1926ss06

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (Renewal), EPA ICR Number 1926.06, OMB Control Number 2060-0450.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Commercial and Industrial Solid Waste Incineration Units were proposed on November 30, 1999, and promulgated on December 1, 2000. These standards apply to either owners or operators of a combustion device used to combust commercial and industrial waste, and that meet either of the following two criteria: 1) began construction on or after December 31, 1999; or 2) began reconstruction or modification on or after June 1, 2001.

The NSPS was recently amended on February 7, 2013. The 2013 standards apply to either owners or operators of a combustion device used to combust commercial and industrial waste, and that meet either of the following two criteria: 1) began construction on or after June 4, 2010; or 2) began reconstruction or modification on or after August 7, 2013. Burdens associated with the 2013 standards are addressed separately under EPA ICR Number 2384.05. This ICR applies only to those existing sources that have burdens under the 2000 standards.

Commercial and industrial waste is a solid waste combusted in an enclosed device using controlled flame combustion without energy recovery, which is a distinct operating unit of any commercial or industrial facility, including field-erected, modular, and custom-built incineration units operating with starved or excess air, or solid waste combusted in an air curtain incinerator without energy recovery that is a distinct operating unit of any commercial or industrial facility. This information is being collected to assure compliance with 40 CFR part 60, subpart CCCC.

In general, all NSPS standards 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 NSPS.

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 three-year period of this information collection request (ICR), we estimate 30 existing sources have burdens associated with the standards. New sources will become subject to the 2013 standards, and are not covered under this ICR.

The active (previous) ICR had the following Terms of Clearance (TOC):

When this ICR is renewed, EPA should review the respondent burden, universe, response number, labor rates, and capital costs and if necessary, update these estimates.

EPA has addressed each item of concern in the TOC by reviewing and updating the aforementioned items accordingly. Specific updates are discussed in detail in Section 6(f).

The “Affected Public” are owners or operators of commercial and industrial solid waste incineration units. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (Renewal). The “burden” to the Federal Government is attributed to work performed by either Federal employees or government contractors, and may be found below in Table 2: Average Annual EPA Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years.

In addition, section 114(a) states that the Administrator may require any owner/operator 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, 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 Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.

In the Administrator's judgment, emissions from commercial and industrial solid waste incinerators either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart CCCC.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensures compliance with the applicable regulations which were 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, if continuous emission monitoring systems are not required. Performance test reports are needed as these are Agency records of a source's initial capability to comply with emission standards, and serve as a record of the operating conditions under which compliance was achieved. The Agency or delegated authority may also observe the performance test.

The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated and if the standard is 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 CCCC.

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 (77 FR 63813) on October 17, 2012. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data.

Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply. In developing this ICR, the Agency contacted: 1) the Solid Waste Association of North America (SWANA), at (240) 494-2253; and 2) the National Solid Waste Management Association (NSWMA), at (202) 364-3724. EPA did not receive any comments from the consultations.

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 with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond 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 or operators of commercial and industrial solid waste incineration (CISWI) units. The United States Standard Industrial Classification (SIC) codes, which correspond to the North American Industry Classification System (NAICS) codes for the respondents subject to this standard, can be found in the following table.

Standard (40 CFR Part 60, Subpart CCCC)	SIC Codes	NAICS Codes
Manufacturers of chemicals and allied products	28	325
Manufacturers of electronic equipment	34	325
Manufacturers of wholesale trade, durable goods	36	421
Manufacturers of lumber and wood furniture	24, 25	321, 337

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC).

A source must make the following reports:

Notifications/Reports
Notification of preconstruction (prior to commencing construction) including anticipated date of initial startup	60.2190
Notification of actual startup	60.2195
Notification of initial performance test	60.2200
Annual report	60.2205, 60.2210
Emission limitation or operating limit deviation report	60.2215, 60.2220
Qualified operator deviation notification	60.2225(a)(1)
Qualified operator deviation status report	60.2225(a)(2)
Qualified operator deviation notification of resumed operation	60.2225(b)

A source must keep the following records:

