2385ss01

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Existing Sources: Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR part 60, subpart DDDD) (Proposed Rule)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

(a) Title of the Information Collection.

Emission Guidelines for Existing Sources: Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR part 60, subpart DDDD), EPA ICR number 2385.01, OMB control number 2060-NEW

(b) Characterization of Information Collection.

This supporting statement addresses information collection activities imposed by the Commercial and Industrial Solid Waste Incineration (CISWI) Unit Emission Guidelines C Subpart DDDD. The guidelines do not apply directly to CISWI unit owners and operators. The guidelines can be thought of as model regulations that States use in developing State plans to implement the emission guidelines. If a State does not develop, adopt, and submit an approvable State plan, the Environmental Protection Agency (EPA) must develop a Federal plan to implement the emission guidelines. Whether a CISWI unit is ultimately regulated under a State plan or Federal plan, the full respondent burden for the first 3 years after promulgation of the emission guidelines is included in this information collection request (ICR).

The use of the term "Designated Administrator" throughout this document refers to the person or office designated by each State plan to administer the implementation of the plan, or to the U.S. EPA Administrator in the event that a State's plan is not approvable and a Federal plan must be developed. The term "Administrator" alone refers to the U.S. EPA Administrator.

This ICR includes the burden for activities that will be conducted in the first three years following promulgation of the proposed emission guidelines. These activities include reading the rule, submitting a control plan, initial stack testing, establishing operating parameters, and monitoring, recordkeeping, and reporting requirements. Since this proposed rule will re-propose the existing CISWI emission guidelines, as well as include units from source categories that are, in some cases, regulated under other national emission standards for hazardous air pollutants (NESHAP), we have assumed that many similar monitoring, reporting, and recordkeeping requirements may be well established already and may begin within the first three years following promulgation of the proposed emission guidelines. We realize, however, that some facilities may not incur these costs within the first three years, and may incur them during the fourth or fifth year instead. Therefore, this ICR presents a conservatively high burden estimate for the initial three years following promulgation of the proposed emission guidelines.

This ICR presents the burden to respondents (owners or operators of CISWI units) and the Designated Administrator (State or Federal Government) that will be imposed by State plans developed to implement the emission guidelines. Respondents are owners or operators of existing CISWI units.

The requirements described below are the minimum requirements established by the emission guidelines. Although States may choose to impose more stringent requirements, it is assumed for this burden estimate that the State plans mirror the emission guidelines.

2. AUTHORITY/NEED FOR AND USE OF THE COLLECTION

(a)  Need/Authority for the Collection

The EPA is charged under section 111(c) of the Clean Air Act (Act), as amended, to establish procedures by which:

. . .each State shall submit to the Administrator a plan which (A) establishes standards of performance for any existing source for any air pollutant. . .to which a standard of performance 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) states:

The Administrator shall establish performance standards and other requirements pursuant to section 111 and this section of 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 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 or who is subject to any requirement of this Act . . . to (A) establish and maintain such records, (B) make such reports, (C) install, use, and maintain such monitoring equipment or methods, (D) sample such emissions (in accordance with such methods, at such locations, at such intervals, and in such manner as the Administrator shall prescribe), and (E) provide such other information, as he may reasonably require.

Certain reports are necessary to enable a Designated Administrator to identify existing sources subject to the State plan that implements the emission guidelines and to determine if the standards are being achieved.

(b) Use/Users of the Data.

The information will be used by Designated Administrators' enforcement personnel to ensure that the requirements of the State (or Federal) plan are being implemented and are complied with on a continuous basis. Specifically, the information will be used by the Designated Administrator to: (1) identify existing sources subject to the standards; (2) ensure that existing sources have a control plan to achieve compliance by the final compliance date; (3) ensure that subpart DDDD is being properly applied; (4) ensure that the emission standards are being complied with; (5) ensure, on a continuous basis, that the operating parameters established during the initial performance test are not exceeded.

