected by the standards are listed in the table below.

Standard	SIC Codes	NAICS Codes
40 CFR part 60, subpart Cb 40 CFR part 62, subpart FFF	9511, Air and Water Resource and Solid Waste Management	92411, Air and Water Resource and Solid Waste Management
	4953, Refuse Systems	562213, Solid Waste Combustors and Incinerators

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the emission guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR 60, Subpart Cb).

A source must make the following reports:

Reports for Facilities Affected by 40 CFR part 60, subpart Cb
Notification of completion of each increment of progress, including final control plan.	62.14108; 62.14109(e), (f), (g), (h), (m)
Notification of exemptions, including alternatives, limitations, cease operations, and de-rating requests.	60.32b(b), 62.14102(c), (d)-(f), (i), (j), (l); 62.14108(b)(4); 62.14109(j)-(l); 60.59(b)(l)
Notification of initial performance tests (PM, dioxin/furan, opacity, HCl, Cd, Pb, Hg, fugitives).	60.8(d)
Report initial performance tests for all regulated pollutants and parameters.	60.59b(f), 62.14109(c)
Report of Continuous Emissions Monitoring System (CEMS) demonstration and test data.	60.59b(f)(3), 62.14109(a)
Annual compliance reports for all pollutants and parameters.	60.59b(g)
Develop and update annually site-specific operating manual	62.14105(e)
Training records	62.14105(g)
Semiannual excess emission reports (SO2, CO, load, temperature, PM, dioxin/furan, opacity, HCl, Cd, Pb, Hg, fugitives).	60.59b(h)

A source must keep the following records:

Recordkeeping for Facilities Affected by 40 CFR part 62, subpart FFF
Records of CEMS concentration rates and parameters and computations of average emissions and parameters.	60.59b(d), (m); 62.14109(a)
Records of initial performance tests and annual performance tests, including final control plan.	60.59b(d)-(e); 62.14109(a), (i)
Records of results of daily CEMS drift tests and Appendix F accuracy assessments.	60.59b(d)(8), 62.14109(a)
Records of the occurrence and duration of any startup, shutdown, or malfunction of the facility or any malfunction of the CEMS.	60.59b(d), (n), (o)
Records of quarterly amount of sorbent used for Hg control.	60.59b(d), 62.14109(a)
Records of names of persons who have completed review of operating manual.	60.59b(d)(13), 62.14105(g), 62.14109(a)
Records are required to be retained for 5 years at the facility.	60.59b(d)-(f), (j)-(k); 62.14109(a)

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 still not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate continuous emissions monitoring systems for sulfur dioxide, nitrogen oxides, opacity, carbon monoxide, load level, temperature of the fuel gas stream, and oxygen or carbon dioxide.

Perform initial performance test, applicable Reference Methods test, 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.

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

5(a) Agency Activities

The designated administrator (EPA or State) 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, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority can inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and are submitted annually. Semiannual reports are required for non-compliance MWCs.

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

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

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses) affected by this regulation.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in Tables 1A, 2A, 1B, 2B, 1C and 2C. Large MWC units subject to State plans or the Federal plan have already completed initial performance tests and CEMS demonstrations. The remaining tasks for large MWC units include annual performance tests and compliance reports, records of quarterly CEMS audits, and continuous recordkeeping as indicated in the tables.

6. Estimating the Burden and Cost of the Collection

This supporting statement contains nine tables that are subdivided into three groups. The “1” series tables present the burden for privately-owned MWCs, the “2” series tables present the burden for publicly-owned MWCs, and the “3” series table present the burden for state agencies (delegated administrators) implementing Subpart Cb. Each of these series is then subdivided into an “A,” “B,” or “C” subset. The “A” subset is the burden for MWCs subject to the approved State plans, the “B” series of tables is the burden for MWCs subject to the Federal plan, and the “C” series is the combined burden for MWCs subject to either approved State plans or the Federal plan (A+B=C). As an example, table 2B is the burden for publicly-owned MWCs subject to the Federal plan. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

6(a) Estimating Respondent Burden

The respondent burden includes recordkeeping and reporting costs to industry associated with complying with either the Federal plan or a State plan. Tables 1A, 1B, and 1C document the information collection activities for private industry owners of MWCs; Tables 2A, 2B, and 2C document the information collection activities for the public sector owners of MWCs. In addition, these tables include the recordkeeping and reporting burden for emission testing contractors to conduct annual performance tests. The hour estimates are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience in developing emissions guidelines, the previously approved ICR, and any comments received.

