1058ss11

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Incinerators (40 CFR Part 60, Subpart E) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Incinerators (40 CFR Part 60, Subpart E) (Renewal), EPA ICR Number 1058.11, OMB Control Number 2060-0040

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Incinerators were promulgated on July 25, 1977, and amended on May 10, 2006. These regulations apply to incinerators that charge more than 45 metric tons per day (50 tons per day) of solid waste, and that commenced construction or modification after August 17, 1971. Solid waste is defined as refuse that is more than 50 percent municipal wastes. Additionally, incinerators that are covered by Part 60, subpart Cb, Eb, AAAA, or BBBB (covered under an EPA-approved State section 111(d)/129 plan implementing subpart Cb or BBB, or covered under Part 62, subpart FFF or JJJ) are not subject to this standard. This information is being collected to assure compliance with 40 CFR part 60, subpart E.

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 the 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 two 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 82 respondents per year will be subject to the standard. We estimate that no new sources will become subject to the standards over this period, since new sources will be subject to either 40 CFR part 60, subpart Eb, or 40 CFR part 60, subpart AAAA. Large municipal waste combustors (MWC) with a capacity greater than 250 tons per day that are constructed, modified, or reconstructed after September 20, 1994 are subject to 40 CFR part 60, subpart Eb. Small MWCs with capacities of 35 to 250 tons per day of municipal solid waste that commenced construction after August 30, 1999, or commenced reconstruction or modification after June 6, 2001, are subject to 40 CFR part 60, subpart AAAA. While no new sources are expected to be subject to reporting requirements, existing sources must continue to comply with the recordkeeping requirements of the standard.

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

Prior to submission of a request to extend this collection, the agency should revisit estimates of burden taking into account recent experience with the program.

EPA has addressed this concern by reviewing and updating the burden estimates accordingly. Specific updates are discussed in detail in Section 6(f).

The “Affected Public” are owners or operators of incinerators. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Incinerators (40 CFR Part 60, Subpart E) (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 – NSPS for Incinerators (40 CFR Part 60, Subpart E) (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, particulate air emissions from municipal incinerators cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart E.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these 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 standard, and serve as a record of the operating conditions under which compliance was achieved. Continuous emission monitors are used to ensure compliance with the standard at all times.

The notifications required in the standard are used to inform either 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, that leaks are being detected and repaired, and that 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.

The information generated by the monitoring, recordkeeping, and reporting requirements described in this ICR is used by the Agency to ensure that facilities subject to the NSPS continue to operate control equipment in compliance with the standard. Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable regulations, as required by the Clean Air Act. The information collected from recordkeeping and reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court.

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

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

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 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.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (see 40 CFR 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 owner and operators of incinerators. The United States Standard Industrial Classification (SIC) codes and corresponding North American Industry Classification System (NAICS) codes for incinerators are provided in the following table.

Standard (40 CFR Part 60, Subpart E)	SIC Codes	NAICS Codes
Air and Water Resource and Solid Waste Management	9511	924110
Refuse Systems (hazardous waste treatment and disposal)	4953	562211
Refuse Systems (material recovery facilities)	4953	562920
Refuse Systems (other nonhazardous waste treatment and disposal)	4953	562219
Refuse Systems (solid waste combustors and incinerators)	4953	562213
Refuse Systems (solid waste landfills)	4953	562212

Data from the 2000 inventory of large MWCs and the 2001 inventory of small MWCs indicated that, on average, 75.5 percent of large and small MWCs are publicly-owned, while the remaining 24.5 percent are privately-owned.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Incinerators (40 CFR Part 60, Subpart E).

A source must make the following reports:

Notifications/Reports
Notification and application of construction or modification.	60.7(a)(1)
Notification of anticipated date of initial startup.	60.7(a)(2)
Notification of actual startup.	60.7(a)(3)
Notification of physical or operational change which may increase the emission rate.	60.7(a)(4)
Notification of initial performance tests.	60.8(d), 60.52(a), and 60.54(a)
Initial performance test results, to determine the conditions of the performance test, and performance test measurements and results.	60.8(d), 60.52(a), and 60.54(a)

A source must keep the following records:

Recordkeeping
Records of the occurrence and duration of any startup, shutdown, or malfunction in operation of an affected facility.	60.7(b)
Records of malfunctions of the air pollution control equipment.	60.7(b)
Records of periods when the system is inoperative.	60.7(b)
Records of daily charging rates and hours of operation.	60.53(a)
Records of the initial performance test and performance test measurements and results.	60.8(c), 60.52(a) and 60.54(a)
Maintain records for two years.	60.7(f)

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 compliance monitoring system (CMS) for opacity, or for pressure drop and liquid supply pressure for wet scrubber.

