2163ss05

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE) (Renewal), EPA ICR Number 2163.05, OMB Control Number 2060-0563.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Other Solid Waste Incineration (OSWI) Units (40 CFR Part 60 Subpart EEEE) were proposed on December 9, 2004, promulgated on December 16, 2005, and revised on November 24, 2006. These regulations apply to very small municipal waste combustion units and institutional waste incineration units. A new incineration unit subject to this subpart should meet either of the two criteria: 1) commenced construction after December 9, 2004; or 2) commenced reconstruction or modification on or after June 16, 2006. A very small municipal waste combustion unit is any municipal waste combustion unit that has the capacity to combust less than 35 tons per day of municipal solid waste or refuse-derived fuel. An institutional waste incineration unit is any combustion unit that combusts institutional waste and is a distinct operating unit of the institutional facility that generated the waste. Institutional waste is solid waste that is combusted at any institutional facility using controlled flame combustion in an enclosed, distinct operating unit: whose design does not provide for energy recovery; operated without energy recovery; or operated with only waste heat recovery. Institutional waste also means solid waste combusted on site in an air curtain incinerator that is a distinct operating unit of any institutional facility. This information is being collected to assure compliance with 40 CFR Part 60, Subpart EEEE.

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 United States Environmental Protection Agency (EPA) regional office.

Currently there are no OSWI units that subject to the regulations, and it is estimated that no additional respondents per year will become subject to the regulation over the next three years. The economical cost of complying with the proposed NSPS makes it more likely that sources will select an alternative method of waste disposal.

Based on the information gathered including the results of our consultations, we have concluded that, to date, no new OSWI units are being constructed, even in the absence of regulations, because other waste disposal alternatives, such as landfills, are more economical. Therefore, the number of respondents remains at zero.

The active 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 ensure these estimates have been updated. In particular, EPA should reevaluate the universe in light of the definition of non-hazardous waste regulation.

EPA has addressed each item of concern in the TOC by consulting our internal experts and industry trade associations. We believe the respondent universe remains to be zero.

All of the OSWI units in the United States are owned and operated by the solid waste incineration industry (the “Affected Public”), which is privately- owned, for-profit businesses. None of the facilities in the United States are owned by state, local, tribal or the Federal government. The burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed by federal employees or government contractors and can be found in Table 2: Average Annual EPA Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE) (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 matter, sulfur dioxide, hydrogen chloride, nitrogen oxides, carbon monoxide, lead, cadmium, mercury, and dioxin/furans emissions from OSWI units cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR Part 63, Subpart EEEE.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure 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 standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in the 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, that leaks are being detected and repaired and the standard are being met. The performance test may also be observed.

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

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 60, Subpart EEEE.

3(a) Nonduplication

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, no duplication exists.

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 (79 FR 30117) on May 27, 2014. Two comments were received on the burden published in the Federal Register and is addressed in section 3(c) below.

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 Enforcement and Compliance History Online (ECHO), which is operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this ICR, we contacted the National Solid Waste Management Association (NSWMA) at (202) 364-3773, and the Solid Waste Association of North America (SWANA) at (240) 494-2253. The 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. EPA received two comments in response in the first Federal Register notice, but the comments do not contain any substantive recommendations specific to this NSPS and did not result in changes to this ICR.

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 (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 OSWI units. The United States Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) codes for the respondents affected by the standards are listed below.

