1901ss06_deliverable_mbm_ERG-clean

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal), EPA ICR Number 1901.06, OMB Control Number 2060-0424.

1(b) Short Characterization/Abstract

The Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 were originally promulgated in December 1995, but were vacated by the Federal Court in March 1997. Subsequently, the Emission Guidelines were re-proposed on August 30, 1999, and promulgated on December 6, 2000 (65 FR76378). The Emission Guidelines regulate organics (dioxin/furans), metals (cadmium, lead, mercury), particulate matter, and acid gases (hydrogen chloride, sulfur dioxide, and nitrogen oxides) for small Municipal Waste Combustion (MWC) units. Small MWC units are MWC units with capacities to combust greater than 35 tons per day (tpd) and less than 250 tons per day (tpd) of municipal solid waste. The Emission Guidelines contain monitoring, reporting, and recordkeeping requirements that are to be included in state plans. This Information Collection Request (ICR) identifies the burden for States and U.S. territories to develop and implement State plans, and the burden for small MWCs imposed by these State plans. This information is being collected to assure compliance with 40 CFR Part 60, Subpart BBBB.

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 United States Environmental Protection Agency (EPA) regional office.

The “Affected Public” is owners and operators of existing small MWC units. The burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost –Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal). The “Federal Government” burden is attributed entirely to work performed by federal employees or government contractors and may be found in Table 2: Average Annual EPA Burden and Cost –Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal).

Based on our consultations with industry representatives, there are an average of 2.3 affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 54 facilities located at 23 plants (23 respondents) per year will be subject to the Emission Guidelines. Of the 23 respondents, 19 are privately-owned, and 4 are owned by state, or local, or tribal governments. Since the Emission Guidelines only apply to sources that commenced construction on or before August 30, 1999, no additional MWC units will become subject to the standard over the next three years.

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

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; . . ..

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, 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 BBBB.

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 (80 FR 32116) on June 5, 2015. 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. 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 both the Solid Waste Association of North America (SWANA), at (240) 494-2253; the National Solid Waste Management Association (NSWMA), at (202) 364-3773; Veolia ES Solid Waste at (414) 479-7883; and Covanta, at (973) 882-7253.

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. In this case, no comments were received.

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 small MWC units constructed on or before August 30, 1999. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards, and the corresponding North American Industry Classification System (NAICS) codes are listed in the table below.

Standard (40 CFR Part 60, Subpart BBBB)	SIC Codes	NAICS Codes
Air and Water Resource and Solid Waste Management	9511	92411
Refuse System; Solid Waste Combustors and Incinerators	4953	562213

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB).

State/US protectorates must perform the following requirements:

Requirement
Submit a state plan	60.1505
Submit a negative declaration	60.1510

A source must make the following reports:

Notifications
Construction/reconstruction	60.7(a)(1)
Notification of completion of each increment of progress	60.1585
Actual startup	60.7(a)(3)
Performance test and demonstration of continuous monitoring system	60.7(a)(5)
Physical or operational change	60.7(a)(4)

Reports
Initial report	60.8 (a) & (d), 60.1860, 60.1875
Annual Report	60.1680, 60.1880
Semiannual reports for any emission or parameter that does not meet limits	60.1680, 60.1890, 60.1895, 60.1900

A source must keep the following records:

Recordkeeping
Startups, shutdowns, and malfunctions, periods where the continuous monitoring system is inoperative.	60.7(b)
Emission test results and other data needed to determine emissions.	60.1830, 60.1835, 60.1845
Operator training & certification	60.1830, 60.1835, 60.1840
Record for MWCs using activated carbon	60.1830, 60.1835, 60.1855
Records for continuously monitored pollutants or parameters.	60.1830, 60.1850
Records are required to be retained for 5 Years. All five years of records must be retained at the facility.	60.1835

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

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CEMS for SO₂, NO_x, opacity, CO, CO₂ & O₂.

Perform initial performance test and reports (PM, dioxin/furans, opacity, fugitives, HCL, Cd, Pb, Hg), 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 the Enforcement and Compliance History Online (ECHO) and ICIS.

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 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 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

Some of the small MWC units potentially affected by the Emission Guidelines are owned by small businesses, non-profit organizations or governments. The EPA does not expect the standards to adversely affect these small entities. The standards only apply to units with capacities between 35 tpd and 250 tpd. Furthermore, the standards contain provisions for reduced testing. Owners of small MWC units where the aggregate plant capacity is less than 250 tpd can skip annual tests for 2-year periods for certain pollutants if they have demonstrated compliance for three annual tests in a row. In addition to this 3-year testing option, less frequent dioxin/furan testing is possible if all units at a plant achieve emission levels less than the emission limit for two consecutive years. This provision allows plants to test only one unit per year, rather than all units, as normally required.