State/local/Tribal government burden and costs were developed as part of the respondent burden. Table 3A documents the overall required activities for the designated administrator to review and analyze the reported information. For MWCs subject to State plans, the designated administrator is administrator of the State/local/Tribal air pollution authority.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

For industry respondents, this ICR uses the following labor rates:

Managerial $106.68 ($48.49 + 120%)

Technical $101.60 ($46.18 + 120%)

Clerical $50.03 ($22.74 + 120%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2008, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 120 percent to account for the overhead and benefit packages available to those employed by private industry.

For public sector owner (State/local/Tribal government-owned) respondents, this ICR uses the same labor rates as the EPA designated administrator as presented in Section 6(c).

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

The type of industry costs associated with the information collection activities in the subject standards 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 monitors and other costs such as photocopying and postage.

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

Tables 1C and 2C include the costs to install and maintain continuous emission monitors for MWCs. The total capital/startup costs for this is zero. Respondents have already incurred capital and startup costs, as listed in tables 1C and 2C, to purchase and install continuous monitors and no new sources are expected.

The operation and maintenance (O&M) costs for MWCs for this ICR are $1,555,200. This is the total of column G in the following table.

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Source (i.e., Affected Facility)	(C) Number of New Sources	(D) Total Capital/Startup Cost (B X C)	(E) Annual O&M Costs for One Source	(F) Number of Sources with O&M	(G) Total O&M (E x F)
Private sector- Load monitors, temperature monitors, and carbon feedrate monitors.	$100,000	0	$0	$9,600	80	$768,000
Public sector -Load monitors, temperature monitors, and carbon feedrate monitors.	$100,000	0	$0	$9,600	82	$787,200

6(c) Estimating Agency Burden and Cost

The only costs to EPA are those costs associated with analysis of the reported information. EPA’s overall 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.

Tables 3A, 3B, and 3C include the burden to the “designated administrator” to review and analyze the reported information. For MWCs subject to State plans, the designated administrator is administrator of the State/local/Tribal air pollution authority. For MWCs subject to the Federal plan, the designated administrator is the Administrator of the U.S. EPA. Table 3A documents the burden for the State/local/Tribal designated administrator and Table 3B documents the burden for the U.S. EPA Administrator or her representative.

This ICR uses the following labor rates for the both the EPA and State/local/Tribal designated administrator respondents:

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) Salary Table 2008-GS Schedule, which excludes locality rates of pay.

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

Based on our research for this ICR, for each of the next three years, approximately 63 MWC plants (162 individual MWC units) will be subject to the emission guidelines. No additional respondents are expected to become subject to the emission guidelines. The overall average number of respondents, as shown in the table below is 81, which comprises 31 privately owned MWCs, 32 publicly owned MWCs, and 18 State designated administrators.

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	(B) Number of Existing Private Sector Respondents	(C) Number of Existing Public Sector Respondents	(D) Number of State Designated Administrator Respondents	(E) Number of Respondents (E=A+B+C+D)
1	0	31	32	18	81
2	0	31	32	18	81
3	0	31	32	18	81
Average		31	32	18	81

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
Privately owned large MWCs
Increments of Progress (Plant Control Plan, notifications, etc.)	0	3	0	0
Initial Testing Notifications and Reports (Performance Test, CEMS Demonstration, etc.)	0	4	0	0
Annual Performance Tests and Reports	31	1	0	31
Annual Compliance Reports	31	1	0	31
Semiannual Excess Emission Reports	6	2	0	12
Subtotal				74
Publicly owned large MWCs
Increments of Progress (Plant Control Plan, notifications, etc.)	0	3	0	0
Initial Testing Notifications and Reports (Performance Test, CEMS Demonstration, etc.)	0	4	0	0
Annual Performance Tests and Reports	32	1	0	32
Annual Compliance Reports	32	1	0	32
Semiannual Excess Emission Reports	7	2	0	14
Subtotal				78

For privately owned MWCs, the total number of annual responses is 74 and the number of respondents is 31. Thus, the annual frequency is 2.39 responses per respondent per year.