In addition, records and reports are necessary to enable the Designated Administrator to identify CISWI units that may not be in compliance with the standards. Based on reported information, the Designated Administrator can decide which CISWI units should be inspected and what records or processes should be inspected at the CISWI unit. The records that CISWI units maintain would indicate to the Designated Administrator whether the personnel are operating and maintaining control equipment properly and whether they have met the qualification requirements.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

(a) Nonduplication.

This ICR contains reporting and recordkeeping requirements for CISWI units, whether regulated under a State plan or Federal plan. The information collected in the first 3 years following promulgation of the proposed emission guidelines consists of a control plan and a waste management plan, as well as initial and ongoing compliance information. This information collection amends the information collection requirements currently collected for CISWI units by EPA or any other Federal agency.

Other activities, such as performance tests and performance test reports, installation of monitoring systems and control devices, operator training, and monitoring of operating parameters, do not typically occur until 4 or 5 years after promulgation. However, since some CISWI units are currently complying with the 2000 CISWI rule or other NESHAP, we are estimating these burdens within the first three years after promulgation of the proposed emission guidelines to be conservative in our estimates.

In more than 95 percent of the cases, the enforcement of emission guidelines has been delegated to State air pollution control agencies. In such cases, the reports required by the standards will be submitted to the appropriate State agency, and not directly to the EPA. Thus, there is a minimal possibility for the submittal of duplicate information to State agencies and EPA. In those few cases where State agencies have not developed a State plan or requested delegation of the Federal plan, Federal enforcement still requires information from the CISWI facility. The plant owner or operator may submit a copy of State or local reports to the Administrator in lieu of the report required by the standards, as specified in the General Provisions of 40 CFR part 60.

(b) Public notice prior to ICR submission to OMB.

A public notice of this collection is being provided in the notice of proposed rulemaking published for the emissions guidelines.

(c) Consultations.

The public has the opportunity to review and comment on the proposed emission guidelines and ICR during the public comment period.

(d) Effects of Less Frequent Data Collection.

The emission guidelines require a one-time control plan report, a one-time final compliance report, a one-time waste management plan, initial performance tests for ten pollutants, annual performance testing, continuous operating parameter monitoring, annual operator training, and annual reporting (a deviation report is required if any of the emission limitations or operating limits are exceeded). The frequency of these activities was chosen by EPA as the period that will provide an adequate margin of assurance that affected facilities will not operate for extended periods in violation of the standards.

The control plan and the waste management plan are submitted in the first 3 years after promulgation of the emission guidelines. The one-time control plan will allow the Designated Administrator to determine whether the owner or operator has an adequate strategy for achieving compliance with the emission guidelines by the final compliance date. The one-time waste management plan will allow the Designated Administrator to determine whether the owner or operator has an adequate plan for reducing and separating waste. The other activities take place after the compliance date, which will be in the fifth year after promulgation for most facilities, although, as discussed earlier, we anticipate that many facilities are already performing many of these tasks due to compliance with the prior CISWI regulation or to already applicable national emission standards for hazardous air pollutants which already applied to some units prior to the proposed CISWI emission guidelines. The final compliance report notifies the Designated Administrator that the owner or operator has achieved compliance with the emission guidelines. Annual reporting allows the submittal of required information and data parameters so that any potential problems can be identified in a timely fashion. A deviation report is required for deviations from the operating limits and the emission limitations so that the Designated Administrator can ensure that rapid corrective action is being taken.

(e) General Guidelines.

With the exception of requiring records to be maintained for more than 3 years, none of the guidelines in CFR 1320.5 are being exceeded. This rule requires all records to be maintained at the source for a period of 5 years. In 40 CFR part 63, subpart A, "General Provisions for National Emission Standards for Hazardous Air Pollutants for Source Categories," owners or operators of facilities are required to keep and maintain records for a period of 5 years. These records must be kept on file for use, if needed, by the regulating authority to ensure that the plant personnel are operating and maintaining control equipment properly. Under section 129 of the Act, CISWI facilities are subject to similar MACT-based regulations, therefore, this 5‑year record retention requirement was adopted for CISWI facilities. Furthermore, section 129 requires all CISWI units to obtain title V operating permits under part 70 or 71 permit programs. The title V permit programs also require records to be retained for 5 years. These records must be kept on file for use, if needed, by the regulating authority to ensure that the plant personnel are operating and maintaining control equipment properly.

