1899ss07

1899ss07.docx

NSPS for Hospital/Medical/Infectious Waste Incinerators (40 CFR part 60, subpart Ce and 40 CFR part 62, subpart HHH) (Renewal)

OMB: 2060-0422

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SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incineration (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal)


1. Identification of the Information Collection


1(a) Title of the Information Collection


State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal), EPA ICR Number 1899.07, OMB Control Number 2060-0422


1(b) Short Characterization/Abstract


The State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators were promulgated on September 15, 1997 (subpart Ce) and September 14, 2000 (subpart HHH), and revised on October 6, 2009. Subpart Ce requires either states or tribes to develop plans to implement the Emission Guidelines. If approvable state or tribal plans were not developed, the EPA was required to develop a Federal plan (subpart HHH) to implement the Emission Guidelines for such states and tribes. States and tribes may choose to impose requirements that are more stringent, however, the burden estimates provided in this ICR assume that the state and tribal plans mirror the Emission Guidelines. This information is being collected to assure compliance with 40 CFR part 60, subpart Ce and 40 CFR part 62, Subpart HHH.


In general, the Emission Guidelines require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also 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 Emission Guidelines.


Any owner/operator subject to the provisions of this part shall 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 U.S. Environmental Protection Agency (EPA) regional office.


Over the next three years, an average of 79 existing sources located at 73 different facilities will be subject to the standard and no additional respondents per year will become subject to the standard. An estimated 47 of these sources are owned and operated by the private sector (hospitals, commercial waste disposal companies, pharmaceutical companies, and private universities); 6 are owned and operated by the Federal government (U.S. military base, veterans hospitals, and Federal research facilities); and 4 are owned and operated by State or local governments (State universities), and 22 States that require annual State Plan Inventory.


This ICR 1899.07 is being combined with ICR number 2335.02, (OMB control number 2060-0628). The number of existing sources is increased from 57 to 79; the latter number includes 22 States who must report their annual update of State Plan Inventory.


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


Hospital/Medical/Infectious Waste Incinerators (HMIWI) in the United States are owned and operated by either the private sector, the Federal government, or state and local governments (the “Affected Public”). The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – State and Federal Emission Guidelines for Hospital/

Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal). The burden to the “Federal Government” burden is attributed entirely to work performed by either Federal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal).


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, particulate matter (PM), carbon monoxide (CO), dioxin/furans (D/F), hydrogen chloride (HCl), sulfur dioxide (SO2), nitrogen oxide (NOx), lead (Pb), cadmium (Cd), and mercury (Hg) emissions from hospital, medical, or infectious waste incinerators cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the state and Federal emission guidelines were promulgated for this source category at 40 CFR part 60, subpart Ce and 40 CFR part 62, subpart HHH.


2(b) Practical Utility/Users of the Data


The recordkeeping and reporting requirements in the standards ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. 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, leaks are being detected and repaired, and the standards are being met. The performance test may also be observed.


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


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


The requested recordkeeping and reporting are required under 40 CFR part 60, subpart Ce and 40 CFR part 62, subpart HHH.



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 its 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, duplication does not exist.


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 (76 FR 26900) on May 9, 2011. No comments were received on the burden published in the Federal Register.


3(c) Consultations


The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. 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 EPA's Office of Compliance. OTIS is EPA’s 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.


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 and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted: 1) the Healthcare Waste Institute (HWI), at (202) 364-3724; and 2) the Larson-Miller Medical Waste Disposal Service, at (801) 738-6545.


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


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 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 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


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 owners and operators of HMIWI for which construction commenced on or before the date of the rule proposal. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards and the corresponding North American Industry Classification System (NAICS) codes are listed below for the HMIWI source category. Not all processes classified in these NAICS codes are subject to the emission guidelines.



Standard (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH)


SIC Codes


NAICS Codes

General Medical and Surgical Hospitals

8062, 8069

622110

Specialty Hospitals

8069

622310

Medicinal and Botanical Manufacturing

2833

325411

Pharmaceutical Preparation Manufacturing

2834

325412

Solid Waste Combustors and Incinerators

4953

562213

Colleges, Universities, and Professional Schools

8221

611310

Research and Development in Physical, Chemical, and Life Sciences

3721, 3724, 3728, 3761, 3764, 3769, 8731, 8733

541710

National Security

9711

928110

Public Health Facility

9431

923120

Nursing and Personal Care Facilities

8051, 8052, 8059

623110, 623311

Veterinary Services

0741, 0742, 8734

541940


4(b) Information Requested


(i) Data Items


In this ICR, all the data that is recorded or reported is required by State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH).