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 – Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (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 102,000 (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 Emission Guidelines 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)
Load monitors, temperature monitors, and carbon federate monitors (Sections 60.1315 thru 60.1335)	$200,000	0	$0	$19,200	54	$1,036,800
TOTAL						$1,040,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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

The total operation and maintenance (O&M) costs for this ICR are $1,040,000. 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 $1,040,000.

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 $125,000.

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), 2015 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 and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal).

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

There are 55 States and U.S. territories subject to the Emission Guidelines. These are the air quality programs in 50 States, one federal district, and four U.S. territories.

In addition, the regulations developed under the emissions guidelines apply to small MWC’s. Based on our research for this ICR, on average over the next three years, approximately 23 existing respondents (19 privately-owned, and 4 state, or local, or tribal governments) will be subject to the standard. It is estimated that no additional respondents per year will become subject. The overall average number of respondents, as shown in the table below, is 23 per year.

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

Number of State and U.S. Protectorate
	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	55	0	0	55
2	0	55	0	0	55
3	0	55	0	0	55
Average	0	55	0	0	55

Note: The respondents include the 50 States, one federal district (Washington D.C.), and four territories (America Samoa, Puerto Rico, Virgin Islands, and Northern Mariana Islands). See 40 CFR Part 62.

¹ New respondents are those who previously submitted a negative declaration but subsequently identify find a small MWC unit.

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	23	0	0	23
2	0	23	0	0	23
3	0	23	0	0	23
Average	0	23	0	0	23

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 23.

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
State plan	0	1	0	0
Negative Declaration	0	1	0	0
Plant Startup (Plant Control Plan, notifications, etc.)	0	5	0	0
Notifications (Performance Test, CEMS Demonstration, etc.)	0	4	0	0
Annual Reports	23	2.35	0	54.05
Semiannual Excess Emission Reports	2.3	2	0	4.6
			Total	59 (Rounded)

The number of Total Annual Responses is 59 (rounded) (49 for privately-owned MWC units and 10 for state, or local, or tribal government MWC units).

The total annual labor costs are $10,200,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 102,000. Of this burden, 84,300 hours are attributed to sources owned by the private sector, and 17,700 hours are attributed to sources owned by state and local government. Details regarding these estimates may be found in Table 1: Annual Respondent Burden and Cost – Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (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 1,729 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,040,000. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

Category	No. of Respondents	Reporting Hours	Record-keeping Hours	Total Labor Hours	Respondent Labor Cost	Capital & O&M Cost	No. of Responses
Private	19	75,600	8,700	84,300	$8,430,000	$859,000	49
State & Local Government	4	15,900	1,800	17,700	$1,770,000	$181,000	10
Total	23	91,500	10,500	102,000	$10,200,000	$1,040,000	59

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 2,750 labor hours at a cost of $125,000. See Table 2: Average Annual EPA Burden and Cost – Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (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 an adjustment increase in the respondent burden from the most recently approved ICR. The increase in respondent labor hour is caused by a change in assumption; in this ICR, we assume all existing sources will take some time each year to re-familiarize themselves with the rule requirements. There is also a small increase in the total O&M cost due to rounding of all calculated values to three significant digits.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,729 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-2012-0517. 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-2012-0517 and OMB Control Number 2060-0424 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 and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal)

