1927ss06

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal), EPA ICR Number 1927.06, OMB Control Number 2060-0451

1(b) Short Characterization/Abstract

The Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR part 60, subpart DDDD) were proposed on November 30, 1999, and promulgated on January 30, 2001. The guidelines were recently amended on February 7, 2013, to clarify definitions, references, applicability, and compliance issues and to establish effective dates. These guidelines fulfill the requirements of sections 111 and 129 of the Clean Air Act (CAA), and affect the administrator of an air quality program in a state or United States protectorate with one or more existing commercial and industrial solid waste incineration (CISWI) units. The emission guidelines apply to sources commencing construction on or before June 4, 2010 or to sources commencing modification or reconstruction between June 1, 2001 and August 7, 2013. The guidelines do not apply directly to CISWI unit owners and operators, since they are implemented through state implementation plans (SIP). If a state does not develop, adopt, and submit an approved state plan, or if a state’s plan is not approved, the EPA must promulgate a Federal implementation plan to implement the emission guidelines in a state without its own SIP. This information is being collected to assure compliance with 40 CFR part 60, subpart DDDD.

In general, all 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.

We estimate an average of 90 sources will be subject to the standard, and that no new respondents will be subject over the three-year period of this information collection request (ICR). The estimated number of existing sources is based on the February 2011 regulatory impact analysis (RIA) conducted in support of proposed revisions to the existing emission guidelines. The RIA can be found in the public docket under Docket ID Number EPA-HQ-OAR-2003-0119. The RIA estimated 88 existing sources were subject to the standard in 2011, and that the industry would grow at a rate of one new source per year. Since the emission guidelines apply to sources commencing modification or reconstruction before August 7, 2013, we have revised the number of sources to 90 to account for sources modified or reconstructed in the two years between RIA publication (i.e., 2011) and August 7, 2013. Starting on this date, no new sources will be subject to the standard.

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

The “Affected Public” are CISWI units, all of which are owned by private, for-profit businesses. The “burden” to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal). The “burden” to the Federal Government 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 – Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (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, emissions from CISWI units either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the emission guidelines were promulgated for this source category at 40 CFR part 60, subpart DDDD.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensures 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 standard. Continuous emission monitors are used to ensure compliance with the standard at all times.

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 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.

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

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

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

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, EPA 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) 364-3773. 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 CISWI units. The United States Standard Industrial Classification (SIC) codes and corresponding North American Industry Classification System (NAICS) codes for CISWI unit owners and operators are provided in the following table:

Standard (40 CFR Part 60, Subpart DDDD)	SIC Codes	NAICS Codes
Manufacturers of chemicals and allied products	28	325
Manufacturers of electronic equipment	34	325
Manufacturers of wholesale trade, durable goods	25, 36	337, 421
Manufacturers of lumber and wood furniture	24	321
Law enforcement agencies	9229	922
Department of Defense (labs, military bases, munition facilities)	9711	928
Research Centers	8221	6113

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD).A source must make the following reports:

Notifications/Reports
Notification of construction/reconstruction.	60.7(a)(1)
Notification of initial startup date.	60.7(a)(3)
Notification of physical or operational change.	60.7(a)(4)
Notification of demonstration date of continuous monitoring system performance.	60.7(a)(5)
Notification of anticipated date for conducting opacity observations.	60.7(a)(6)
Notification of use of continuous opacity monitoring system data results to determine compliance with opacity standard during performance testing.	60.7(a)(7)
Notification of final control plan.	60.2575, 60.2600, 60.2610
Notification of final compliance.	60.2575, 60.2605, 60.2610
Notifications until increments of progress are met.	60.2595
Notification of closure.	60.2615
Waste management plan.	60.2755
Initial and subsequent performance test reports.	60.2760
Annual report.	60.2765, 60.2770
Emission limitation or operating limit deviation report.	60.2775, 60.2780
Qualified operator deviation notification.	60.2785(a)(1)
Qualified operator deviation status report.	60.2785(a)(2)
Qualified operator deviation notification of resumed operation.	60.2785(b)
Notification of waste-to-fuel switch.	60.2710(a)(4), 60.2790(b)
Notification of air curtain incinerator closure.	60.2855