A source must make the following reports:


Notifications

State Plan to implement and enforce emission guidelines

60.39e(a), 60.23(a)

Notification of public hearing on State Plan

60.23(d)

Certification that public hearing on State Plan conducted according to subpart B State procedures

60.23(f)

Installation of CMS

60.37(e), 60.56(c), 60.57(c) 62.14454

Initial and repeat performance specification tests for CMS

60.37(e), 60.56(c), 60.57(c), 62.14454(f)

Initial equipment inspection (small rural HMIWI)

60.37(b), 60.56(c), 60.57(c), 62.14440

Increments of progress for HMIWI that will comply with regulation

60.39e(c)

Request for extension to shut down late

60.39e(d)

Waste management plan

60.35e, 60.353(a), 60.38e(a), 60.55c(c), 60.58c(c), 62.14430

Notification of HMIWI capacity

60.58c(a)

Notification of initial CMS demonstration

60.38e(a), 60.7

Report of initial CMS demonstration

60.38e(a), 60.7(c)

Notification of exemption claim for combustors burning pathological, low-level radioactive, and/or chemotherapeutic waste

60.32e(b)

Annual report containing information from annual equipment inspection, required maintenance, and repairs not completed during established time frame

60.38e(b)

Notification of exemption claim for co-fired combustors

60.32e(c)

Notification of relative weight of hospital waste, medical/infectious waste, and other fuels and/or waste to be combusted at co-fired combustor

60.32e(c)

Notification of initial performance test (PM, CO, fugitive emissions, stack opacity, dioxins/furans, HCI, Cd, Pb, Hg)

60.38e(a), 60.8(d)

Report of initial performance test

60.38e(a), 60.58c(c), 60.8 (a), 60.58c(d)(6), 62.14463(a)

Initial report of values for site-specific operating parameters

60.38e(a), 60.58c(c), 62.14463(f)

Annual report of values for site-specific operating parameters

60.38e(a), 60.58c(d), 62.14463(d) – (f)

Annual report of the highest maximum and lowest minimum operating parameters (covering the last two years)

60.38e(a), 60.58c(d), 62.14463(d)

Annual and semiannual reports of emissions or operating parameter exceedances, malfunctions, and periods for which data on emissions/operating parameters were not obtained

60.38e(a), 60.58c(d-e), 60.7(c-d), 62.14463(g), 62.14464(b-c)

Annual report containing results of annual performance test

60.38e(a-b), 60.58c(d), 62.14463(h), 62.14464(b)

Annual report of no excess emissions, malfunctions, or operating parameter exceedances

60.38e(a), 60.58c(d), 60.7(c), 62.14463(i)

Results of previous performance tests

60.37e(f), 60.38e(a)

Any use of the bypass stack, duration, reason for malfunction, and corrective action taken

60.38e(a), 60.58c(d), 62.14463(j)

Annual update of operating information

60.34(e), 60.53c(i), 62.14423(c)

Annual review of operating information with each operator

60.34(e), 60.53c(h), 6214425(a)


A source must keep the following records:


Recordkeeping

Records of public hearing conducted on State Plan

60.23(e)

Retention of records for 5 years

60.38e(a), 60.58c(b), 60.58c(f), 62.14461

Records of startup, shutdown, or malfunction

60.38e(a), 60.57c, 60.7(b), 62.14460(d)

Records of initial performance test

60.37e, 60.57c, 62.14460(a)

Records of CMS operation and maintenance

60.38e(a), 60.57c, 60.7(f), 62.14460(a)

Records of annual equipment inspections, required maintenance, and repairs not completed during established timeframe

60.38e(b), 62.14460(a-b)

Records on a quarterly basis of periods, when only pathological, low-level radioactive, and/or chemotherapeutical waste is burned.

60.32e(b-c), 62.14400

Records of quarterly basis of weight of hospital waste and medical/infectious waste combusted, and weight of all other fuels and waste combusted at co-fired combustors

60.32e(c), 62.14400

Records for which data on emissions/operating parameters were not obtained

60.38e(a), 60.58c(b), 60.8(f), 62.14460(c-e)

Records related to malfunctions

60.38e(a), 60.58c(b), 60.8(f), 62.14460(d)

Records of emissions or operating parameter exceedances

60.38e(a), 60.58c(b), 60.8(f), 62.14460(e)

Records of initial, annual, and any subsequent performance tests

60.38e(a), 60.58c(b), 60.8(f), 62.14460(f)

Records of persons completing reviews of HMIWI operating manual (initial and annual)

60.38e(a), 60.58c(b), 62.14460(g)

Records of operators completing operator training course and qualification requirements

60.38e(a), 60.58c(b), 62.14460(h)

Records of operators who have met the qualification requirements

60.38e(a), 60.58c(b), 62.14460(h-i)

Records of calibration of any monitoring devices

60.38e(a), 60.58c(b), 62.14460(j)

Records of emissions, process, and control device operating parameters

60.38e(a), 60.58c(b), 60.8(f), 62.14460(a) and (b)(2-12)

Records of initial testing of fugitive ash emissions

60.38e(a), 60.58c(b)(2)(ii)


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 15 percent of the respondents use electronic reporting.


(ii) Respondent Activities



Respondent Activities


Read instructions.


Develop State Plan and inventory and update inventory annually.


Conduct public hearing on State Plan.


Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply pressure for control device.


Perform CMS demonstrations and repeat CMS demonstrations if necessary.


Perform initial performance tests and repeat performance tests if necessary.


Develop, update, and review operating information.


Perform inspections.


Write the notifications and reports listed above.


Develop waste management plan.


Prepare and review reports of performance tests and CMS demonstrations.


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.


Complete operator training and qualification.


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


Maintain the records listed in the table above.


Transmit, or otherwise disclose the information.


Currently, sources are using monitoring equipment and reporting 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, and excess emissions reports, required to be submitted by industry.


Audit facility records.


Input, analyze, and maintain data in the Online Tracking Information System (OTIS).


5(b) Collection Methodology and Management


Following notification of startup, the reviewing authority could 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 published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.


Information contained in the reports is entered into OTIS which is operated and maintained by EPA's Office of Compliance. OTIS 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 OTIS 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


A 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. However, the regulation includes various provisions that would reduce the burden on HMIWI, including the two HMIWI within the respondent universe that are classified as small entities. For example, there are provisions allowing HMIWI to skip annual tests and test reports for 2-year periods if they have demonstrated compliance for three annual tests in a row. Also, the emission guidelines allow HMIWI to submit previous emission tests to demonstrate compliance with the emission limits in the revised guidelines.


5(d) Collection Schedule


The specific frequency for each information collection activity within this request is shown in below Table 1: Annual Respondent Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal).


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 each of the subparts 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 60,080 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with part 60 and part 62 regulations, the previously approved ICR, and any comments received.


6(b) Estimating Respondent Costs


(i) Estimating Labor Costs

This ICR uses the following labor rates:


Industry State Government


Managerial $120.77 ($57.51 + 110%) $66.98 ($41.86 + 60%)

Technical $99.39 ($47.33 + 110%) $52.13 ($32.58 + 60%)

Clerical $50.04 ($23.83 + 110%) $24.35 ($15.22 + 60%)


The industry rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2011, “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. Rates for the State government are from the United States Department of Labor, Bureau of Labor Statistics, May 2011 National Industry-Specific Occupational Employment and Wage Estimates for State government (NAICS code 999200). The rates have been increased by 60 percent to account for the benefit packages available to State government employees.

(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



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


(A)

Continuous Monitoring Device


(B)

Capital/Startup Cost for One Respondent


(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)

Monitoring costs

- Privately-owned HMIWI

$3,751

0

$0

$11,957

47

$562,000

- Federally owned HMIWI

$3,700

0

$0

$8,317

6

$49,900

- State/locally-owned HMIWI

$3,700

0

$0

$6,275

4

$25,100

Testing1

$21,000

0

$0

NA

0

$0

File Cabinets2

$33.50

0

$0

NA

0

$0

Photocopying and postage

- States

N/A

0

$0

$16.27

22

$358

- Privately-owned HMIWI

N/A

0

$0

$50.28

47

$2,363

- Federally owned HMIWI

N/A

0

$0

$49.67

6

$298

- State/locally-owned HMIWI

N/A

0

$0

$49.50

4

$198

Temperature pressure, flow rate, change rate, voltage, and pH monitors3

- Privately-owned HMIWI

N/A

0

$0

$1,800

47

$84,600

- Federally owned HMIWI

N/A

0

$0

$1,800

6

$10,800

- State/locally-owned HMIWI

N/A

0

$0

$1,800

4

$7,200

Subtotals

- States



$0



$358

- Privately-owned HMIWI



$0



$648,963

- Federally owned HMIWI



$0



$60,998

- State/locally-owned HMIWI



$0



$32,498

TOTAL






$742,817

Note: This ICR assumes that all existing respondents have already installed monitoring and testing equipment to comply with the emission guidelines, including equipment for in-house testing of fugitive ash emissions required by the revised emission guidelines. Therefore, there is no capital/startup costs associated with this ICR.

1 Average testing cost for all respondents

2 Annualized cost with a capital recovery factor of 0.14238 based on a 10-year equipment life and a 7 percent interest rate, assuming each facility will purchase one standard four-drawer file cabinet ($235 per cabinet).

3 The average HMIWI operates approximately 6 continuous monitoring devices. The average cost per monitoring device is $300 per year. Therefore, the estimated O&M cost per respondent is estimated to be $1,800.

The total capital/startup costs for this ICR are zero. This is the total of column D in the above table.


The total operation and maintenance (O&M) costs for this ICR are $742,817. 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 $742,817. These are recordkeeping costs.


6(c) Estimating Agency Burden and Cost


The only costs to the Agency 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.


The average annual Agency cost during the three years of the ICR is estimated to be $131,043.


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


Managerial $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)


These rates are from the Office of Personnel Management (OPM), 2011 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 below in Table 2: Average Annual EPA Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal).