Recordkeeping
Maintain records of CISWI operation parameters.	60.2175(b)
Maintain records of days for which data on operating parameters have not been obtained, including operating parameters not measured, reasons for not measuring, and a description of corrective actions taken.	60.2175(c)
Maintain records of occurrence and duration of malfunction and the corrective action taken.	60.2175(d)
Maintain records of days when deviation from operating limits have occurred, and description of corrective actions taken.	60.2175(e)
Records of initial performance tests, annual performance tests, and any subsequent performance tests.	60.2175(f)
Maintain records of all documentation produced for the siting analysis.	60.2175(g)
Maintain records of names of persons who have completed review of site-specific information and incinerator operating procedures.	60.2175(h), 60.2095(a)
Maintain records of names of persons who have completed the operator training requirements.	60.2175(i)
Maintain records of names of phone and/or pager numbers of persons who have met the operator qualification criteria.	60.2175(j)
Maintain records of calibration of monitoring devices.	60.2175(k)
Maintain records of equipment vendor specifications for the incinerator, emission controls, and monitoring equipment.	60.2175(l)
Maintain records of daily log of quantity and types of wastes burned.	60.2175(n)
Records should be retained for five years.	60.2175

Electronic Reporting

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

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

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate control devices for PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO₂.

Perform initial performance test, Reference Method 1, 3A, or 3B test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

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

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

Transmit or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide 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

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, and to note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. 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). According to the final rule (65 FR 75348), approximately 9 percent of companies that own affected facilities might be small businesses. However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (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 the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where 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 5,965 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 the NSPS program, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $121.44 ($57.83+ 110%)

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

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

The types of industry costs associated with the information collection activities in the subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs associated with continuous monitoring. The capital/startup costs are one time costs when a facility becomes subject to the regulation. The annual operation and maintenance (O&M) 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 1	(C) Number of New Respondents	(D) Total Capital/Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent 2	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Wet Scrubber	$77,413	0	$0	$12,740	30	$382,200

¹ The total capital/startup cost is $77,413, and includes the capital cost of parameter monitoring equipment ($2,240) and the contractor labor cost associated with emissions testing ($75,173). The capital cost for wet scrubber parameter monitoring equipment excludes planning and selection costs ($500 and $300, respectively); therefore, the capital cost is estimated to be $17,986 ($18,786 - $500 - $300 = $17,986). Equipment planning and selection costs are addressed separately in Table 1 (see burden item 3B(e) and footnote e). We have applied a capital recovery factor of 0.11746, which is based on a 20-year equipment life span and a 10% interest rate ($17,986 x 0.11746 = $2,113). We have also applied a cost adjustment factor of 1.06 ($2,113 x 1.06= $2,240).

The emissions testing contractor labor cost is a one-time cost that new sources will incur during initial stack testing. We estimate it will require 750 contractor hours at a labor rate of $100.23 per hour (750 hours x $100.23 per hour = $75,173, after rounding). The labor rate is based on the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rate is from column 1, “Total compensation,” and has been increased by 110 percent to account for the benefit packages available to those employed by private industry.

² The total O&M cost is $12,740, and includes the O&M cost of parameter monitoring equipment ($211) and the contractor labor cost associated with annual stack testing ($12,529). The O&M cost for wet scrubber parameter monitoring equipment is $1,693, and is based on the memorandum titled “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions," A-91-61, IV-B-66. We have applied capital recovery and cost adjustment factors of 0.11746 and 1.06, respectively ($1,693 x 0.11746 x 1.06 = $211, after rounding).

The annual stack testing contractor labor cost is an annual cost incurred by existing sources, and we estimate it will require 125 contractor hours per respondent. The contractor labor rate is $100.23 per hour, per footnote 1, above. The total labor cost is $12,529 per respondent (125 hours per respondent x $100.23 per hour = $12,529 per respondent, after rounding).

The total capital/startup costs for this ICR are $0. This is the total of column D in the above table.

The total O&M costs for this ICR are $382,200. 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 $382,200.

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 $10,365.

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 – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (Renewal).

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

Based on our research for this ICR, approximately 30 existing respondents and zero new respondents will be subject to the standard. The overall average number of respondents, as shown in the table below, is 30 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	30	0	0	30
2	0	30	0	0	30
3	0	30	0	0	30
Average		30			30

¹ New respondent include sources with constructed, reconstructed, and modified affected facilities. In this standard existing respondents submit initial notifications.

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 30.