(f) Confidentiality and Sensitive Questions.

(i) Confidentiality. All 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 2; 41 FR 36902, September 1, 1976, amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).

(ii) Sensitive Questions. This section is not applicable because this ICR does not involve matters of a sensitive nature.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

(a) Respondents/NAICS Codes.

Respondents are owners or operators of CISWI units for which construction commences on or before the date of proposal publication in the Federal Register. These standards affect any industry using a solid waste incinerator as defined in the regulation. This includes

North American Industry Classification System (NAICS) Codes 325 (Chemical Manufacturing), 421 (Wholesale Trade, Durable Goods), 321 (Wood Product Manufacturing), and 337 (Furniture and Related Product Manufacturing), among others.

(b) Information Requested.

(i) Data items. Attachment 1, Source Data and Information Requirements, and Tables 1 through 5 of Attachment 2 present a summary of the recordkeeping and reporting requirements of this regulation.

(ii) Respondent activities. The respondent activities required by the standards are provided under the first

column of Tables 1 through 5 of Attachment 2, introduced in section 6(a). All burden items are included in these tables.

(iii) Summary of emission guidelines requirements.

The information collection activities in this ICR include the preparation and submittal of the final control plan and the waste management plan, as well as the initial and ongoing compliance activities. The one-time control plan will allow the Designated Administrator to determine whether the owner or operator has an adequate strategy for achieving compliance with the emission guidelines. The waste management plan identifies both the feasibility and the approach to separate certain components of solid waste from the waste stream to reduce the amount of toxic emissions from incinerated waste.

Other information collection activities included in the emission guidelines may occur within the first three years, and are presented in this burden estimate, but may not occur until 4 or 5 years following promulgation of the proposed standards for some affected sources. To be conservative in our estimate, the burden for these items is included in this ICR. These items include: performance tests, operating parameter monitoring, operator training, one-time and periodic reports, and the maintenance of records.

The regulation requires an initial performance test for the following pollutants: PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx and SO₂. During the initial performance test the owner or operator must establish limits for each operating parameter. Thereafter, the owner or operator must conduct annual performance tests and continuously monitor the operating parameters. The rule allows the owner or operator to skip two annual performance tests for a pollutant if all performance tests over the previous 3 years show compliance with the emission limit.

To ensure the proper operation of the incinerator, the rule requires that each facility have at least one qualified CISWI unit operator or supervisor. The operator qualification process includes training, an exam, and review of site-specific materials. The operator qualification requirements allow the flexibility to use State-approved training and qualification programs. To maintain qualification operators or supervisors must attend an annual refresher course and review site-specific materials annually.

Following the initial performance test, the owner or operator must submit a report that documents the performance test and the values for their operating limits.

An annual report is required that documents: the values for the operating limits; any deviations or malfunctions; the results of any performance tests; if no deviations occurred, a statement that no deviations occurred; and documentation of periods when all qualified operators were unavailable for more than 8 hours.

If the operating limits or emission limitations are exceeded, the owner or operator must submit a deviation report that provides details on the deviation.

If all qualified operators are unavailable for more than 2 weeks, the owner or operator must submit a deviation report within 10 days and a corrective action summary every 4 weeks.

Owners or operators of CISWI units are required to keep records of certain parameters and information for a period of 5 years. Owners or operators are required to maintain records of the initial performance test, annual performance tests, and any subsequent performance tests. Owners or operators must also maintain records of the monitoring data for the operating parameters.

Records must be maintained for any incinerator malfunctions, any deviations from the operating limits, and days for which the minimum amount of operating parameter data were not obtained.