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


Based on our research for this ICR, on average over the next three years, approximately 79 existing respondents (47 privately-owned, 6 Federally-owned, and 4 State/locally-owned HMIWI residing in 22 States, plus the individual 22 states.) will be subject to the standard. It is estimated that no additional respondents per year will become subject. The overall average number of respondents, as shown in the table below is 79 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


79


0


0


79


2


0


79


0


0


79


3


0


79


0


0


79


Average


0


79


0


0


79

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

.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is 79.


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






(A)


Information Collection Activity




States


Privately-Owned

HMIWI


Federally- Owned HMIWI


State/Locally Owned HMIWI


Total

State Plan/inventory1

0

0

0

0

0

Annual update of State Plan inventory

22

0

0

0

22

Notification of initial performance test and CMS demonstration

N/A





Annual Reports2






CMS emissions and operating parameters

0

47

6

4

57

Exceedances, malfunctions, and periods for which data not obtained

0

9.4

1.2

0.8

11.4

Results of performance tests conducted during the year

0

47

6

4

57

Report of no exceedances

0

37.6

4.8

3.2

45.6

Report of annual equipment inspection (small rural HMIWI)

0

2

0

0

2

Semiannual report of exceedances, malfunctions, and periods for which data not obtained3

0

9.4

1.2

0.8

11.4


Total


22


152.4


19.2


12.8


206.4

1 This ICR assumes all 22 states have approved State Plans by the first year this ICR.

2 This ICR assumes 20% of respondents report exceedances, and 80% of respondents report no exceedances.

3 Because the semiannual report coincides once each year with the annual report and both reports include information on exceedances, malfunctions, and periods for which data were not obtained, the frequency of the semiannual report is shown in the table as only once per year to avoid double-counting.


The number of Total Annual Responses is approximately 206 (rounded), (22 for States, 152.4 for privately-owned HMIWI, 19.2 for Federally-owned HMIWI, and 12.8 for State/locally owned HMIWI.


The total annual labor costs are $5,746,349. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal).


6(e) Bottom Line 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 hours are 60,080. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal).


Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 292 (rounded) hours per response.


The total annual capital/startup and O&M costs to the regulated entity are $742,817. 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 2,908 labor hours at a cost of $131,043. See below Table 2: Average Annual EPA Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (Renewal).


6(f) Reasons for Change in Burden


There is a decrease in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. The decrease is not due to any program changes. The most recently approved ICR (ICR 1899.06) estimated the total burden associated with the regulation by adding together the burdens and costs from the ICR for the existing standard (ICR 1899.05) and the revised standard (ICR 2335.02); portions of the rule requirements and burden activities in ICRs 1899.06 and 2335.02 overlap. This ICR updates all estimates and removes any duplicate burdens.


There is no capital/startup cost associated with this ICR, which is a decrease from the most recently approved ICR. There are also changes in the O&M costs in this ICR compared to the previous ICR. These changes occurred because the most recently revised standard has been in effect for more than three years and the requirements are different during initial compliance as compared to on-going compliance. This ICR does not include the costs and burden for conducting initial compliance tests and notifications. Additionally, this ICR assumes that all sources have already purchased monitoring and testing equipment to comply with the standard.


6(g) Burden Statement


The annual public reporting and recordkeeping burden for this collection of information is estimated to average 292 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.


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 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–2011–0272. 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 contents of the 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 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 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 docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA–HQ–OECA–2011–0272 and OMB Control Number 2060-0422 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 – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (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 (States)

 

 

 

 

 

 

 

 

A. Read instructions

1

1

1

0

0

0

0

$0

B. Required activities c

 

 

 

 

 

 

 

 

- Development of State Plan/Inventory

2,080

1

2,080

0

0

0

0

$0

- Annual update of State Plan Inventory

20

1

20

22

440

22

44

$25,481.28

- Public hearing on State Plan

8

1

8

0

0

0

0

$0

C. Create information

Incl. in 3B

 

 

 

 

 

 

 

D. Gather information

Incl. in 3B

 

 

 

 

 

 

 

E. Write report

 

 

 

 

 

 

 

 

- State Plan/Inventory

Incl. in 3B

 

 

 

 

 

 

 

- Annual update of State Plan Inventory

Incl. in 3B

 

 

 

 

 

 

 

- Notification of public hearing on State Plan

8

1

8

0

0

0

0

$0

- Certification that public hearing on State Plan conducted according to Subpart B State procedures

2

1

2

0

0

0

0

$0

Subtotal for Reporting Requirements (States)

 

 

 

 

506

$25,481.28

4. Reporting requirements (privately-owned HMIWI)

 

 

 

 

 

 

 

 

A. Read instructions d

40

1

40

0

0

0

0

$0

B. Required activities e

 

 

 

 

 

 

 

 

Installation of CMS

15

1

15

0

0

0

0

$0

Performance specification tests for CMS

8

1

8

0

0

0

0

$0

Repeat performance specification tests/CMS

8

1

8

0

0

0

0

$0

Initial equipment inspection (small rural HMIWI)

20

1

20

0

0

0

0

$0

Annual update of operating information f

20

1

20

47

940

47

94

$103,806.55

Review operating information with each operator g

8

2

16

47

752

37.6

75.2

$83,045.24

Annual equipment inspection (small rural HMIWI)