Burden item	(A) Person-hours per occurrence	(B) No. of occurrence per respondent per year	(C) Person-hours per respondent per year	(D) Respondents per yeara	(E) Technical person-hours per year	(F) Management person-hours per year	(G) Clerical person hours per year	(H) Cost b $
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Read and Understand Rule Requirements	40	1	40	23	920	46	92	$106,394.27
B. Required Activities
i.  Initial performance tests and reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	0	0	0	0	$0
ii. CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)
a. Installation of CEM units	225	1	225	0	0	0	0	$0
b. Initial demonstration	450	1	450	0	0	0	0	$0
iii. Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	23	17,825.00	891.25	1782.5	$2,061,389.06
iv. Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a. RATA audit (one per year)	350	2.3	805	23	18,515.00	925.75	1,851.5	$2,141,184.76
b. RAA audit (three per year)	130	6.9	897	23	20,631.00	1,031.55	2,063.1	$2,385,891.59
c. Daily calibration and operation	1	840	840	23	19,320.00	966	1932	$2,234,279.75
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
i. Plant startup
a. Plant Control Plan	40	1	40	0	0	0	0	$0
b. Notification of Contract Awards	4	1	4	0	0	0	0	$0
c. Notification of on-site construction start	4	1	4	0	0	0	0	$0
d. Notification of construction completion	4	1	4	0	0	0	0	$0
e. Notification of final completion	4	1	4	0	0	0	0	$0
ii. Notification of initial performance tests	4	1	4	0	0	0	0	$0
iii. Initial compliance reports	40	1	40	0	0	0	0	$0
iv. Notification of CEMS demonstration	4	1	4	0	0	0	0	$0
v. Initial CEMS demonstration report	90	1	90	0	0	0	0	$0
vi. Annual compliance reports	40	2.3	92	23	2,116	105.8	211.6	$244,706.83
vii. Semiannual excess emission reports	40	2	80	2.3	184	9.2	18.4	$21,278.85
Reporting Subtotal					91,438			$9,195,125.13
4. Recordkeeping Requirements
A. Read and Understand Rule Requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record information
i. Record startups, shutdowns, and malfunctions h	4	47	188	23	4,324	216.2	432.4	$500,053.09
ii. Records of all emission rates, computations, tests	4	47	188	23	4,324	216.2	432.4	$500,053.09
iii. Records of employee review of operations manual	4	1	4	23	92	4.6	9.2	$10,639.43
iv. Record amount of sorbent used for Hg and dioxin/furan control	4	4	16	23	368	18.4	36.8	$42,557.71
F. Personnel Training	N/A
G. Time for audits	N/A
Recordkeeping subtotal					10,474			$1,053,303.31
TOTAL LABOR BURDEN AND COST (Rounded):i					102,000			$10,200,000
Capital and O&M Cost (see Section 6(b)(iii)): i								$1,040,000
TOTAL COST: i								$11,200,000

Assumptions:

^a Assumes an average of 2.3 affected facilities (i.e., sources or units) per respondent [53 facilities at 23 plants; 53/23 = 2.3 (Rounded)].

^b No additional facilities will become subject to the standard over the next three years.

^c 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.

^d Relative accuracy test audits (RATA) occur once per year for each affected facility (1 x 2.3 = 2.3). RATA are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.

^e Relative accuracy audits (RAA) occur three times per year for each affected facility (3 x 2.3 = 6.9).

^f Daily calibration and operation data occurs daily [365 x 2.3 = 840 (Rounded)].

^g Assumes 10 percent of sources (2.3) have affected facilities with excess emissions and must submit two semiannual reports.

^h Assumes 47 weeks of operation (90 percent availability) per year per facility.

ⁱ Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal)

Activity	(A) Number of occurrence per year	(B) EPA person-hours per occurrence	(C) Technical person-hours per year	(D) Management person-hours per year	(E) Clerical person-hours per year	(H) Costa $
			(C=AxB)	(Ex0.05)	(Ex0.1)
1. Prepare and submit State plan and negative declarationb	N/A
2. Report Reviews
Review preliminary and final material separation plans and siting analysis b	0	8	0	0	0	$0
ii. Review notification of construction b	0	2	0	0	0	$0
iii. Review notification of startup b	0	2	0	0	0	$0
iv. Review notification of initial performance test b	0	8	0	0	0	$0
v. Review notification of initial CEMS demonstration b	0	4	0	0	0	$0
vi. Review initial performance test report b	0	40	0	0	0	$0
vii. Review initial CEMS demonstration report b	0	40	0	0	0	$0
viii. Review annual compliance report c, d	23	92	2,116	105.8	211.6	$110,754.83
ix. Review semi-annual excess emission report e	4.6	16	73.6	3.68	7.36	$3,852.34
3. Prepare annual summary report	1	200	200	10	20	$10,468.32
TOTAL ANNUAL COST (rounded)f			2,750			$125,000

Assumptions:

^a This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 Managerial rate (GS-13, Step 5, $39.31 x 1.6), $46.67 Technical rate (GS-12, Step 1, $29.17 x 1.6), and $25.25 Clerical rate (GS-6, Step 3, $15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) 2015 General Schedule, which excludes locality rates of pay.

^b No additional sources will become subject to the standard over the next three years. We also assume affected air quality program administrator in States and U.S. territories have already submitted a State Plan and/or negative declaration.

^c Assumes 54 affected units at 23 plants.

^d Assumes four hours to review the annual compliance report for each plant (4 x 23 = 92).

^e Assumes submission of semiannual excess emission reports will be required for 10 percent of units (2.3); (2 x 2.3 = 4.6).

^f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.