A source must keep the following records:

Recordkeeping
Maintain records of startups, shutdowns, or malfunctions.	60.7(b)
Retain records for five years.	60.2740
Maintain calendar date of each record.	60.2740(a)
Maintain records of operating parameters.	60.2740(b)
Maintain records of dates when deviation from operating limits has occurred, including reasons for deviations and descriptions of corrective actions taken.	60.2740(e)
Maintain records of initial, annual, and any subsequent performance tests.	60.2740(f)
Maintain records of CISWI unit operators who have completed the operator training requirements.	60.2740(h)
Maintain records of phone and/or pager numbers of CISWI unit operators having met the operator qualification criteria.	60.2740(i)
Maintain records of monitoring device calibrations.	60.7(f), 60.2740(j)
Maintain records of equipment vendor specifications and operation and maintenance requirements for incinerators, emission controls, and monitoring equipment.	60.2740(k)
Maintain records of site-specific procedures; CISWI unit operator review of site-specific procedures; and operator training documentation and contact information.	60.2660(a), 60.2740(l), 60.2660(c), 60.2740(g)
Maintain records of daily log of quantity and types of waste burned.	60.2740(m)
Maintain records of annual inspections of air pollution control devices, any required maintenance, and any repairs not completed within the established timeframe.	60.2740(n)
Maintain records of continuous monitoring systems parameter measurements.	60.7(f), 60.2740(o)
Maintain records indicating date, time, and duration of bypass stack use.	60.2740(p)
Maintain annual records showing previous stack test emission was below 75 percent of applicable limit and that no source operation changes occurred that would increase emissions within the past year.	60.2740(q)
Maintain records of occurrence and duration of process equipment, air control, or monitoring equipment malfunctions.	60.2740(r)
Maintain records of all required maintenance performed on air pollution control and monitoring equipment.	60.2740(s)
Maintain records of actions taken to minimize emissions from process, air pollution control, and monitoring equipment during periods of malfunction.	60.2740(t)
Maintain records showing how non-hazardous secondary materials meet legitimacy criteria or petition process requirements, or showing how materials are listed as non-wastes.	60.2740(u)
Maintain records of criteria establishing unit qualification as a small power production facility, and that proposed waste materials are homogeneous.	60.2740(v)
Maintain records of criteria establishing unit qualification as a cogeneration facility, and that proposed waste materials are homogeneous.	60.2740(w)

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 pollutant control devices.

Perform initial and annual performance tests.

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.

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).

Observe compliance tests (optional).

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.

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). A RIA published in February 2011 by EPA estimated that 88 entities (from a total of 90) were subject to the regulation. Of these facilities, ten were considered to be small businesses. 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.

The rules contain provisions that reduce the impact of the rule on all regulated entities which includes small entities. These are:

1. Operating parameter monitoring is required instead of continuous emissions monitoring systems (CEMS).

2. The owner or operator is allowed to skip two annual performance tests for a pollutant if previous performance tests demonstrate compliance.

3. Deviation reports only required if there is a deviation, otherwise reporting is annual.

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 – Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (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 18,061 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 emission guidelines, 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 type of industry costs associated with the information collection activities in the subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the regulation. The annual operation and maintenance (O&M) costs are the ongoing costs to maintain the monitor(s) 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)
Wet scrubber 1	$2,240	0	$0	$0	0	$0
Annual stack testing 2	$0	0	$0	$12,500	90	$1,125,000
Continuous parameter monitoring (including bypass stack) 3	$0	0	$0	$211	90	$18,990
TOTAL			$0			$1,143,990

¹ Total capital cost of parameter monitoring for wet scrubbers minus planning and equipment selecting cost equals: $18,786 - $800 = $17,986. Based on 0.11746 capital recovery factor, 10 percent interest rate, and 20 year lifetime of the units = $2,113; $2,113 x 1.06 cost adjustment = $2,240.