20

1

20

2

40

2

4

$4,417.30

Annual equipment inspection (all other HMIWI)

20

1

20

45

900

45

90

$99,389.25

C. Create information

See 3B

 

 

 

 

 

 

 

Development of operating information h

160

1

160

0

0

0

0

$0

D. Gather information

Incl. in 4B

 

 

 

 

 

 

 

E. Write report e

 

 

 

 

 

 

 

 

Increments of progress for HMIWI that will Comply

 

 

 

 

 

 

 

 

Control plan

24

1

24

0

0

0

0

$0

Notification of construction contracts

2

1

2

0

0

0

0

$0

Notification of construction commencement

2

1

2

0

0

0

0

$0

Notification of construction completion

2

1

2

0

0

0

0

$0

Notification of control plan completion

2

1

2

0

0

0

0

$0

Request for extension to shut down date

12

1

12

0

0

0

0

$0

Notification of initial performance test

2

1

2

0

0

0

0

$0

Notification of initial CMS demonstration

2

1

2

0

0

0

0

$0

Waste management plan i

160

1

160

0

0

0

0

$0

Report of initial performance test for PM, CO, Hg, dioxins/furans, and stack opacity (small rural HMIWI)

560

1

560

0

0

0

0

$0

Report of initial performance test for PM, CO, HCI, dioxins/furans, metals, and stack opacity (small non-rural, medium, and large HMIWI)

640

1

640

0

0

0

0

$0

Report of initial CMS demonstration

See 4B

 

 

 

 

 

 

 

Annual report

 

 

 

 

 

 

 

 

CMS operating parameters

32

1

32

47

1,504

75.2

150.4

$166,090.48

Emissions/parameter exceedances and periods when emission/parameter data not obtained j

 

 

 

 

 

 

 

 

- Small rural HMIWI

16

1

16

0.4

6.4

0.32

0.64

$706.77

- All other HMIWI

64

1

64

9

576

28.8

57.6

$63,609.12

Report of annual performance test

 

 

 

 

 

 

 

 

- Small rural HMIWI

20

1

20

2

40

2

4

$4,417.30

- All other HMIWI

280

1

280

45

12,600

630

1,260

$1,391,449.50

Report of no exceedances

 

 

 

 

 

 

 

 

- Small rural HMIWI

8

1

8

1.6

13

0.65

1.3

$1,413.54

- All other HMIWI

32

1

32

36

1,152

57.6

115.2

$127,218.24

Report of annual equipment inspection

See 4B

 

 

 

 

 

 

 

Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained (small non-rural, medium, and large HMIWI) j

32

2

64

9

576

28.8

57.6

$63,609.12

Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained (small rural HMIWI) j

8

2

16

0.4

6.4

0.32

0.64

$706.77

Subtotal for Reporting Requirements (Privately-owned HMIWI)

 

 

 

 

21,971

$2,109,879.17

5. Reporting requirements (Federally-owned HMIWI)

 

 

 

 

 

 

 

 

A. Read instructions e

1

1

1

0

0

0

0

$0

B. Required activities

 

 

 

 

 

 

 

 

Annual update of operating information f

20

1

20

6

120

6

12

$13,251.90

Review operating information with each operator g

8

2

16

6

96

4.8

9.6

$10,601.52

Annual control equipment inspection

20

1

20

6

120

6

12

$13,251.90

C. Create information

NA

 

 

 

 

 

 

 

D. Gather existing information

Incl. in 5B

 

 

 

 

 

 

 

E. Write report

 

 

 

 

 

 

 

 

Annual report

 

 

 

 

 

 

 

 

CMS operating parameters

32

1

32

6

192

9.6

19.2

$21,203.04

Emissions/parameter exceedances and periods when emission/parameter data not obtained j

64

1

64

1.2

76.8

3.84

7.68

$8,481.22

Report of annual performance test

40

1

40

6

240

12

24

$26,503.80

Report of no exceedances

32

1

32

4.8

153.6

7.68

15.36

$16,962.43

Report of annual equipment inspection

Incl. in 5B

 

 

 

 

 

 

 

Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained j

32

2

64

1.2

76.8

3.84

7.68

$8,481.22

Subtotal for Reporting Requirements (Federally-owned HMIWI)

 

 

 

 

1,236

$118,737.02

6. Reporting requirements (State/locally-owned HMIWI)

 

 

 

 

 

 

 

 

A. Read instructions e

1

1

1

0

0

0

0

$0

B. Required activities

 

 

 

 

0

0

0

$0

Annual update of operating information

20

1

20

4

80

4

8

$8,834.60

Review operating information with each operator

8

2

16

4

64

3.2

6.4

$7,067.68

Annual control equipment inspection

20

1

20

4

80

4

8

$8,834.60

C. Create information

NA

 

 

 

 

 

 

 

D. Gather existing information

Incl. in 6B

 