Owners or operators must maintain the names of persons who have completed the review of site-specific information and who have met the operator qualification requirements.

Records must also be maintained of all documentation for monitoring device calibration and site-specific documentation.

All reports are to be submitted to the Designated Administrator. The information will be used to determine that all sources subject to the emission guidelines are achieving the requirements.

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION, METHODOLOGY, AND INFORMATION MANAGEMENT

(a) Agency Activities.

A list of Agency activities is provided in section 6(c) and in Tables 7 through 10 of Attachment 3.

(b) Collection Methodology and Management.

This collection of information does not require the use of automated collection techniques because of the relatively small number of respondents affected. See section 5(d) Collection Schedule.

(c) Small Entity Flexibility.

Based on Small Business Administration guidelines, approximately 15 small businesses are affected by this rule. The EPA does not expect the standards to have a significant small business impact.

The rule does not contain any provisions reserved exclusively for the benefit of small entities. However, the rule does contain several provisions that reduce the impact of the rule on regulated entities, which include small entities. These are: annual performance testing is only required for three pollutants rather than the full ten pollutants included in the initial performance test for some subcategories; operating parameter monitoring is required instead of continuous emissions monitoring systems (CEMS) for some subcategories; the owner or operator is allowed to skip two annual performance tests for a pollutant if all performance tests over the previous 3 years show compliance; and deviation reports are only required if there is a deviation, otherwise reporting is annual.

(d) Collection Schedule.

In the first three years following promulgation of the emission guidelines owners or operators would read the rule and are required to submit a one-time control plan. As discussed earlier, we also anticipate many of the one-time activities, including: initial performance tests (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, SO_2), initial operator training and qualification, and report following initial performance test (includes operating parameter values) to occur for many facilities within the first three years, but they may occur in years 4 or 5. These data will be entered into the Aerometric Information Retrieval System (AIRS), operated and maintained by EPA=s Office of Air Quality Planning and Standards.

Annual performance tests are required for each subcategory of CISWI. Continuous parameter monitoring and/or CEMS is required, depending on the subcategory and control device being used. An annual operator training refresher course and site-specific information review is required.

An annual report is required that includes data on the operating parameters, performance test results, identification of deviations and malfunctions, and documentation of periods when all qualified operators were unavailable for more than 8 hours.

If all qualified operators are unavailable for more than 2 weeks, a status report must be submitted within 10 days and a corrective action summary must be submitted every 4 weeks until compliance is achieved.

Additionally, if the operating limits or emission limitations are exceeded, the owner or operator must submit a deviation report that provides details on the deviation. Information obtained from annual compliance reports will be published and distributed through the compliance data system (CDS). Data obtained during periodic visits by EPA personnel from records maintained by the respondents will be tabulated and published for internal EPA use in compliance with enforcement programs.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

(a) Estimating Respondent Burden.

Upon promulgation of the proposed standards, we anticipate that many of the affected CISWI units will begin to be shut down and facilities will utilize alternative means of disposal instead. The baseline population of 110 existing CISWI units at 67 facilities is based upon our estimates of how many units would remain operating instead of shutting down. This population is expected to decline over time. Tables 1 through 5 of Attachment 2 present an itemized breakdown of the reporting and recordkeeping requirements for the respondents subject to these standards. The annual cost and labor burden estimates for reporting and recordkeeping are also presented in Tables 1 through 5. Table 6 of Attachment 2 presents a summary of the respondent burden.

(b) Estimating Respondent Costs.

The information collection activities for sources subject to these requirements are presented in Tables 1 through 5 of Attachment 2. The total cost for each respondent activity includes labor costs, capital/startup costs, and operating and maintenance (O&M) costs.