² Assume 125 contractor hours per respondent and an average contractor labor rate of $100 per hour; 125 x $100 = $12,500.

³ 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)," O&M cost = $1,693 x 0.11746 = $199; $199 x 1.06 cost adjustment = $211.

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 $1,143,990. 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 $1,143,990. These are the costs of recordkeeping.

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 $46,642.

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 – Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (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 90 existing respondents will be subject to the standard. No new respondents will become subject. The overall average number of respondents, as shown in the table below, is 90 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	90	0	0	90
1	0	90	0	0	90
3	0	90	0	0	90
Average		90			90

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 90.

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
Construction/reconstruction notification	0	1	0	0
Startup notification	0	1	0	0
Demonstration date of continuous monitoring system performance notification	0	1	0	0
Anticipated date for conducting opacity observations notification	0	1	0	0
Use of continuous opacity monitoring system data notification	0	1	0	0
Final control plan notification	0	1	0	0
Final compliance notification	0	1	0	0
Waste management plan	0	1	0	0
Initial performance test report	0	1	0	0
Annual report 1	90	1	0	90
Emission limitation or operating limit deviation report 2	9	2	0	18
Qualified operator deviation notification 2	9	1	0	9
Qualified operator deviation status report 2	9	1	0	9
Qualified operator deviation notification of resumed operation 2	9	1	0	9
			Total	135

¹ Annual reports are not required until the second year that units are in operation; therefore, annual reports will only apply to existing sources (i.e., 90 respondents).

² Assume that these activities will apply to 10 percent of existing sources.

The number of Total Annual Responses is 135.

The total annual labor costs are $1,748,799. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (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 (below), respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 18,061 hours at a cost of $1,748,799. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 134 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,143,990. 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 1,035 labor hours at a cost of $46,642. See below Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal).

6(f) Reasons for Change in Burden

There is a change in the total estimated respondent and Agency burden and cost as currently identified in the OMB Inventory of Approved Burdens. The change from the most recently approved ICR is due to several reasons.

First, the previous ICR included contractor labor costs associated with annual stack testing and continuous parameter monitoring as a respondent burden. Since the contractor labor costs apply solely to O&M activities, we have revised the ICR to reflect these as O&M costs, resulting in an apparent decrease in the total respondent labor burden.

Second, this ICR revises the number of respondents based on more recent information obtained from a 2011 Regulatory Impact Analysis (RIA) conducted by EPA. The previous ICR estimated 97 existing sources were subject to the standard; however, the RIA indicates there are approximately 90 existing sources. This ICR reflects the most recent information obtained from the 2011 RIA, and contributes to the apparent decrease in the respondent and Agency labor burdens.

Finally, there is a slight increase in Agency burden costs from the most recently approved ICR due to the use of updated labor rates. This ICR references labor rates from the Bureau of Labor Statistics to calculate respondent burden costs and references labor rates from OPM to calculate Agency burden costs.

There is an apparent increase in the O&M costs as compared to the previous ICR. As described above, the previous ICR included contractor labor costs associated with annual stack testing and continuous parameter monitoring as a respondent burden. The revision to reflect these activities as O&M costs resulted in the apparent increase of the total O&M cost.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 134 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-2012-0685. 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-2012-0685 and OMB Control Number 2060-0451 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 – Emission Guidelines for Commercial and Industrial Solid Waste Incineration