 

 

 

 

 

 

E. Write report

 

 

 

 

 

 

 

 

Annual report

 

 

 

 

 

 

 

 

CMS operating parameters

32

1

32

4

128

6.4

12.8

$14,135.36

Emissions/parameter exceedances and periods when emission/parameter data not obtained j

64

1

64

0.8

51.2

2.56

5.12

$5,654.14

Report of annual performance test

40

1

40

4

160

8

16

$17,669.20

Report of no exceedances j

32

1

32

3.2

102.4

5.12

10.24

$11,308.29

Report of annual equipment inspection

Incl. in 6B

 

 

 

 

 

 

 

Semiannual report of emissions/parameter exceedances and periods when emission/parameter data not obtained j

32

2

64

0.8

51.2

2.56

5.12

$5,654.14

Subtotal for Reporting Requirements (State/locally-owned HMIWI)

 

 

 

 

824

$79,158.02

7. Reporting requirements (co-fired combustors and pathological/low-level radioactive/chemotherapeutic waste combustors)

 

 

 

 

 

 

 

 

A. Read instructions

N/A

 

 

 

 

 

 

 

B. Required activities

N/A

 

 

 

 

 

 

 

C. Create information

N/A

 

 

 

 

 

 

 

D. Gather existing information

N/A

 

 

 

 

 

 

 

E. Write report

 

 

 

 

 

 

 

 

Notification of exemption claim

2

1

2

0

0

0

0

$0

Notification of relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted (co-fired combustors only)

2

1

2

0

0

0

0

$0

Subtotal for Reporting Requirements (Co-fired combustors and pathological/low-level radioactive/chemotherapeutic waste combustors)

 

 

 

 

0

$0

8. Recordkeeping requirements (States)

 

 

 

 

 

 

 

 

A. Read instructions

NA

 

 

 

 

 

 

 

B. Plan activities

NA

 

 

 

 

 

 

 

C. Implement activities

NA

 

 

 

 

 

 

 

D. Develop record system

NA

 

 

 

 

 

 

 

E. Time to enter information

NA

 

 

 

 

 

 

 

F. Time to train personnel

NA

 

 

 

 

 

 

 

G. Time for audits

NA

 

 

 

 

 

 

 

Subtotal for Recordkeeping Requirements (States)

 

 

 

 

0

0

9. Recordkeeping requirements (privately-owned HMIWI)

 

 

 

 

 

 

 

 

A. Read instructions

N/A

 

 

 

 

 

 

 

B. Plan activities

N/A

 

 

 

 

 

 

 

C. Implement activities

N/A

 

 

 

 

 

 

 

D. Develop record system

N/A

 

 

 

 

 

 

 

E. Time to enter information

 

 

 

 

 

 

 

 

Records of startup, shutdown, malfunction

1.5

52

78

47

3,666

183.3

366.6

$404,845.55

Records of persons reviewing operating information r

2

2

4

47

188

9.4

18.8

$20,761.31

Records of operators completing training requirements

2

1

2

0

0

0

0

$0

Records of operators that have been qualified

2

1

2

0

0

0

0

$0

Records of initial performance test

See 4E

 

 

 

 

 

 

 

Records of process and control device operating parameters

 

 

 

 

 

 

 

 

- Small rural HMIWI

0.5

52

26

2

52

2.6

5.2

$5,742.49

- All other HMIWI

1.5

52

78

45

3,510

175.5

351

$387,618.08

Records of CMS operation and maintenance

 

 

 

 

 

 

 

 

- Small rural HMIWI

0.5

250

125

2

250

12.5

25

$27,608.13

- All other HMIWI

1.5

250

375

45

16,875

843.75

1,688

$1,863,548.44

Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j

 

 

 

 

 

 

 

 

- Small rural HMIWI

0.5

52

26

0.4

10.4

0.52

1.04

$1,148.50

- All other HMIWI

1.5

52

78

9

702

35.1

70.2

$77,523.62

Records of annual and subsequent compliance tests

See 4E

 

 

 

 

 

 

 

Records of annual equipment inspection

See 4B

 

 

 

 

 

 

 

F. Time to train personnel

40

1

40

0

0

0

0

$0

G. Time for audits

N/A

 

 

 

 

 

 

 

Subtotal for Recordkeeping Requirements (Privately-owned HMIWI)

 

 

 

 

29,042

$2,788,796.10

10. Recordkeeping requirements (Federally-owned HMIWI)

 

 

 

 

 

 

 

 

A. Read instructions

N/A

 

 

 

 

 

 

 

B. Plan activities

N/A

 

 

 

 

 

 

 

C. Implement activities

N/A

 

 

 

 

 

 

 

D. Develop record system

N/A

 

 

 

 

 

 

 

E. Time to enter information

 

 

 

 

 

 

 

 