Standard (40 CFR, Part 60, Subpart FFFF)	SIC Codes	NAICS Codes
Solid Waste Combustors and Incinerators	4953	562213
Administration of Air and Waste Resource and Solid Waste Management Programs	None	92411
Elementary and Secondary Schools	None	6111
Nursing and Residential Care Facilities	None	623
Justice, Public Order, and Safety Activities	None	922
National Security and International Affairs	None	928
Junior Colleges	None	6112
Colleges, Universities, and Professional Schools	None	6113
Museums, Historical Sites, and Similar Institutions	None	7121
Religious Organizations	None	8131
Civic and Social Organizations	None	8134

4(b) Information Requested

(i) Data Items

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

A source must make the following reports:

Notifications
Notification to commence construction	60.2952 (a)-(e)
Notification of initial startup	60.2953
Notification of qualified operator deviation	60.2959(a)(1)
Notification of resumed operation	60.2959(b)

Reports
Pre-construction report	60.2952
Initial test report	60.2954
Annual report	60.2955, 60.2956
Qualified operation deviation status report	60.2959(a)(2)
Semiannual report of deviation	60.2957, 60.2958
Waste management plan	60.2900

A source must keep the following records:

Recordkeeping
The OSWI unit charge dates, times, weights, and hourly charge rates.	60.2949(b)(1)
Liquor flow rate to the wet scrubber inlet, pressure drop across the wet scrubber system or amperage to the wet scrubber, and liquor pH as introduced to the wet scrubber every 15 minutes of operation, as applicable.	60.2949(b)(2) – (4)
Data collected for all operating parameters used to determine compliance with the operating limits.	60.2949(b)(5)
Average concentrations of carbon monoxide emissions and continuously monitored operating parameters.	60.2949(b)(6) – (7)
Records of the dates, times, and durations of any bypass of the control device.	60.2949(b)(8)
Dates, times, durations and descriptions of malfunctions or when monitoring systems were inoperative, inactive, or out of control. A description of corrective actions taken.	60.2949(c), (d)
Dates, times and descriptions of monitoring data deviations from emissions or operating limits, and description of corrective actions taken.	60.2949(e)
Maintain records of all initial, annual and occasional performance test reports.	60.2949(i)
Records of operator training and qualifications.	60.2949(k), (l), (m)
Procedures for receiving, handling, and charging waste; incinerator startup, shutdown; maintaining proper combustion air supply levels; operating the incinerator and control systems; monitoring, reporting and recordkeeping; and ash handling.	60.2910(a)
Maintain waste management plan records	60.2901

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.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate continuous emission monitoring systems (CEMS) for carbon monoxide and oxygen.

Perform initial performance test, Reference Method 1, 3A, 3B, and 26A tests, 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.

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

Transmit, or otherwise disclose the information.

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 Integrated Compliance Information System (ICIS) and ECHO.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS 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

There are no small entities affected by this regulation.

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 Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE)(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 zero (Total Labor Hours from Table 1). 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 $129.93 ($61.87 + 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “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 costs are the ongoing costs to maintain the monitor 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)
Continuous emission monitoring system	$44,445	0	$0	$5,000	0	$0
			$0			$0

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

The total operation and maintenance (O&M) costs for this ICR are zero. 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 zero because there are no respondents subject to this standard. These are recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be zero.

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%)

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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 Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE)(Renewal).

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

Based on our research for this ICR, no respondent will be subject to this standard in the next three years. It is estimated that no additional respondents per year will become subject. The overall average number of respondents, as shown in the table below, is zero per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR.

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
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	0	0	0	0
2	0	0	0	0	0
3	0	0	0	0	0
Average	0	0	0	0	0

¹ New respondents 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 zero.

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 to commence construction	0	1	0	0
Notification of initial startup	0	1	0	0
Notification of deviation	0	1	0	0
Initial test report	0	0	0	0
Waste management plan	0	1	0	0
Annual compliance reports	0	0	0	0
Semiannual deviation reports	0	0	0	0
			Total	0

The number of Total Annual Responses is zero.