Perform initial performance test, Reference Method 1, 2, 3B, and 5 test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

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

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

Transmit, or otherwise disclose the information.

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 reduced the burden associated with monitoring and recordkeeping significantly.

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 test, 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, 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 two 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. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

Data from a 1996 inventory of municipal waste combustors indicated that 21 percent of affected sources were located in an area with less than 50,000 people. This was the basis of our estimate for affected small businesses for this ICR renewal.

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 – NSPS for Incinerators (40 CFR Part 60, Subpart E) (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 8,393 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	(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)
Particulate matter	$5,000	0	0	$2,500	82	$205,000

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 $205,000. 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 $205,000. 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 $0; however, the potential for rate costs requiring mentioning (see below).

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-based rates of pay. The rates would 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 Incinerators (40 CFR Part 60, Subpart E) (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 82 existing respondents will be subject to the standard. It is estimated that no additional respondents per year will become subject to the rule; therefore, the overall average number of respondents, as shown in the table below, is 82 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	82	0	0	82
2	0	82	0	0	82
3	0	82	0	0	82
Average	0	82	0	0	82

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 82.

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
Notification reports	0	0	0	0
Compliance reports	0	0	0	0
Records of startup, shutdown, and malfunction (SSM), emissions monitoring system, and initial performance test results	0	0	82	82
Records of daily charging rates and hours of operation	0	0	82	82
			Total	164

The number of Total Annual Responses is 164.

The total annual labor costs are $812,654. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Incinerators (40 CFR Part 60, Subpart E) (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 below shown in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 8,393 hours at a cost of $812,654. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Incinerators (40 CFR Part 60, Subpart E) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 51 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $205,000. 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 zero labor hours at a cost of $0. See below Table 2: Average Annual EPA Burden and Cost – NSPS for Incinerators (40 CFR Part 60, Subpart E) (Renewal).

6(f) Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the previous ICR. This is due to two considerations: 1) the regulations have not changed over the past three years and are not anticipated to change over the next three years; and 2) the growth rate for the industry is non-existent, so there is no significant change in its overall burden.

There is an adjustment increase in the estimated respondent burden cost as currently identified in the OMB Inventory of Approved Burdens. This increase is due to the use of updated labor rates from the Bureau of Labor Statistics.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 51 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-2012-0646. 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-2012-0646 and OMB Control Number 2060-0040 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 Incinerators (40 CFR Part 60, Subpart E) (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	1	1	1	0	0	0	0	$0
B. Required activities
Initial performance test c, d	200	1	200	0	0	0	0	$0
C. Create information on performance test	See 3B
D. Gather existing information	See 3E
E. Write Report
Notification of construction/ reconstruction c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of physical and operational changes which may increase emission rates of any regulated pollutants	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Report of initial performance test results c	4	1	4	0	0	0	0	$0
Compliance status reports e	4	1	4	0	0	0	0	$0
Subtotal for Reporting Requirements					0			$0
4. Recordkeeping Requirements
A. Read instructions	See 4E
B. Plan activities	See 4E
C. Implement activities	See 4E
D. Develop record system	N/A
E. Time to enter information
Record of occurrence and duration of startup, shutdown, or malfunction; emissions monitoring system; and initial performance test results	1.5	1	1.5	82	123	6.15	12.3	$13,696.42
Records of daily charging rates and hours of operation f	0.25	350	87.5	82	7,175	358.75	717.5	$798,957.78
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					8,392.7			$812,654.20
TOTAL ANNUAL BURDEN AND COST (rounded)					8,393			$812,654

Assumptions:

^a. We estimate that an average of 82 existing respondents per year will be subject to the rule, and that no new, modified, or reconstructed facilities will become subject 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. We assume this is a one-time-only cost.

^d. We assume it takes 60 technical hours for pretests/test preparation, 60 technical hours for testing, and 80 technical hours for analysis and report preparation.

^e. This rule does not require semiannual reporting, just recordkeeping.

^f. We assume it will take 0.25 hours per day over 350 days per year to record daily charging rates.

Table 2: Average Annual EPA Burden and Cost – NSPS for Incinerators (40 CFR Part 60, Subpart E) (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
Notification of construction/ reconstruction b, c	2	1	2	0	0	0	0	$0
Notification of actual startup b, c	2	1	2	0	0	0	0	$0
Notification of physical and operational changes which may increase emission rates of any regulated pollutant	2	1	2	0	0	0	0	$0
Compliance status report d	4	1	4	0	0	0	0	$0
Test results d, e	8	1	8	0	0	0	0	$0
Audit and review facility records	6	1	6	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)					0			$0

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 there will be no new, modified, or reconstructed facilities constructed over the next three years.

^c. We assume this is a one-time-only cost.

^d. This rule does not require semiannual reporting, only recordkeeping.

^e. We assume it will take eight hours to review test results.