Records of startup, shutdown, malfunction

1.5

52

78

6

468

23.4

46.8

$51,682.41

Records of persons reviewing operating information

2

2

4

6

24

1.2

2.4

$2,650.38

Records of operators completing training requirements

2

1

2

0

0

0

0

$0

Records of operators that have been qualified

2

1

2

0

0

0

0

$0

Records of initial performance test

See 5E

 

 

 

 

 

 

 

Records of process and control device operating parameters

1.5

52

78

6

468

23.4

46.8

$51,682.41

Records of CMS operation and maintenance

1.5

250

375

6

2,250

112.5

225

$248,473.13

Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j

1.5

52

78

1.2

93.6

4.68

9.36

$10,336.48

Records of annual and subsequent compliance tests

See 5E

 

 

 

 

 

 

 

Records of annual equipment inspection

See 5B

 

 

 

 

 

 

 

F. Time to train personnel

40

1

40

0

0

0

0

$0

G. Time for audits

N/A

 

 

 

 

 

 

 

Subtotal for Recordkeeping Requirements (Federally-owned HMIWI)

 

 

 

 

3,799

$364,824.81

11. Recordkeeping requirements (State/locally-owned HMIWI)

 

 

 

 

 

 

 

 

A. Read instructions

N/A

 

 

 

 

 

 

 

B. Plan activities

N/A

 

 

 

 

 

 

 

C. Implement activities

N/A

 

 

 

 

 

 

 

D. Develop record system

N/A

 

 

 

 

 

 

 

E. Time to enter information

 

 

 

 

 

 

 

 

Records of startup, shutdown, malfunction

1.5

52

78

4

312

15.6

31.2

$34,454.94

Records of persons reviewing operating information r

2

2

4

4

16

0.8

1.6

$1,766.92

Records of operators completing training requirements

2

1

2

0

0

0

0

$0

Records of operators that have been qualified

2

1

2

0

0

0

0

$0

Records of initial performance test

See 5E

 

 

 

 

 

 

 

Records of process and control device operating parameters

1.5

52

78

4

312

15.6

31.2

$34,454.94

Records of CMS operation and maintenance

1.5

250

375

4

1,500

75

150

$165,648.75

Records of emissions/parameter exceedances and periods when emission/parameter data not obtained j

1.5

52

78

0.8

62.4

3.12

6.24

$6,890.99

Records of annual and subsequent compliance tests

See 5E

 

 

 

 

 

 

 

Records of annual equipment inspection

See 5B

 

 

 

 

 

 

 

F. Time to train personnel

40

1

40

0

0

0

0

$0

G. Time for audits

N/A

 

 

 

 

 

 

 

Subtotal for Recordkeeping Requirements (State/Locally-owned HMIWI)

 

 

 

 

2,533

$243,216.54

12. Recordkeeping requirements (co-fired and pathological/low-level radioactive/ chemotherapeutic combustors)

 

 

 

 

 

 

 

 

A. Read instructions

N/A

 

 

 

 

 

 

 

B. Plan activities

N/A

 

 

 

 

 

 

 

C. Implement activities

N/A

 

 

 

 

 

 

 

D. Develop record system

N/A

 

 

 

 

 

 

 

E. Time to enter information

 

 

 

 

 

 

 

 

Quarterly records of periods when only pathological, low-level radioactive, chemotherapeutic waste burned k

2

4

8

13.4

107.2

5.36

10.72

$11,838.36

Quarterly records of weight of hospital waste and medical/infectious waste combusted, and weight of all other fuels and waste combusted (co-fired only) k

2

4

8

5

40

2

4

$4,417.30

Subtotal for Recordkeeping Requirements (Co-fired and pathological/low level radioactive / chemotherapeutic combustors)






169


$16,255.66

F. Time to train personnel

N/A

 

 

 

 

 

 

 

G. Time for audits

N/A

 

 

 

 

 

 

 

TOTAL REPORTING REQUIREMENTS (FROM SUBTOTALS)

 

 

 

 

24,537

$2,333,255

TOTAL RECORDKEEPING REQUIREMENTS (FROM SUBTOTALS)

 

 

 

 

35,543

$3,413,093

TOTAL LABOR BURDEN AND COST (ROUNDED)

 

 

 

 

60,080

$5,746,349



Note: States and tribes may choose to impose requirements that are more stringent. However, the burden estimates provided in this ICR assume that the state and tribal plans mirror the federal Emission Guidelines.


Assumptions:

a We have assumed that there are approximately 79 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.