The total annual labor costs are zero. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE)(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 zero. Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE)(Renewal). We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

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

The total annual capital/startup and O&M costs to the regulated entity are zero. 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 Table 2: Average Annual EPA Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE)(Renewal). We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is no change in the labor hours or cost in this ICR compared to the previous ICR. At present, there are no OSWI units subject to the regulations, and no new units are expected to be constructed or operated over the next three years. It is assumed that potential respondents would use alternative methods of waste disposal that are more economical, e.g. landfills, rather than replacing existing OSWI units. As a result, no respondent or agency burdens or costs have been estimated, and no annual burden is expected.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average zero 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-2014-0094. 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) 566-1927. 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-2014-0094 and OMB Control Number 2060-0563 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 Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE)(Renewal)

Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Read instructions c	40	1	40	0	0	0	0	$0
B. Required activities
1) Initial performance test and reports
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg) c	24	1	24	0	0	0	0	$0
b) Repeat of initial performance tests	24	1	24	0	0	0	0	$0
2) CEMS demonstration (CO, 02)
a) Repeat of initial demonstration	229	1	229	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	24	1	24	0	0	0	0	$0
4) Daily calibration and operation d	1	250	250	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
1) Preconstruction report	8	1	8	0	0	0	0	$0
2) Startup notification	2	1	2	0	0	0	0	$0
3) Initial test report c	40	1	40	0	0	0	0	$0
4) Annual compliance reports	40	1	40	0	0	0	0	$0
5) Semiannual deviation reports	24	2	48	0	0	0	0	$0
Subtotal for Reporting Requirements						0		$0
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 SSM e	1.5	52	78	0	0	0	0	$0
2) Records of emission rate computations, all emission exceedances and periods when there is no data e	1.5	52	78	0	0	0	0	$0
3) Records of employee review of operations manual	4	1	4	0	0	0	0	$0
4) Record of control devices operating parameters e	1.5	52	78	0	0	0	0	$0
F. Perform Audits	N/A
Subtotal for Recordkeeping Requirements						0		$0
TOTAL LABOR BURDEN AND COST (rounded)						0		$0
Capital and O&M Cost								$0
GRAND TOTAL (Labor Cost + Capital/O&M)								$0

Assumptions:
a We have assumed that there are no OSWI units that are currently subject to the regulations, and it is estimated that no new units are expected to be constructed or in operation over the next three years.
b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 “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 have assumed that this is a one-time only cost.
d We have assumed that each respondent will take 1 hour 250 times per year to record daily calibration and operation.
e We have assumed that each respondent will record information 52 times per year. Note: Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NSPS for Other Solid Waste Incineration Units (40 CFR Part 60, Subpart EEEE)(Renewal)

Activity		(A) EPA person- hours per occurrence		(B) No. of occurrences per plant per year		(C) EPA person- hours per plant per year (C=AxB)		(D) Plants per year a	(E) Technical person- hours per year (E=CxD)		(F) Management person-hours per year (Ex0.05)		(G) Clerical person-hours per year (Ex0.1)		(H) Cost, $ b
1. Applications		N/A
2. Read and understand rule requirements		16		1		16		0	0		0		0		$0
3. Required activities
A. Create information		N/A
B. Gather information		See 3A & 3F
C. Report reviews
1) Notification of final compliance c		1.5		1		1.5		0	0		0		0		$0
2) Review initial compliance test report c		40		1		40		0	0		0		0		$0
3) Review annual compliance report		40		1		40		0	0		0		0		$0
4) Review semiannual deviation reports		16		2		32		0	0		0		0		$0
5) Review waste management plan c		16		1		16		0	0		0		0		$0
D. Annual summary report d		4		1		4		0	0		0		0		$0
TOTAL ANNUAL BURDEN AND COST (rounded)									0						$0
	Assumptions:
	a We have assumed that there are no OSWI units that are currently subject to the regulations, and it is estimated that no new units are expected to be constructed or in operation over the next three years.
	b This cost is based on the following hourly labor rates: $62.90 for Managerial (GS-13, Step 5, $39.31 + 60%), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2014 General Schedule”, which excludes locality rates of pay. These rates have been increased by 60 percent to account for the benefit packages available to government employees.
	c We have assumed that this is a one-time only cost.
	d We have assumed that all affected facilities will be required to prepare an annual summary plan.