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

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Preconstruction Report	0	1	0	0
Startup Notification	0	1	0	0
Annual Report 1	30	1	0	30
Deviation Report 2	3	2	0	6
Qualified Operator Deviation Notification 2	3	1	0	3
Qualified Operator Report 2	3	2	0	6
			Total	45

¹ We estimate 30 existing respondents have to submit annual reports.

² We assume that these activities will apply to 10 percent of facilities

The number of Total Annual Responses is 45.

The total annual labor costs are $577,588. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (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 and summarized below in Tables 1 and 2, respectively.

(i) Respondent Tally

The total annual labor hours are 5,965 hours at a cost of $577,588. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 133 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $382,200. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 230 labor hours at a cost of $10,365. See below Table 2: Average Annual EPA Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart CCCC) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in the Agency costs from the most-recently approved ICR due to an increase in labor rates. This ICR uses updated labor rates in calculating all burden costs.

Additionally, as compared to the previous ICR, there is a decrease in the respondent burden, with an increase in the total O&M cost. The previous ICR included contractor labor costs associated with initial emissions testing and annual stack testing under Table 1: Annual Respondent Burden and Cost. Since the contractor labor costs apply solely to capital/startup and O&M activities, we have revised the ICR to reflect contractor labor costs under their respective capital/startup and O&M activities, and also have updated the associated contractor labor burden rate.

There is also a decrease in capital/startup costs in this ICR as new sources will become subject to the 2013 standards, and will not have burden associated with capital/startup under this NSPS.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 133 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-2012-0681. 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-2012-0681 and OMB Control Number 2060-0450 in any correspondence.

Part B of the Supporting Statement

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

Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR

Part 60, Subpart CCCC) (Renewal)

Burden Item			A	B	C	D	E	F	G	H
			Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b
1.	Applications		N/A
2.	Survey and Studies		N/A
3.	Reporting Requirements
	A.	Read Instructions c, d	16	1	16	0	0	0	0	$0
	B.	Required Activities
		1) Initial requirements c
		a) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2)	24	1	24	0	0	0	0	$0
		b) Establish and teach operator qualification course	64	1	64	0	0	0	0	$0
		c) Obtain operator qualification	72	1	72	0	0	0	0	$0
		d) Establish operating parameters (maximum and minimum)	160	1	160	0	0	0	0	$0
		e) Continuous parameter monitoring initial costs (including by-pass stack) d, e	8	1	8	0	0	0	0	$0
		f) Initial review of site-specific information	Included in 3B
		2) Periodic requirements f
		a) Annual stack test and test report (PM, HCl, and opacity)	12	1	12	30	360	18	36	$40,087.08
		b) Annual refresher operator training course	12	1	12	30	360	18	36	$40,087.08
		c) Annual review of site-specific information	8	1	8	30	240	12	24	$26,724.72
		d) Continuous parameter monitoring (including by-pass stack) annual costs g	83	1	83	30	2,490	124.5	249	$277,268.97
	C.	Create Information	Included in 3B
	D.	Gather Information	Included in 3E
	E.	Report Preparation
		1) Report prior to construction (includes siting analysis) c	160	1	160	0	0	0	0	$0
		2) Report prior to initial start-up c, h
		a) With site-specific parameter petition	6	1	6	0	0	0	0	$0
		b) Without site-specific parameter petition	14	1	14	0	0	0	0	$0
		3) Report of initial performance test	Included in 3B
		4) Siting analysis for new units only (establishes values for site-specific operating parameters) c	8	1	8	0	0	0	0	$0
		5) Waste management plan c	160	1	160	0	0	0	0	$0
		6) Annual Report
		a) Site-specific operating parameters	8	1	8	30	240	12	24	$26,724.72
		b) Emissions/parameter exceedances and malfunctions i	Included in 3E(9)
		c) Results of stack tests conducted during the year	Included in 3B
		d) Statement of no exceedances i	8	1	8	27	216	10.8	21.6	$24,052.25
		e) Documentation of use of by-pass stack	Included in 3B
		f) Documentation for periods when all qualified operators were unavailable for more than 8 hours	8	1	8	30	240	12	24	$26,724.72
		7) Status report for operators that are off-site for more than 2 weeks j	8	1	8	3	24	1.2	2.4	$2,672.47
		8) Corrective action summary for operators that are off-site for more than 2 weeks j	8	2	16	3	48	2.4	4.8	$5,344.94
		9) Semiannual report of emissions/parameter exceedances i	12	2	24	3	72	3.6	7.2	$8,017.42
		Subtotal for Reporting Requirements					4,933.5			$477,704.37
4.	Recordkeeping Requirements
	A.	Read Instructions	Included in 3A
	B.	Plan Activities	Included in 3B
	C.	Implement Activities	Included in 3B
	D.	Develop Record System	N/A
	E.	Record Information
		1) Records of operating parameters	Included in 3B
		2) Records of periods for which minimum amount of data on operating parameters were not obtained	0.5	52	26	3	78	4	8	$8,685.50
		3) Records of malfunction of the unit i	1.5	1	1.5	3	4.5	0.23	0.45	$501.09
		4) Records of exceedances of operating parameters i	1.5	1	1.5	3	4.5	0.23	0.45	$501.09
		5) Records of stack tests	Included in 3E
		6) Records of siting analysis	Included in 3E
		7) Records of persons who have reviewed operating procedures	1	1	1	30	30	1.5	3	$3,340.59
		8) Records of persons who have completed operator training	1	1	1	30	30	1.5	3	$3,340.59
		9) Records of persons who meet operator qualification criteria	1	1	1	30	30	1.5	3	$3,340.59
		10) Records of monitoring device calibration	Included in 3B
		11) Records of site-specific documentation	24	1	24	30	720	36	72	$80,174.16
	F.	Personnel Training	Included in 3B
	G.	Time for Audits	N/A
		Subtotal for Recordkeeping Requirements					1,031.86			$99,883.64
TOTAL ANNUAL BURDEN AND COST (rounded)							5,965			$577,588