For privately owned MWCs, reporting hours total 154,748 hours and the number of responses is 74. Thus, the hours per reporting response is 2091.2 hours per response. Recordkeeping hours total 36,206 hours and the number of responses is 74. Thus, the hours per recordkeeping response is 489.24 hours per response.

For privately owned MWCs, the total annual capital/startup and O&M (non-labor) costs for reporting are $768,000. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. The reporting cost per response is $10,378. There are no non-labor costs for recordkeeping.

For publicly owned MWCs, the total number of annual responses is 78 and the number of respondents is 32. Thus, the annual frequency is 2.44 responses per respondent per year.

For publicly owned MWCs, reporting hours total 163,851 hours and the number of responses is 78. Thus, the hours per reporting response is 2,100.65 hours per response. Recordkeeping hours total 37,113 hours and the number of responses is 78. Thus, the hours per recordkeeping response is 475.81 hours per response.

For publicly owned MWCs, the total annual capital/startup and O&M (non-labor) costs to the regulated entities are $787,200. These costs are included in the Cost per Response and Total Annual Cost Burden. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. The reporting cost per response is $10,092.31. There are no non-labor costs for recordkeeping.

For designated administrators that enforce State plans, the total number of annual responses is 77 and the number of respondents is 18. Thus, the annual frequency is 4.28 responses per respondent per year.

For designated administrators that enforce State plans, reporting hours total 3,036 hours and the number of responses is 77. Thus, the hours per reporting response is 39.43 hours per response. There are no recordkeeping responses. In addition, there are no non-labor costs associated with enforcing State plans.

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

The detailed bottom line burden hours and cost calculations for the respondents are shown in Tables 1A, 1B, and 1C. Tables 1A and 1B contain the burden for large MWC plants subject to State plans and the Federal plan, respectively. Table 1C presents the combined burden for large MWC plants subject to State plans and the Federal plan.

The detailed bottom line burden hours and cost calculations for the designated administrators (EPA and the States) are shown in Tables 3A, 3B, and 3C, and are summarized below.

(i) Respondent Tally

For privately owned large MWC plants, the total annual responses are 74, the total annual hours are 190,954, and the total (including labor) annual cost burden is $25,815,289. For publicly owned large MWC plants, the total annual responses are 78, the total annual hours are 200,964, and the total (including labor) annual cost burden is $23,086,676.

The total annual labor hours requested are 394,954. Details regarding these estimates may be found in Tables 1C, 2C, and 3A. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,725 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,555,200. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 441 labor hours at a cost of $19,052. See Table 3B: Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Large for Large MWC Units Subject to Subpart FFF (Federal Plan).

6(f) Reasons for Change in Burden

The apparent increase in burden from the most recently approved ICR is due to increased coverage of this ICR. The previous ICR included only the burden of nine large MWC plants that are subject to 40 CFR part 60, subpart Cb, as implemented by the Federal plan (40 CFR part 62, subpart FFF). This ICR has been expanded to include additional large MWC plants subject to 40 CFR part 60, subpart Cb, as implemented by State plans. With expansion to include large MWC units subject to State plans, the number of large MWC plants covered by this ICR increased from nine to 63. Of the 63 large MWC plants, 55 are located in States with State plans and eight are located in States without State plans and thus are subject to the Federal plan.

Compared to the previously approved ICR that covered only MWCs covered by Federal plan, there is an increase from 24 responses to 229 responses; an increase from 38,417 hours to 394,954 hours; and an increase from $384,000 to $1,555,200.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,725 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or 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.

The 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-OAR-2009-0253, which is available for public viewing at the Air and Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, 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 Air and Radiation Docket is (202) 566-1742. An electronic version of the public docket is available through the Federal Docket Management System (FDMS) at http://www.regulations.gov. Use FDMS to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17^th Street, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2009-0253 and OMB Control Number 2060-0390 in any correspondence.

Part B of the Supporting Statement

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