(i) Estimating Labor Costs. Labor rates, on a per-hour basis, are taken from the Bureau of Labor Statistics, Occupational Employment Statistics, May 2008 National Industry-Specific Occupational Employment and Wage Estimates for the pulp, paper, and paperboard mills; pipeline transportation; cement and concrete product manufacturing; and pharmaceutical and medicine manufacturing industry categories. The occupational categories that are the most similar to personnel operating CISWI unit operations are assumed to be stationary engineers and boiler operators, engineering managers, and general office clerks. The base labor rates are $21.62 for technical personnel, $51.40 for management personnel, and $13.95 for clerical personnel. The labor rates are adjusted with an average fringe benefit and overhead rate of 160 percent to account for paid leave, insurance, etc. Therefore, the total loaded wage rates are calculated by the following equation:

Base labor rate x 1.60 = Loaded labor rate

Given the fringe benefit and cost overhead adjustments, the final total loaded wage rates are $34.60 for technical personnel, $82.23 for management personnel, and $22.32 for clerical personnel. For emission testing labor rates, a nominal labor rate of $80.00 per hour is typically used. This labor rate reflects the current loaded labor rate for emission testing contractors and includes fringe benefits and overhead, as well as the additional equipment costs needed to perform emission tests and analyze gas samples.

(ii) Estimating Capital/Start-up Costs.

The capital costs associated with the proposed emission guidelines include a file cabinet for storing copies of records and reports, initial stack testing costs, and monitoring system initial costs. As discussed earlier, we have estimated the burden if these occurred within the first three years, but realize that some facilities may incur these costs within years 4 or 5.

(iii) Total Operation and Maintenance (O&M), and Purchase of Service Costs.

Operational or maintenance costs associated with the proposed emission guidelines include maintenance of the CEMS or parameter monitoring systems. We have estimated the burden if these occurred within the first three years, but realize that some facilities may incur these costs within years 4 or 5.

(c) Estimating Agency Burden and Cost.

Because the information collection requirements were developed as an incidental part of standards development, no costs can be attributed to the development of the additional information collection requirements. Because reporting and recordkeeping requirements on the part of the respondents are required under sections 111 and 129 of the Act, no operational costs would be incurred by the Federal Government. Publication and distribution of the information are part of the AIRS Facility subsystem, with the result that no Federal costs can be directly attributed to the ICR. Examination of records to be maintained by the respondents would occur incidentally as part of the periodic inspection of sources that is part of the Designated Administrator’s overall compliance and enforcement program and, therefore, could not be attributable to the ICR. The only costs that the Implementing Agency would incur in the first three years are: reading and understanding the rule, reviewing control plans submitted by CISWI units, and the preparing of an annual report summarizing progress in implementing State plans and the compliance status of all the affected facilities. However, as we have noted before, some facilities may already be undertaking similar compliance activities already due to existing regulations, so we have estimated the burden as if the costs to the Implementing Agency for initial and ongoing compliance activities are also accounted for. These are presented in Tables 7 through 10 of Attachment 3. Labor rates for the Designated Administrator’s employees are based on the estimated hourly rates of $52.37 for technical personnel (GS-12, Step 5); $86.56 for management personnel (GS-15, Step 5); and $29.52 for clerical personnel (GS-7, Step 5). These values represent the inclusion of a 1.6 multiplier to account for overhead and fringe benefit costs.

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

The total number of respondents is also referred to as the respondent universe. The respondent universe for this ICR is based on the EPA’s CISWI database, accounting for expected closures upon promulgation of the proposed emission guidelines. Industry burden is calculated based on the number of units and facilities in each subcategory and the anticipated controls and monitoring that each unit will most likely utilize to comply with the proposed emissions guidelines.

Additional estimates regarding the respondent universe are included in the industry burden determination. The EPA estimates that 67 respondents (facilities) will read the rule in year 1 and will submit a control plan and a waste management plan. We have also included the burden associated with initial monitoring in the year 1 estimates. In years 2 and 3, the 67 respondents incur the annual burden associated with the emission guidelines, such as annual testing and monitoring system operation and maintenance.

(e) Bottom Line Burden Hours and Cost Tables.