Assumptions:

^a. We estimate that 30 existing respondents and zero new respondents per year will be subject to the rule over the three-year period of this ICR.

^b. This ICR uses the following labor rates: $100.23 for technical, $121.44 for managerial, and $50.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

^c. One-time only cost.

^d. Cost is incurred by a facility regardless of the number of affected units at the plant.

^e. Based on memorandum titled “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions," A-91-61, IV-B-66. We have assumed $500 and $300 for planning and selection, respectively. ($500 + $300)/$100.23 per hour = 8 hours.

^f. Annual costs are not incurred until the second year that units are in operation.

^g. We assume 83 technical labor hours for reporting, based on memorandum titled “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions," A-91-61, IV-B-66.

^h. We assume that new sources will petition for site-specific parameters.

^i. We assume that exceedances and malfunctions each will account for 10 percent of existing facilities. 10% x 30 facilities = 3 facilities.

^j. We assume that 10 percent of facilities will not have a qualified operator available for more than two weeks at least once a year, and that two corrective action summaries will be required.

Table 2: Average Annual EPA Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration Units (40 CFR

Part 60, Subpart CCCC) (Renewal)

Burden Item			A	B	C	D	E	F	G	H
			Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (C=AxB)	Respondents per year	Technical hours per year (E=CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) a
1.	Applications		N/A
2.	Read and Understand Rule Requirements		N/A
3.	Required Activities
	A.	Observe initial stack tests (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2) b, c	48	0	0	0	0	0	0	$0
	B.	Create Information	N/A
	C.	Gather Information	N/A
	D.	Report Reviews
		1) Review control plan c	8	0	0	0	0	0	0	$0
		2) Review notification of final compliance c	8	0	0	0	0	0	0	$0
		3) Review waste management plan c	8	0	0	0	0	0	0	$0
		4) Review initial stack test report c	40	0	0	0	0	0	0	$0
		5) Review annual compliance report	8	0	0	0	0	0	0	$0
		6) Review semi-annual excess emission and parameter exceedance report	16	0	0	0	0	0	0	$0
		7) Review status reports and corrective action summary for operators off-site	4	0	0	0	0	0	0	$0
	E.	Prepare annual summary report d	4	1	4	50	200	10	20	$10,364.90
TOTAL ANNUAL BURDEN AND COST (rounded)							230			$10,365

Assumptions:

^a. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. 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.

^b. We estimate initial stack test observations will take 48 hours per plant.

^c. One-time only cost.

^d. We assume that each state (i.e., 50 respondents) will prepare an annual summary of progress for implementing state plans.