The breakdown is as follows: 47 privately-owned HMIWI (including 2 small rural HMIWI), 6 Federally-owned HMIWI, and 4 State/locally-owned HMIWI, and 22 States that require annual State Plan Inventory.

b This ICR uses the following labor rates for industry: $120.77 per hour for Executive, Administrative, and Managerial labor; $99.39 per hour for Technical labor, and $50.04 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2011 “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. In addition, this ICR uses the following labor rates for State government: $66.98 for Managerial labor; $52.13 for Technical labor, and $24.35 for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2011 National Industry-Specifics Occupational Employment and Wage Estimates for State government (NAICS code 999200). The rates have been increased by 60 percent to account for the benefit packages available to State government employees.

c Assume all 22 states with HMIWI have approved State Plan by the first year of this ICR. However, the State Plan/Inventory is updated on an annual basis.

d We have assumed that it will take 40 hours for each new respondent to read requirements.

e The zero value for number of respondents indicates that burden was incurred prior to the time period covered by this supporting statement or for new respondents.

f We have assumed that it would take each respondent 20 hours each to update the annual operating information.

g We have assumed that it would take each respondent 8 hours to review the operating information with each operator.

h We have assumed that each facility will take 160 hours to develop the operating information.

i We have assumed that each facility will rake 40 hours to develop the waste management plan.

j Assume 20 percent of respondents report exceedances, and 80 percent report no exceedances.

k We have assumed that all co-fired and pathological/low-level radioactive/ chemotherapeutic combustors units would be owned by the private sector.



Table 2: Average Annual EPA Burden and Cost – State and Federal Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR Part 60, Subpart Ce and 40 CFR Part 62, Subpart HHH) (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. Initial performance test

32

1

32

0

0

0

0

$0

2. Repeat performance test

 

 

 

 

 

 

 

 

A. Retesting preparation

12

1

12

0

0

0

0

$0

B. Attend retesting

32

1

32

0

0

0

0

$0

3. Report review

 

 

 

 

 

 

 

 

A. Review reports for co-fired combustors

 

 

 

 

 

 

 

 

Review notification of exemption claim

2

1

2

0

0

0

0

$0

Review notification of relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted

2

1

2

0

0

0

0

$0

B. Review notification of exemption claim for pathological, low-level radioactive, chemotherapeutic combustors

2

1

2

0

0

0

0

$0

C. Review reports of increments of progress

 

 

 

 

 

 

 

 

Review control plan

4

1

4

0

0

0

0

$0

Review notification of construction contracts

2

1

2

0

0

0

0

$0

Review notification of construction commencement

2

1

2

0

0

0

0

$0

Review notification of construction completion

2

1

2

0

0

0

0

$0

Review notification of control plan completion

2

1

2

0

0

0

0

$0

D. Review request for extension for HMIWI planning to shut down late

4

1

4

0

0

0

0

$0

E. Review reports for small non-rural, medium and large HMIWI

 

 

 

 

 

 

 

 

Review waste management plan

8

1

8

0

0

0

0

$0

Review notification of initial performance test

8

1

8

0

0

0

0

$0

Review notification of initial CMS demonstration

5

1

5

0

0

0

0

$0

Review report of initial performance test

36

1

36

0

0

0

0

$0

Review report of initial CMS demonstration

24

1

24

0

0

0

0

$0

Review annual report

 

 

 

 

 

 

 

 

CMS operating parameters

 

 

 

 

 

 

 

 

- Small rural HMIWI

2

1

2

2

4

0.2

0.4

$207.30

- All other HMIWI

6

1

6

55

330

16.5

33

$17,102.09

Emissions/parameter exceedances and periods when emission/parameter data not obtained c

 

 

 

 

 

 

 

 

- Small rural HMIWI

4

1

4

0.4

1.6

0.08

0.16

$82.92

- All other HMIWI

16

1

16

11

176

8.8

17.6

$9,121.11

Results of annual performance test

 

 

 

 

 

 

 

 

- Small rural HMIWI

6

1

6

2

12

0.6

1.2

$621.89

- All other HMIWI

24

1

24

55

1,320

66

132

$68,408.34

Report of no exceedances

 

 

 

 

 

 

 

 

- Small rural HMIWI

2

1

2

1.6

3.2

0.16

0.32

$165.84

- All other HMIWI

8

1

8

44

352

17.6

35.2

$18,242.22

Review semiannual report of emissions/ parameter exceedances and periods when emission/parameter data not obtained c

 

 

 

 

 

 

 

 

- Small rural HMIWI

2

1

2

0.4

0.8

0.04

0.08

$41.46

- All other HMIWI

8

1

8

11

88

4.4

8.8

$4,560.56

Report of annual equipment inspection (Small rural HMIWI)

4

1

4

2

8

0.4

0.8

$414.60

Report of annual control equipment inspection (All other HMIWI)

4

1

4

0

0

0

0

$0

G. Review reports for States

 

 

 

 

 

 

 

 

Review annual update of State Plan Inventory d

8

1

8

22

176

8.8

17.6

$9,121.11

4. Prepare annual summary report e

1

1

1

57

57

2.9

5.7

$2,954.00

TOTAL ANNUAL BURDEN AND COST

2,908

$131,043.43


Assumptions:

a We have assumed that there are approximately 57 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. The 57 respondents are located in 22 States.

b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.

c Assume 20 percent of respondents report parameter exceedances, and 80 percent report no exceedances.

d Assume all 22 States have approved State/Plan Inventory by the first year of this ICR. All States are expected to update State Plan/Inventory annually.

e We have assumed that all respondents will have to prepare annual summary report.



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