(i) The Respondent Tally. A breakdown for each of the collection, reporting, and recordkeeping activities required by the emission guidelines is presented in Tables 1 through 6 of Attachment 2. Tables 1A, 1B, and 1C show the costs for incinerators in years 1, 2, and 3, respectively. Table 1D summarizes the costs for the three year period. Similarly, Tables 2A, 2B, 2C, and 2D show the costs for burn-off ovens; Tables 3A, 3B, 3C, and 3D show the costs for small remote incinerators; Tables 4A, 4B, 4C, and 4D show the costs for energy recovery units; and Tables 5A, 5B, 5C, and 5D show the costs for cement kilns. The estimate of total annual hours requested from the respondents was based on the assumptions outlined in section 6(d) of this ICR. The EPA estimated the respondent burden for the first 3 years after adoption of these guidelines by totaling the hours per year for technical, managerial, and clerical staff at the plant. This total was then divided by 3 to arrive at the annualized burden (see Table 6). A similar approach was taken for estimating annual labor costs. For the first three years after the adoption of the emission guidelines, EPA estimates that industry would expend 21,985 hours annually at a cost of $782,642 per year to meet the monitoring, recordkeeping, and reporting requirements. The annual non-labor costs are estimated at $8,626,349, which include the initial and annual costs associated with the monitoring system and initial and annual performance testing.

(ii) The Designated Administrator. The bottom line Designated Administrator burden hours and costs, presented in Tables 7 through 9 of Attachment 3, were calculated by totaling the hours per year for technical, managerial, and clerical staff, and by totaling the cost column. Table 10 of Attachment 3 summarizes the annual agency burden for each of the first three years and calculates the average annual burden by dividing the three year total by three. The estimated average annual burden over the first 3 years for the Designated Administrator would be 3,811 hours at a cost of $204,136 per year.

(iii) Variations in the annual bottom line. The total respondent costs for years 1, 2, and 3 are $11,330,052, $8,448,460, and $8,448,460, respectively. The corresponding total number of respondent hours over this period are 47,567, 9,194, and 9,194 (see Tables 1 through 6 of Attachment 2). Activities during this period include reading and understanding the rule, developing a control plan, developing the waste management plan. Since this rule addresses a remand of the existing CISWI rule and brings sources in that are subject to other existing regulatory requirements which may have similar monitoring, reporting and recordkeeping provisions, we have also estimated the burden of the rule to occur within the first three years. These include initial and annual performance tests, operator training and qualification, setting and monitoring of operating parameter values, and reporting and recordkeeping for these activities. We realize, however, that some of these activities will not occur until years 4 or 5 for some sources. Therefore, the respondent burden for years 1-3 may be conservatively high.

During the first 3 years, the Designated Administrators will be reviewing the regulation, reviewing the control plans, reviewing the waste management plan, observing initial stack tests, reviewing initial test reports, and preparing annual summary reports. In years 1, 2, and 3, the Designated Administrators will expend 7,845, 1,794, and 1,794 total hours in labor, respectively. The corresponding costs for each year are $426,306, $93,051, and $93,051 (see Tables 7 through 10 of Attachment 3).

(f) Reasons for change in burden.

The new burden summarized in this ICR results from information collection activities imposed by the Commercial and Industrial Solid Waste Incineration (CISWI) Unit Emission Guidelines C Subpart DDDD. However, as noted earlier in this supporting statement, this burden estimate accompanies a proposed emission guideline that addresses a remand of the 2000 CISWI rule. Rule changes since the 2000 CISWI rule have re-proposed emission limits for units subject to the 2000 rule, as well as removing most of the exemptions present in the previous rule. A separate proposed rulemaking proposes a solid waste definition that also will affect the population of combustion units subject to CISWI, primarily including waste burning boilers, process heaters, and cement kilns. Many of these units are subject to other NESHAP or NSPS already, but will be subject to CISWI upon promulgation of the proposed solid waste definition.

(g) Burden Statement.