Units (40 CFR Part 60, Subpart DDDD) (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 person hours per year (CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.10)	Total cost per year ($) b
1. Applications
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	16	1	16	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 (including by-pass stack) e	9	1	9	0	0	0	0	$0
2) Periodic requirements
a) Annual stack test and test report	12	1	12	90	1,080	54	108	$120,261.24
b) Annual refresher operator training course	12	1	12	90	1,080	54	108	$120,261.24
c) Annual review of site-specific information	8	1	8	90	720	36	72	$80,174.16
d) Continuous parameter monitoring (including by-pass stack) f	83	1	83	90	7,470	373.5	747	$831,806.91
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Control plan	40	1	40	0	0	0	0	$0
2) Notification of final compliance	4	1	4	0	0	0	0	$0
3) Report of initial performance test	8	1	8	0	0	0	0	$0
4) Siting analysis for new units only (established values for site-specific operating parameters)	8	1	8	0	0	0	0	$0
5) Waste management plan	160	1	160	0	0	0	0	$0
6) Annual Report: g
a) Site specific operating parameters	8	1	8	90	720	36	72	$80,174.16
b) Emissions/parameter exceedances and malfunctions	See 3E
c) Results of stack tests conducted during the year	See 3B
d) Statement of no exceedances	8	1	8	90	720	36	72	$80,174.16
e) Documentation of use of by-pass stack	See 3B
f) Documentation for periods when all qualified operators were unavailable for more than 8 hours	8	1	8	90	720	36	72	$80,174.16
7) Status report for operators that are off-site for more than 2 weeks h	8	1	8	9	72	3.6	7.2	$8,017.42
8) Corrective action summary for operators that are off-site for more than 2 weeks h	8	2	16	9	144	7.2	14.4	$16,034.83
9) Qualified operator deviation notification of resumed operation	8	1	8	9	72	3.6	7.2	$8,017.42
10) Semiannual report of emissions/parameter exceedances i	12	2	24	9	216	10.8	21.6	$24,052.25
Subtotal for Reporting Requirements					14,966.1			$1,449,147.94
4. Recordkeeping Requirements
A. Read Instructions	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record Information
1) Records of operating parameters	See 3B
2) Records of periods for which minimum amount of data on operating parameters were not obtained	0.5	52	26	9	234	11.7	23.4	$26,056.6
3) Records of malfunction of the unit	1.5	1	1.5	9	13.5	0.68	1.35	$1,503.27
4) Records of exceedances of the operating parameters	1.5	1	1.5	9	13.5	0.68	1.35	$1,503.27
5) Records of stack tests	See 3E
6) Records of persons who have reviewed operating procedures	1	1	1	90	90	4.5	9	$10,021.77
7) Records of persons who have completed operator training	1	1	1	90	90	4.5	9	$10,021.77
8) Records of persons who meet operator qualification criteria	1	1	1	90	90	4.5	9	$10,021.77
9) Records of monitoring device calibration	See 3B
10) Records of site-specific documentation	24	1	24	90	2,160	108	216	$240,522.48
F. Personnel Training	See 3B
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					3,094.66			$299,650.92
TOTAL ANNUAL BURDEN AND COST (rounded)					18,061			$1,748,799

Assumptions:

^a. We estimate that an average of 90 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. This activity is based on a one-time cost only.

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

^e. Based on the “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions (A-91-61,IV-B-66)," we assume 9 hours (($300 for planning + $500 for selection)/$89.94 per hour = 9 hours).

^f. Based on the "Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions (A-91-61, IV-B-66)," respondents spend 83 hours for reporting.

^g. Respondents make one combined annual report per year.

^h. 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.

^i. Assume that 10 percent of the facilities will have an exceedance during the year.

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration

Units (40 CFR Part 60, Subpart DDDD) (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	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) a
1. Applications	N/A
2. Read rule requirements	16	0	0	0	0	0	0	$0
3. Required Activities
Report Reviews
1) Review control plan	8	1	8	0	0	0	0	$0
2) Review notification of final compliance	8	1	8	0	0	0	0	$0
3) Review waste management plan	8	1	8	0	0	0	0	$0
4) Review initial stack test report	40	1	40	0	0	0	0	$0
5) Review annual compliance report	8	1	8	90	720	36	72	$37,313.64
6) Review semi-annual excess emission and parameter exceedance report b	16	1	16	9	144	7.2	14.4	$7,462.73
7) Review status reports and corrective action summary for operators off-site b	4	1	4	9	36	1.8	3.6	$1,865.68
TOTAL ANNUAL BURDEN AND COST (rounded)					1,035			$46,642

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 assume that 10 percent of the facilities will have exceedance reports and operator off-site reports.