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 24 hours per response. Burden means 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. An 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. The OMB control numbers for EPA=s regulations are listed in 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-2003-0119, which is available for online viewing at www.regulations.gov, or in person viewing at the [insert your Program Office docket name] in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. 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 Docket is (202) 566-1742. An electronic version of the public docket is available at www.regulations.gov. This site can be used 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 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ or EPA-HQ-OAR-2003-0119 and OMB Control Number 2060-NEW in any correspondence.

PART B OF THE SUPPORTING STATEMENT

This section is not applicable because statistical methods are not used in data collection associated with this regulation.

ATTACHMENT 1 SOURCE DATA AND INFORMATION REQUIREMENTS
Requirement	40 CFR 60 Subpart DDDD
RECORDKEEPING
5-year retention of records.	60.2740
Calendar date of each record.	60.2740(a)
Records of operating parameters.	60.2740(b)
Records of days when a deviation from the operating limits have occurred. Includes a description of the deviation and a description of the corrective actions taken.	60.2740(e)
Records of initial performance tests, annual performance tests, and any subsequent performance tests.	60.2740(f)
Records of names of persons who have completed review of the site-specific information and incinerator operating procedures in 60.2660(c).	60.2740(g)
Records of names of persons who have completed the operator training requirements. Includes documentation of the training and the dates of the training.	60.2740(h)
Records of phone and/or pager number of persons who have met the operator qualification criteria.	60.2740(i)
Records of calibration of any monitoring devices.	60.2740(j)
Equipment vendor specifications for the incinerator, emission controls, and monitoring equipment.	60.2740(k)
Daily log of quantity and types of waste burned.	60.2740(m)
Records of annual control device inspections.	60.2740(n)
Records of site-specific information and incinerator operation procedures.	60.2660(c)
REPORTING
Submit final control plan	60.2600(a)
Submit notification of final compliance	60.2605
Submit waste management plan	60.2755
Report the following information no later than 60 days after the initial performance test: - complete test report for the initial performance test results - the values for site-specific operating limits	60.2760
Closure notification report	60.2615
Report the following information annually: - company name and address - certification by responsible official - date of report and beginning and ending dates of reporting period - the values for the site-specific operating parameters - the highest maximum operating parameter and the lowest minimum operating parameter - information on deviations and malfunctions - the results of performance tests conducted during the period, if any - if no deviations or malfunctions occurred during the period, a statement that no exceedances occurred - documentation of periods when all qualified CISWI unit operators were unavailable for more than 8 hours	60.2765, 60.2770
If a deviation from operating limits or emission limitations occurs, submit a deviation report that includes the following information: - date of deviation - the data for that date - the reason for the deviation - the corrective actions that were taken	60.2775, 60.2780
If all qualified operators are unavailable for more than 2 weeks, submit a notification of the deviation within 10 days and a corrective action summary every 4 weeks	60.2785
If an increment of progress is not met, submit a notification each month until increment is met	60.2595

ATTACHMENT 2

TABLES 1, 2, 3, 4, 5, and 6

Tables 1.A – 1.D: Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units - Subpart DDDD, Incinerators

Tables 2.A – 2.D: Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units - Subpart DDDD, Burn-off Ovens

Tables 3.A – 3.D: Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units - Subpart DDDD, Small Remote Incinerators

Tables 4.A – 4.D: Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units - Subpart DDDD, Energy Recovery Units

Tables 5.A – 5.D: Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Existing Stationary Sources: Commercial and Industrial Solid Waste Incineration Units - Subpart DDDD, Cement Kilns

Table 6: Summary of Respondent Burden for Emission Guidelines - Years 1 through 3

ATTACHMENT 3

TABLES 7, 8, 9, and 10

Table 7: Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units - Subpart DDDD - Year 1

Table 8: Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units - Subpart DDDD - Year 2

Table 9: Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units - Subpart DDDD - Year 3

Table 10: Summary of Designated Administrator Burden for Emission Guidelines - Years 1 through 3

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